TD Bank Is the Most Shorted Bank in the World……. Schwab’s $7 Trillion Empire Built on Low Rates Is Showing Cracks

TORONTO (Reuters) – Hedge fund bets against Canada’s TD Bank Group on Wednesday hit $4.2 billion, making it the most-shorted banking stock globally, according to data provider ORTEX’s calculations, with some analysts concerned about the bank’s exposure to U.S. regional lenders. Around 4.1% of TD’s outstanding shares were out on loan to hedge funds, while the second-most shorted bank stock, JP Morgan, only had $2.3 billion worth of shorts, showed the data. Hedge funds profit when they borrow a stock from an institutional investor and sell it back when the price falls, pocketing the difference, a practice known as short-selling. Turmoil in the banking sector began last month with the collapse of regional banks Silicon Valley Bank and Signature Bank, sparking a crisis of confidence. The Biden administration on Thursday called for stricter rules to reduce future risk.

TD is the midst of acquiring U.S. regional lender First Horizon Corp for $13.4 billion, though some shareholders have urged the Canadian bank to either scrap the deal or renegotiate a lower price.

The First Horizon deal would catapult TD to the sixth-biggest commercial bank in the U.S. from the tenth-largest now, according to the Federal Reserve. The next-largest Canadian bank in the U.S. is BMO, which is number 23 on the list. TD shares are down 15.7% since the beginning of the regional bank crisis and down 3.4% this week. Peer Bank of Montreal (BMO) is down 15.8% over the same time period and is down 2.2% this week. Around 2.9% of BMO’s outstanding shares were out on loan to hedge funds, or about $1.8 billion. A spokesperson for TD was not immediately available for comment. “The bank’s acquisition of First Horizon is also not looking great in the current context,” Eric Compton, equity analyst at Morningstar, told Reuters via email. “TD has the most exposure to the U.S. regional banking system,” Compton added.

He noted TD also has a material stake in Charles Schwab, which is down 40% year to date.

TD awaits regulatory approval of its takeover of First Horizon.

Schwab’s $7 Trillion Empire Built on Low Rates Is Showing Cracks

On the surface, Charles Schwab Corp. being swept up in the worst US banking crisis since 2008 makes little sense. The firm, a half-century mainstay in the brokerage industry, isn’t overexposed to crypto like Silvergate Capital and Signature Bank, nor to startups and venture capital, which felled Silicon Valley Bank. Fewer than 20% of Schwab’s depositors exceed the FDIC’s $250,000 insurance cap, compared with about 90% at SVB. And with 34 million accounts, a phalanx of financial advisers and more than $7 trillion of assets across all of its businesses, it towers over regional institutions. Yet the questions around Schwab won’t go away.  Rather, as the crisis drags on, investors are starting to unearth risks that have been hiding in plain sight. Unrealized losses on the Westlake, Texas-based firm’s balance sheet, loaded with long-dated bonds, ballooned to more than $29 billion last year. At the same time, higher interest rates are encouraging customers to move their cash out of certain accounts that underpin Schwab’s business and bolster its bottom line. It’s another indication that the Federal Reserve’s rapid policy tightening caught the financial world flat-footed after decades of declining rates. Schwab shares have lost more than a quarter of their value since March 8, with some Wall Street analysts expecting earnings to suffer.  “In hindsight, they arguably could have had more prudent investment choices,” said Morningstar analyst Michael Wong. “There would be a sufficient amount of liquidity right there to cover if 100% of our bank’s deposits ran off,” Bettinger told the Wall Street Journal in an interview published Thursday, adding that the firm could borrow from the Federal Home Loan Bank and issue certificates of deposit to address any funding shortfall. Through a representative, Bettinger declined to comment for this story. A Schwab spokesperson declined to comment beyond the Thursday statement. The broader crisis showed signs of easing on Monday, after First Citizens BancShares Inc. agreed to buy SVB, buoying shares of financial firms including Schwab, which was up 3.1% at 2:29 p.m. in New York. The stock is still down 42% from its peak in February 2022, a month before the Fed started raising interest rates. Schwab is unusual among peers. It operates one of the largest US banks, grafted on to the biggest publicly traded brokerage. Both divisions are sensitive to interest-rate fluctuations. Like SVB, Schwab gobbled up longer-dated bonds at low yields in 2020 and 2021. That meant paper losses mounted in a short period as the Fed began boosting rates to stamp out inflation. Three years ago, Schwab’s main bank had no unrealized losses on long-term debt that it planned to hold until maturity. By last March, the firm had more than $5 billion of such paper losses — a figure that climbed to more than $13 billion at year-end. 

