Month: September 2025

Source: Airservices Australia

Introduction

It is a privilege to be invited to address the Board of CLS – or ‘Continuous Linked Settlement’ in longhand – on what I believe is your first meeting in Australia.

CLS is hardly a household name. But what it lacks in ‘rizz’, it more than makes up in the critical role it plays in the international financial architecture: massively reducing the risk of settlement failure in the global foreign exchange (FX) market.

As you all know, but is worth repeating for a wider audience, settlement risk is a particularly important issue in FX markets because of the time differences between the major currency blocs. It would be all too easy to pay away one leg of FX transactions during the business hours of that currency, in anticipation of the return leg being paid when the other country wakes up – only to find that second leg interrupted, leaving large, unsettled liabilities. Exactly that happened when the Cologne-based Bankhaus Herstatt was liquidated in 1974 at the end of German banking hours – after Deutsche Mark payments had been made, but before the return US dollar legs had settled. Chaos ensued.

The sums involved in FX markets are truly massive – over US$7.5 trillion a day in 2022, and set to have grown substantially since then. So getting this right matters critically for financial stability. The CLS solution seems obvious today: ensure that payments on both legs are made simultaneously, in central bank money, in each national real time gross settlement system. But it was 22 years after Herstatt before the international community settled on this plan, and another six before CLS opened for business in 2002. So I suppose it shouldn’t be surprising that it’s taken another 23 years to welcome the Board to Sydney!

From the start, Australia has been a close partner in CLS’s development. The Australian dollar was one of the seven founding CLS currencies – so we’ve had an operational relationship with you, every day, since the very beginning. On the regulatory side, too, CLS is categorised as a systemically important international payment system in Australia; and we sit on the regulatory college for CLS, chaired by the Federal Reserve Bank of New York.

The Australian dollar itself has long punched above its weight in global markets. It had the sixth highest daily turnover of any currency in the 2022 BIS Triennial survey, despite Australia ranking only 11th by nominal GDP at the time (Table 1). None of the other top 10 currencies in Table 1 has that level of outperformance while operating a completely free float.

That special status reflects three main things:

1. As a major commodity exporter, Australia’s economic conditions are sensitive to the outlook for global growth; Australian dollar assets have therefore been seen as a good way for investors to manage their risk, gaining ‘risk on’ exposure by going long, or hedging risk by going short.
2. Australia’s geographical position, its openness to capital and its developed FX hedging markets, mean it was historically used to gain proxy-exposure to Asian economies whose currencies are harder to invest in, or where it is harder to issue debt.
3. Australia’s superannuation (or pension) funds are investing an ever-increasing amount overseas. Even today, the sums are huge: Australian retirement savings are the fourth largest in the world, with assets equivalent to around 150 per cent of Australian GDP, half of which are offshore. And that is set to grow further: within a decade the sector will be the second largest globally, with assets rising to around 180 per cent of GDP, and an overseas portfolio share approaching three-quarters.

All of this may be great news for Australian dollar volumes! But it also puts us bang at the heart of a quite exceptional period of uncertainty about the future direction of the global economic and financial system. Some argue we are on the verge of a fundamental shift, with the world breaking into rival, fragmented trading blocks, and a collapse in US dollar hegemony. Others wonder if this may all be a bit overblown, with the global trading system proving more robust, and the US dollar’s role too embedded, to see a serious challenge – for now, at least.

I cannot hope to resolve these profound questions today, but I do want to look at what this uncertainty may mean for Australian investors, and particularly the super funds, as they look out into a turbulent world – and how it could affect the ways they think about managing currency risk in their global portfolios, both now and in the years ahead.

Through a hedge backwards: Australia’s natural advantage?

Australians have always been big overseas investors, both for standard diversification reasons, and because the onshore asset base is relatively small. But they have typically taken only modest levels of protection against FX movements on their riskier overseas asset holdings. The superannuation sector as a whole is estimated to hedge only around one-fifth of the value of its overseas listed equity positions, for example (Graph 1).

To see why that might be, let’s start by reminding ourselves that, other things equal, Australian investors holding US dollar denominated equities are worse off when the Australian dollar appreciates (or equivalently the US dollar depreciates). They can insure against this risk by using FX swaps or forwards to take short positions in the US dollar (against long positions in their own currency). But buying derivatives is often costly – so the benefit from doing so has to justify the cost.