It shifted $189 billion of agency mortgage-backed securities from “available-for-sale” to “held-to-maturity” on its balance sheet last year, a move that effectively shields those unrealized losses from impacting stockholder equity. 

“They basically saw higher interest rates coming,” Stephen Ryan, an accounting professor at New York University’s Stern School of Business, said in a phone interview. “They didn’t know how long they would last or how big they would be, but they protected the equity by making the transfer.”  The rules governing such balance sheet moves are stringent. It means

Schwab plans to hold more than $150 billion worth of debt to maturity with a weighted-average yield of 1.74%. The lion’s share of the securities — $114 billion at the end of 2022 — won’t mature for more than a decade.

The benchmark 10-year Treasury yield now: 3.5%. Which means the $150 billion value they book these bands at now in reality are worth $75 billion. and if my prediction is right and the yield goes north of 5% they could be wroth as little as $10 billion dollars…. the dumb fucks

Schwab’s other headache from higher interest rates stems from cash. At the root of Schwab’s income is idle client money. The firm “sweeps” cash deposits from brokerage accounts to its bank, where it can reinvest in higher-yielding products. The difference between what Schwab earns and what it pays out in interest to customers is its net interest income, among the most important metrics for a bank. Net interest income accounted for 51% of Schwab’s total net revenue last year. “Schwab’s counting on inertia,” said Allan Roth, founder of Wealth Logic, a financial-planning firm.  After a year of rapidly rising rates, there’s greater incentive to avoid being stagnant with cash.

While many money-market funds are paying more than 4% interest, Schwab’s sweep accounts offer just 0.45%.

Though it’s an open question just how much money customers could move away from its sweep vehicles, Schwab’s management acknowledged this behavior picked up last year.  “As a result of rapidly increasing short-term interest rates in 2022, the company saw an increase in the pace at which clients moved certain cash balances” into higher-yielding alternatives, Schwab said in its annual report. “As these outflows have continued, they have outpaced excess cash on hand and cash generated by maturities and pay-downs on our investment portfolios.” In their statement, Bettinger and Schwab wrote that “client deposits may move, but they are not leaving the firm.”

To plug the gap, the brokerage’s banking units borrowed $12.4 billion from the FHLB system through the end of 2022, and had the capacity to borrow $68.6 billion, according to an annual report filed with regulators. Schwab borrowed an additional $13 billion from the FHLB so far this year, the filing showed.

Analysts have been weighing these factors, with Barclays Plc and Morningstar lowering their price targets for Schwab shares in recent weeks. Bettinger and Schwab said that the firm’s long history and conservatism will help customers navigate the current cycle, as they have for more than 50 years. “We remain confident in our client-centric approach, the performance of our business, and the long-term stability of our company,” they wrote in last week’s statement. “We are different than other banks.” NN: Yea they are different. They charge you 0 commissions your trades and fuck you out of 4% interest on your funds they hold….. and are losing on long term instruments that are underwater.

BlackMask Pod Cast also posted in BlackMask Market news and commentary:

Charles Schwab is UnderWater

Saudi Aramco Hikes Crude Prices To Asia

Just days after the unexpected OPEC+ oil production cut, Saudi Aramco, the Saudi state-owned oil company, has raised prices of crude to Asia by 30 cents per barrel. The price hike in Aramco’s flagship Arab Light crude to Asia for May delivery represents the 3rd  monthly increase in a row, Bloomberg reports.  The move to increase the May OSP was not unexpected, though prior to the surprise OPEC+ announcement traders surveyed by Bloomberg had expected Arab Light prices to fall by 43 cents per barrel. Earlier this week, analysts speculated that Aramco could potentially hike May crude prices to Asia by 20 cents per barrel, to $2.7 per barrel, based on a Reuters survey of Asian refiners.

Already tight supply will now be further squeezed with the additional 1.6 million bpd cut. This, in turn, will increase the upward momentum for Middle East medium and sour grades, which are closing that gap with light grades, Reuters reports.

The benchmarks major GCC producers use to price their crude bound for Asia have soared, narrowing the gap with the price of Brent Crude in the past couple of days. Analysts are not discounting the possibility for Dubai crude to entertain a premium to Brent in the coming months, with China’s economic recovery. PetroChina is forecasting a 3% rise in refined fuel demand this year, from 2019, while other state-sponsored Chinese analysts are eyeing a 7.8% increase in oil refinery throughput. While Wednesday’s OSP increase was anticipated in light of the OPEC+ output cuts, the first in the three consecutive hikes that came in February took the market by surprise. The February hike for March OSP of 20 cents per barrel (to a premium of $2 a barrel over the Dubai/Oman average) was the first increase in six months and was primarily based on Chinese demand expectations.  The May OSP price increase further solidifies analysis that the Saudis view coming Chinese demand as particularly robust.
Saudi Aramco sells some 60% of its oil to Asia. NN: After all its a CHINA binary trade.

Gold hits new 1-year high after US jobs data

The price of yellow metal broke over $2,000 on Tuesday, reaching its new one-year high following the release of data on the United States’ labor market, which showed a large drop in the country’s job openings. The lower-than-expected job openings figure in February could indicate that the United States labor market might be slowly cooling off following Federal Reserve’s aggressive monetary tightening to tame the raging inflation in the country. The traders will now shift their focus to nonfarm payrolls, slated for release later this week. Gold jumped 1.62% to go for $2,016.40 per ounce at 10:16 am ET, hitting its highest level since March last year. Silver surged 2.73%, selling at $24.64 per ounce at the same time. Platinum gained 1.84% to $1,011.91 per ounce and palladium rose 0.86% to go for $1,464.13 per ounce. NN: Gold is screaming out sell me. We are at the ending stage of inflation because the FED knows it has got to raise rates to kill inflation. the gold rally is ending its peeking….. FED FUNDS will be north of 6%.  We are within 200 bases points of fed funds peeking….. its closer to the end of the inflation cycle. IF you trade as you should you need to look over the horizion. And it tells me soon its time to lock in higher rates, sell stocks and prepare for the coming  real estate and stock market crash. And yes oil will peek between 100 to 150 a barrel.

so we want to:

be long oil

short gold

short stocks

short real estate

and get ready to lock in long rates on treasuries

Higher Prices At The Pump are Coming…… Fitch: OPEC+ output cuts may lead to market deficit in H2…….. IEA warns OPEC+ output cut will push prices higher

The OPEC+ plus announcement Sunday that it would cut production by 1.6 million barrels per day led to an immediate increase in gasoline futures, which will be passed on to consumers quickly.
Wholesale gasoline prices as reflected in the RBOB were up 3.14% at 11:55 a.m. EST on Monday.  Meanwhile, AAA showed the national average price per gallon at the pump as $3.506, up from $3.439 a week ago.  “I think OPEC is reawakening the inflation monster,” said Tom Kloza, global head of energy analysis for OPIS, which tracks gas prices for AAA, as saying.

“The White House has to be shocked and major-time pissed. It certainly alters the calculus for a while.”

Kloza warns that prices at the pump could run up to $3.90 in a short time frame, though he dismissed fears that prices could spike beyond in the medium-term.  Just last week, ahead of the OPEC+ announcement, gasoline prices were starting to trend higher, with analysts blaming high demand and low supply.  For the week ending March 24, gas reserves fell to 226.7 million barrels, from 229.6 million barrels, while there was a narrow increase in demand, according to the Energy Information Administration (EIA). At the time, AAA said “we may be seeing a return to seasonal trends in demand with warmer weather and longer days, but waffling oil prices could mitigate any increase at the pump for now.”

Oil prices could continue to march higher, with the International Energy Agency warning that OPEC+ cuts could add fuel to the inflationary fires. Various analysts, in the meantime, warn that oil could even reach $100 by June, putting further pressure on consumers in the summer driving season.

“The new cuts are underpinning that the OPEC+ group is intact and that Russia is still an integral and important part of the group,” SEB analyst Bjarne Schieldrop said, as reported by Reuters.