One factor reducing that benefit is the extent to which FX movements can be expected to provide a kind of ‘natural’ hedge against the equity holdings. That would happen in our example if the Australian dollar tended to depreciate against the US dollar when US equity prices fall, offsetting some of the offshore capital losses when converted back to domestic currency. But historically that is exactly what has happened: first, because the US dollar has typically been viewed as a safe haven or ‘risk off’ currency that rises when global conditions are bad; and second, for the reasons I mentioned earlier, the Australian dollar has been seen as one of the standout ‘risk on’ currencies that tend to depreciate when global economic prospects weaken and/or risk-sentiment deteriorates. On that score, the Australian dollar has historically provided a pretty decent ‘natural’ hedge (Graph 2, left hand panel).

If the volatility in the Australian dollar is lower than that in overseas equity returns – as it has been in recent years (Graph 3) – that also reduces the need to take out an explicit hedge, because it just doesn’t form a large part of overall portfolio volatility.

There are several different ways to factor these considerations into a specific quantified hedge ratio. One approach is to calculate the hedge needed to minimise the variance of portfolio returns. I won’t plough through the formalities of how to do that here – and the calculations can be sensitive to assumptions. But the punchline is that – historically speaking – the Australian dollar’s strong correlation with US equities, and its low relative volatility, mean the minimum variance equity hedge ratio has been pretty low. Indeed on some measures it comes quite close to the average levels actually chosen by Australian industry super funds.

For some currencies, such as the Japanese yen, low hedge ratios for US assets have also been driven by high hedging costs, reflecting material differentials in short-term interest rates . But this has not been a dominant factor in Australia (Graph 4).

The times, are they a-changin’?

The debate on everyone’s mind is whether the paradigm underpinning those correlations I’ve just been through is now shifting.

The oft-cited case for the prosecution is that, amidst the huge increase in market uncertainty earlier in 2025 – a situation in which the US dollar would normally be expected to act as a safe haven – the dollar in fact depreciated: falling by around 8 per cent on a trade weighted basis relative to its January peak, with a little under half of this coming in the weeks following the announcement of the Liberation Day tariffs (Graph 5). Dire predictions abounded, including a rumoured mass exodus from US assets, and fears of the end of dollar hegemony in international capital markets.

Uncertainty obviously remains high, and there is still a great deal of water to flow under the bridge. But, to paraphrase Mark Twain, predictions of the death of the US dollar and the Australian hedging model appear somewhat premature, for four main reasons:

1. There is little evidence yet that international investors have substantially reduced their holdings of US assets: indeed the latest data suggest that foreign capital continues to flow into the US (in net terms), particularly on the equity side (Graph 6). Capital inflows into Australia did pick up a little in the June quarter – but the numbers so far do not look materially out of line with historical averages (Graph 7).

2. The correlation between movements in US equity prices and the Australian dollar remained close to its historical average through the recent market turmoil, with the Australian dollar initially depreciating sharply alongside falling equity prices. That is quite different to correlations with some of the other major currencies (Graph 2, right panel).
3. Implied volatility in the exchange rate between the Australian dollar and the US dollar has remained lower than that in US equities.
4. The cost of hedging against FX risk for Australian investors has been little changed (Graph 4).

Investors in some other countries do appear to have increased their hedging ratios in response to Liberation Day, with market attention focused on institutional investors in Europe and parts of Asia. Those additional hedging flows may have played some role in amplifying the US dollar’s decline for a period earlier in the year. In Australia, the super fund sector also increased its equity hedges in the June quarter (Graph 2) – but the pick-up was only small, and market participants report little current expectation of a more material increase in the near term.

Some more structural challenges for super funds’ FX hedging

But none of this means we should be complacent about the scope for a more material regime shift over time. Uncertainty remains elevated, and we are yet to see the full economic implications of the changes to US tariffs play out. It is encouraging therefore that many super funds are strengthening their capacity to think through and manage FX and other liquidity risks.