Fitch: OPEC+ output cuts may lead to market deficit in H2

Fitch Ratings said on Tuesday that it expects the latest production cut agreement by OPEC and its allies to support crude prices in the short term, but warned it could lead to the market switching into deficit in the second half of the year. “The decision on production cuts increases the likelihood of the market switching into deficit this year as demand will increase by 2MMbpd in 2023, according to the US EIA’s estimates, mostly because of China reopening, which will account for about half of demand growth,” the ratings agency noted. Fitch added it still sees Brent crude averaging $85 per barrel this year and declining from next year but now believes there is “a greater upside to our oil short-term price assumption.” Over the weekend, OPEC+ unexpectedly agreed to cut output by almost 1.2 million barrels per day from May until the end of the year, causing crude futures to skyrocket.

IEA warns OPEC+ output cut will push prices higher

The International Energy Agency (IEA) warned on Monday that the surprising production output cut by the OPEC+ countries will only further increase crude prices amid “strong inflationary pressures.” The agency had previously predicted that the world’s oil markets would start to tighten in the second half of 2023, with the possibility of a sizable supply shortfall. “The new OPEC+ cuts risk exacerbating those strains,” the IEA said in the statement, warning that the decision will mostly affect “vulnerable” customers around the world. The United Arab Emirates, Kuwait, Oman, Iraq, Kazakhstan and Algeria joined Saudi Arabia in the decision to lower oil production.

 

OPEC+ Cut Makes Oil Balance Look “Insanely Bullish” For Later This Year

The surprise OPEC+ cuts are making oil balances look “insanely bullish” for later this year, provided that the global economy holds up, Amrita Sen, founder and director of research at Energy Aspects, said on Monday. On Sunday, OPEC+ members, led by Saudi Arabia and other major Middle Eastern producers, announced a fresh combined cut of 1.16 million bpd until the end of this year, on top of Russia’s announcement that its own 500,000-bpd cut until June would be extended to the end of 2023, too. Saudi Arabia will cut 500,000 bpd of its production starting in May and is joined by OPEC heavyweights Iraq, the United Arab Emirates (UAE), and Kuwait, plus OPEC’s Algeria and Gabon, and non-OPEC Oman and Kazakhstan. Prices rallied on the news on Monday morning, and the U.S. benchmark WTI Crude bounced back to above $80 per barrel. The latest cuts come on top of the 2 million bpd cut announced in October 2022 and running through the end of 2023. All those cuts are expected to tighten the market further in the second half of the year. Tightening was already evident in some counter-seasonal drawdowns in March, Energy Aspects’ Sen told CNBC today. “The pure oil market fundamentals are not bullish, but they are ok,” Sen added. But as long as the economy is holding up – and that’s a big ‘if’ – and Energy Aspects already has a mild recession baked in, then “it is looking a very, very bullish second half of the year,” she noted. Asked if we will see oil at $100 this year, Sen told said “I absolutely think we will see a $100 oil, yes.” Hours after OPEC+ announced the new cuts, Goldman raised its Brent Crude forecast to $95 from $90 at the end of the year. The bank also raised its Brent Crude forecast for 2024, now seeing it at $100 at the end of the year from an earlier projection of $97.   NN: I see $150 dollar oil in the next 12 months. After all its a binary trade.. And everyone is helping us….

Trigger for Saudi oil production move was comment that U.S. would not refill SPR this year, report says

Energy Secretary Jennifer Granholm last month said it would be difficult for the U.S. to take advantage of low oil prices to replenish the Strategic Petroleum Reserve because of maintenance at two of the four sites. The Financial Times reported, citing people familiar with Saudi Arabia’s thinking, that Riyadh was “irritated” by that comment. In any case, it came on top of stress in the financial sector that had dragged oil prices as low as $64 in March. And while prices did bounce back — ending the month at nearly $76 — OPEC’s producers felt the need to act, which they did in voluntary moves to reduce production by over 1 million barrels starting in May. The question now is the degree that OPEC will follow through with its pledge. Henri Patricot, an analyst at UBS, says there’s reason to think they will, as the countries that announced the voluntary reduction were producing close to their quotas. “As such, we would expect the actual production cut to be close to the headline number this time,” said Patricot. Granted, some analysts said the real surprise was that OPEC hadn’t already acted. “Since last November our global oil supply-demand balance suggested a strong policy action was needed to keep global oil surpluses in check,” said JPMorgan analysts led by Natasha Kaneva, who left their oil price view unchanged that the Brent contract will end the year at $96. Unlike the last time OPEC and its allies acted preemptively — in October — the momentum in global oil demand is up not down with a strong China recovery, as well as backwardated forward curve and resilient refining margins, said analysts at Goldman Sachs led by Daan Struyven.

Oil prices soar after Saudi Arabia leads coordinated OPEC+ cuts totaling more than 1 million barrels a day……. Goldman Sachs Raises Oil Price Forecast Following OPEC+ Cut

Oil prices spiked, after Saudi Arabia led a surprise oil production cut across several OPEC+ nations that will remove more than 1 million barrels of oil a day from May. In an announcement on Sunday, Saudi Arabia’s Ministry of Energy stated that the kingdom will implement a voluntary cut of 500,000 barrels a day from May until the end of 2023, in conjunction with other countries. It said that the “voluntary cut is in addition to the reduction in production” agreed at the OPEC meeting in October and “is a precautionary measure aimed at supporting the stability of the oil market.” OPEC+ agreed in October to cut production by two million barrels a day from November, a move that angered the Biden administration. Russia’s deputy prime minister, Alexander Novak, said his country would extend a March production cut of 500,000 barrels a day through the end of the year. OPEC+ is made up of members of the Organization of the Petroleum Exporting Countries and its allies, including Russia. “Today, the world oil market is experiencing a period of high volatility and unpredictability due to the ongoing banking crisis in the U.S. and Europe, global economic uncertainty and unpredictable and shortsighted energy policy decisions. At the same time, predictability in the global oil market is a key element in ensuring energy security,” Novak said in a statement. The cuts come after a first quarter that saw a sharp decline in crude prices. Oil bulls were disappointed that China’s lifting of strict COVID curbs didn’t provide stronger support to prices, while aggressive tightening by central banks and fears that banking woes in the U.S. and Europe could turn into a full-fledged crisis stoked recession fears. Elsewhere, Kuwait’s oil ministry said the country will cut 128, 000 barrels a day, while the United Arab Emirates said it would cut its production by 144,000 barrels a day, according to a statement by Energy Minister Suhail Al Mazrouei, reported by Attaqa Breaking News. Oman said it would implement a voluntary cut of 40,000 barrels a day. Kazakhstan said it would cut by 78,000 barrels a day and Algeria said it would cut by 48,000 barrels a day. Ole Hansen, chief commodities strategist at Saxo Bank, said the announcement “came out of the blue.” “Producers were clearly frustrated by the recent slump which was speculative more than fundamentally driven. They will likely achieve a return to the $80s while also trying to pre-empt a smaller than expected increase in global oil demand in the coming months. Remember most of the +2 m b/d increase expected for this year is backloaded into the second half with plenty of room for error should economic slowdown be as severe as currently priced in by the market through expectations of U.S. rate cuts,” Hansen told MarketWatch.

“The Saudi oil minister love[s] to wrong foot the market, especially when it comes to hurting speculative short sellers,” said Hansen.

The move also comes as the U.S., Europe and elsewhere continue to battle inflation. Oil prices have fallen sharply over the last 12 months, after spiking to more than $120 a barrel following Russia’s invasion of Ukraine last year. Brent was down roughly 24% from a year earlier at Friday’s close.

The new cuts, if fully implemented, should make for a significant draw on crude inventories in the second quarter as opposed to previous expectations for an early third-quarter draw, said Giacomo Romeo, energy equity analyst at Jefferies, in a note.

“The only potential downside to this decision is that bears in the market could perceive the cut as a validation of the recent demand concerns,” he wrote, noting that compliance with past targets has also been in issue. The U.A.E., for example, was seen producing around 200,000 barrels a day above its target for a few months, while Russian output in March didn’t see the full 500,000 barrel-a-day reduction announced in February, Romeo noted.

Goldman Sachs Raises Oil Price Forecast Following OPEC+ Cut

It said that the “voluntary cut is in addition to the reduction in production” agreed at the OPEC meeting in October and “is a precautionary measure aimed at supporting the stability of the oil market.” OPEC+ agreed in October to cut production by two million barrels a day from November, a move that angered the Biden administration.

“We would argue you are buying the dip at this point,” the banl’s head of commodities Jeffrey Currie said, adding,

“I have never seen a market sell off that sharply, but retain a bullish structure.”