That also matters because, even if super funds’ average hedge ratios change little in the near term, the size of the market-wide FX hedge book is set to grow significantly over longer horizons, for three reasons:

1. As I noted at the start, total super fund assets are projected to grow from around 150 per cent to 180 per cent of GDP over the next decade.
2. The share of this larger pie devoted to overseas assets is set to rise, given the size of the super fund pool relative to the stock of domestic financial assets.
3. As super funds’ members age over time, they are likely to demand greater certainty of returns, driving super fund portfolios away from equity and towards fixed income. But FX hedge ratios for foreign currency fixed income assets are typically much higher than those for equities, reflecting the very different shape of asset returns and correlations.

The first of these factors alone could see the superannuation sector’s total FX hedge book, currently estimated to be of the order of AUD½ trillion, to double over the next decade. The other two factors will increase this number by some further multiple over the coming years.

Such changes would of course reflect prudent risk management on the part of individual firms. And they would barely touch the sides of a global FX swaps market that exceeds US$100 trillion in stock terms. But they are large relative to the current size of the Australian dollar FX swaps market. And the terms on which FX hedges are typically offered to super funds today are relatively capital-intensive for the swap providers. So it is likely that super funds will have to extend and diversify their pool of hedge providers over time to avoid hitting concentration limits. They may also be asked to meet increased margining and collateral requirements on their hedging positions.

Many super funds are already thinking hard about what these changes could mean for their future liquidity management. One aspect is ensuring they have sufficient resources to meet potential short-run liquidity needs – for example, to cover increased replacement costs for maturing FX hedges if the Australian dollar depreciates. Those potential liquidity needs appear manageable today under most scenarios. But they will grow over time as the hedge book increases in size. And the practice of using relatively short-term derivatives to hedge much longer term investment – though common amongst many institutional investment communities – means super funds are reliant on continuous access to functioning FX derivatives markets. If these markets were to become impaired such that rolling these hedges became difficult or prohibitively expensive, as occurred during episodes of US dollar funding stresses in both 2008 and 2020, super funds would either need to sell foreign assets or face unhedged foreign currency exposures for a period, both of which could be undesirable in a period of market volatility.

Australian banks also rely on the smooth functioning of such markets – in particular, to hedge their foreign-currency denominated funding back to Australian dollars to fund their (mostly) Australian dollar assets. However, their exposure is somewhat mitigated by the fact that their hedges are typically duration-matched to their funding.

System-wide liquidity risks are being explored in APRA’s inaugural system stress test, and we look forward to seeing the results of this work.

Staying on top of FX settlement risk in the region

All of this increased FX activity may seem like good news for FX markets and hence for CLS – and well it may be. But against the backdrop of such a big increase in scale and a huge range of uncertain and unpredictable macro risks, the need to ensure we retain a laser focus on mitigating settlement risk has never been greater.

The first priority, clearly, is to ensure that as many eligible transactions as possible go through CLS. I look forward to seeing the results of the new global survey on FX settlement data, designed by my old colleague Philippe Lintern and team at the Bank of England, and carried out as part of the BIS’ 2025 Triennial exercise. And I would be interested to hear your estimates of how widely Australian firms active in FX use your service. Five years ago, CLS estimated that around 75 per cent of Australia’s 20 largest super funds used CLS to settle their FX trades – which sounded good but left me wondering what the remaining 25 per cent did, and how this number has evolved since then. Perhaps you can enlighten me today! Given the growth expected in that sector it is important to pursue this issue with gusto.

Just as global fragmentation poses risks to the macro outlook, so it also poses risks to the ongoing goal of eliminating FX settlement risk. As Table 1 shows, a number of key currencies in the Asia Pacific region remain outside CLS – specifically the Chinese Renminbi, the India Rupee, the New Taiwan Dollar and the Thai Baht. I do not underestimate the challenges involved, but we should do all we can, where we can. Extended cutoff times for CLS settlement could help with greater global reach too.

Fragmentation, and the geopolitical risks that come with it, poses heightened cyber and operational risks – issues that I know have preoccupied you as a Board for some time.