“Today’s surprise (production) cut is consistent with the new OPEC+ doctrine to act preemptively because they can without significant losses in market share,” the investment bank said, as quoted by Reuters. OPEC+ announced an unexpected update to its production cuts, to the tune of 1.16 million bpd, with Saudi Arabia accounting for the lion’s share, at 500,000 bpd. According to unnamed sources who spoke to the Financial Times, Riyadh had been annoyed by the Biden administration’s decision to delay the start of oil purchases for the SPR.

Prices of precious metals fall, Silver drops 2%

https://media.dailyfx.com/illustrations/2016/06/17/Silver-Prices-Turn-and-Burn-Precious-Metals-Headed-Lower-PRtech_body_silverdaily.png

Precious metals prices declined Monday as the dollar’s value increased. At 12:10 am ET, the dollar index was up 0.43% to 103.0272, while the greenback increased by 0.48% against the euro to sell for 0.92658. The American currency started the week higher after the OPEC+ announcement that it would reduce the production of the commodity by more than 1 million barrels per day. At 12:11 am ET, Silver dropped 2.08% to sell at $23.60 per ounce, and gold fell 0.97% to $1,950.94 per ounce. At the same time, palladium gained 0.59% to go at $1,453.72 per ounce, while platinum grew 0.75% to $985.77 per ounce.

Crude oil prices surge 7% after surprise production cut……. Novak: Russia slashing oil output by 500K bpd

Crude oil futures rose 7% on Monday during early trading in Asia after OPEC+ made a surprise announcement to cut oil production by more than 1 million barrels per day. Saudi Arabia first said it would cut supply by 500,000 barrels per day. Then, other members, such as Kuwait, the United Arab Emirates, and Algeria, joined in. At the same time, Russia stated that the production cut implemented from March to June would continue until the end of 2023. For June contracts, Brent gained 7.29% to $85.58 per barrel, while for May, West Texas Intermediate (WTI) rose 7.44% to sell at $81.25 per barrel at 12:06 am ET.

Novak: Russia slashing oil output by 500K bpd

Russian Deputy Prime Minister Alexander Novak confirmed that Moscow agreed to follow through with the cut in oil production which was announced by Saudi Arabia and the United Arab Emirates on Sunday. According to Novak, Russia will cut its production by 500,000 barrels per day (bpd) until the end of June in coordination wit its OPEC+ allies. Novak criticized the “short-sighted energy policies of the Western countries” and their attempts to introduce a price cap mechanism, warning that these policies create significant risks for global energy security and impact consumers. Kazakhstan also announced a voluntary cut in oil production by 78,000 bpd from May until the end of 2023. NN: I WANT to tell you i told you so. This is the death knell for inflation…… Its off to the races with the FED raising rates…..

OPEC+ Makes Surprise 1 Million-Barrel Oil Production Cut

Saudi Arabia, UAE, Kuwait among countries who announce cut to oil ...

  • Saudi leads cartel with its own 500,000 supply reduction
  • Members including Iraq, Kuwait, UAE, Russia also contribute

OPEC+ announced a surprise oil production cut that will exceed 1 million barrels a day, abandoning previous assurances that it would hold supply steady to maintain a stable market.

That’s a significant reduction for a market where — despite the recent price fluctuations — supply was looking tight for the latter part of the year. Oil futures weren’t trading when the cut was announced on Sunday, but the inevitable price reaction could add to inflationary pressures across the world, forcing central banks to keep interest rates higher for longer and amplifying the risk of recession.  Saudi Arabia led the cartel by pledging its own 500,000 barrel-a-day supply reduction. Fellow members including Kuwait, the United Arabia Emirates and Algeria followed suit, while Russia said the production cut it was implementing from March to June would continue until the end of the 2023.

The initial impact of the cuts, starting next month, will add up to about 1.1 million barrels a day. From July, due to the extension of Russia’s existing supply reduction, there will be about 1.6 million barrels a day less crude on the market than previously expected. 

Country Size of cut (b/d)
Saudi Arabia 500,000
Russia 500,000
Iraq 211,000
UAE 144,000
Kuwait 128,000
Kazakhstan 78,000
Algeria 48,000
Oman 40,000

The move could once again flare tensions between the US and Saudi Arabia, a regional partner whose relationship with President Joe Biden’s administration has been tense. The White House did not immediately respond to a request for comment.  NN: These are massive cuts. This is a unfolding story…. More later