And of course there is always the possibility that rival payment systems, built on less sound principles could cannibalise transactions that currently go through CLS. I sympathise with you that it can be hard to keep up with the hype cycle on this front – from Distributed Ledgers to Central Bank Digital Currencies to today’s topic du jour, stablecoins. But it is important that you do, because we must ensure that whatever emerges from this process is as robust as what preceded it. That is why, here in Australia, we are experimenting with new ways of enabling central bank money to circulate on innovative payments platforms through Project Acacia. I look forward to hearing an update of CLS’ own work in this area.

Conclusions

Let me conclude.

Your visit comes at a critical moment in the history of the global economic and financial system. Uncertainty is at an all-time high – and many of the principles on which we have long relied are in flux.

Against that backdrop, I have devoted much of my remarks today to reviewing how fragmentation could change the way Australian investors approach currency risk management. So far, little fundamental seems to have changed – the Australian dollar has remained a well-functioning ‘natural’ hedge for global risky assets, and hedging costs are relatively low. But that could all change rapidly – and the structural trends towards growing super fund balances, much of which will have to be invested overseas, makes it ever more important that super funds in particular scale up their risk management and scenario planning capacity. Done successfully that should further add to other resilient features of the system – including the fact that super funds are mostly defined contribution (not defined benefit) schemes, are not levered, and have access to those deep and liquid FX markets that I described earlier.

As a founder currency of CLS, a co-regulator and a leading global currency, we care deeply about furthering the mission of eliminating FX settlement risk. In that context, it is wonderful to see the progress CLS has made, and we look forward to continuing to do all we can to help in that endeavour.

Source: New South Wales Community and Justice

Fatal trailbike crash, Norwood

Tuesday, 16 September 2025 – 1:59 pm.

Sadly, a 17-year-old boy has died as a result of injuries sustained in a two-vehicle crash at Norwood, Launceston, last Saturday night.
The boy was one of two male teenagers injured in a collision between a trailbike and a Subaru SUV at the roundabout intersection of Boiton Hill Road and Norwood Avenue, about 8.45pm on Saturday.
The teen was a pillion passenger on the trailbike.
A second 17-year-old driving the motorcycle sustained leg and pelvic injuries and is receiving treatment in hospital.
The driver of the SUV was not physically injured.
Anyone with information or relevant dash-cam footage, is asked to contact police on 131 444 or Crime Stoppers on 1800 333 000 or at crimestopperstas.com.au. Information can be provided anonymously. Please quote (reference 000398-13092025) if providing information.
Our thoughts are with the boy’s family and loved ones.
A report will be prepared for the coroner.

Source:

Will, Matilda, Alannah and Karen Wanless, Yarrambat Fire Brigade’s Sue Mountain and Good Friday Appeal’s Claire O’Riordan.

A Plenty Fire Brigade volunteer will be remembered as keen, enthusiastic and humble by Yarrambat and Plenty Fire Brigade volunteers, with two commemorative plaques created in his name.

Respected firefighter Greig Wanless, who passed away in April 2024, was a member of the team each year when the volunteers worked the Yan Yean/Ironbark Rd intersection, collecting donations for The Royal Children’s Hospital Good Friday Appeal.

The Brigade’s annual collection, first organised by Yarrambat Fire Brigade 11 years ago, has raised close to $85,000 for the hospital.

The two brigades will each display a plaque, recording the amount raised each year by their cooperative efforts.

On Sunday 14 Septenber, Yarrambat brigade’s Sue Mountain told a group of people celebrating Greig’s service that he was a regular member of the Good Friday team, a great friend and passionate about the cause of helping the hospital.

In honouring Greig, Claire O’Riordan, Community Fundraising Manager for the Good Friday Appeal, spoke of the commitment of all CFA volunteers to the annual Royal Children’s Hospital Appeal.

“It’s the people’s charity that improves the lives of children, and we will be forever grateful,” Claire said.

Greig’s wife Karen unveiled the plaques at Yarrambat Fire Station on Sunday, with their children Alannah, Matilda and Will, brigade volunteers and Good Friday Appeal representative Claire O’Riordan.

For information about the Good Friday Appeal, go to the official website. 

Submitted by	Peter Beaton

Source: Northern Territory Police and Fire Services

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Source: New South Wales – News

The intensive search, with the assistance of Port Lincoln and Australian Federal Police officers, is focusing on a property in Pamir Court at Port Lincoln.

The new search is using specialised radar equipment provided by the AFP. It is expected to take several days to complete.

Susan Goodwin was reported missing on Friday 19 July 2002 from her home address in Moonta Crescent at Port Lincoln.

Susan was last seen around lunchtime that day, after shopping at Coles and Woolworths in Port Lincoln.  At about 4.45pm Susan’s vehicle was found in the driveway of her home address.

Police believe Susan has been murdered.  Extensive searches in areas surrounding Port Lincoln over the past two decades have been unsuccessful in locating her remains.

Major Crime Investigation Branch Detective Inspector Andrew Macrae said today’s renewed search for her remains follows an ongoing review of the cold case and all available evidence.

“It is a tragedy that Susan’s family have spent the last 23 years without answers,’’ he said.

“Major Crime Detectives will continue to actively investigate this and all cold case crimes to provide families with the answers they are seeking and bring those responsible to justice.”

Det. Insp. Macrae said ongoing investigations have eliminated several persons of interest from the inquiry, but detectives believed there are still individuals in the Port Lincoln community who have knowledge of what happened to Ms Goodwin.

A reward of up to $200,000 is available to anyone who provides information and assistance that leads to the conviction of the person or persons responsible for the suspected murder of Ms Goodwin and/or leading to the location and recovery of her remains.

Anyone with information that could assist the investigation to call Crime Stoppers on 1800 333 000 or report online at https://crimestopperssa.com.au/.

*Note – There is no link to today’s development and the murder of Port Lincoln man Julian Storey in June. An update on the renewed search will be provided later today.

Source: Australian Parliamentary Secretary to the Minister for Industry

The Australian Bureau of Statistics has delivered the latest annual update to the Measuring What Matters dashboard as part of the Government’s wellbeing framework.

This is about measuring what matters most to Australians to help deliver better outcomes for our people, our communities and our economy.

This annual update to the dashboard is the second since the first Measuring What Matters Statement in 2023.

The dashboard brings all the publicly available data together in one place and allows anyone to explore the trends which drive wellbeing in Australia under five themes: healthy, secure, sustainable, cohesive and prosperous.

Today’s release updates 44 of the 50 dashboard indicators under these themes.

The data shows a range of improvements including moderations in rental growth and mortgage interest costs, a greater share of lands and waters dedicated to conservation, and continued progress to boost renewables in our economy.

It also highlights challenges, such as a marked decline in the share of Australians who feel safe based on their view of world events over the year to 2025.

We know that timeliness of data releases is a vital part of this framework to improve wellbeing and inform policy change and that’s why we’re providing $14.8 million over five years for the ABS to deliver the General Social Survey on an annual, on‑going basis from 2025.

The results of the revitalised survey will be incorporated into next year’s Measuring What Matters Statement, which will examine trends in more depth to better reflect on how we are tracking over time, where we’re doing well and where we can do better.

The data from the expanded survey will also be used to inform the annual dashboard, by increasing the number of metrics updated annually.

Our wellbeing framework is all about helping to build a stronger, more productive, and more resilient nation that provides more opportunities and delivers a better future for more Australians.

Better data will help deliver better policy outcomes for more Australians and these insights will play an important role in informing government decision making.

Source: New South Wales – News

Just after 2pm on Monday 15 September, police and emergency services were called to the Port Wakefield Highway, to reports of a single vehicle crash.

Police and emergency services were quickly in attendance with road closures are in place with northbound traffic down to one lane and speeds reduced in the area.

Police ask all road user to avoid the area where possible.

Source: New South Wales – News

The 19-year-old lost control of his motorcycle when he applied the brakes suddenly, crashing his into a roadside guard rail.

His parents, Stuart and Andrea, have generously donated his pride and joy to the South Australia Police (SAPOL) Road Safety Centre in the hope that others can learn from Nathan’s story and protect themselves on the road. They shared this about Nathan:

“Nathan was a kind and caring person, that cared more about others than himself, he had just started to live his life, leaving school and starting his career in motor mechanics, where he never lived down his questionable hair cut giving him the nickname of mudflap,  he was your typical teenager enjoying life, going out with his mates living for the weekend going for ride.  His crash has forever changed our lives, and our family will forever have a part of us missing.  We miss his laughter, the jokes, and the occasional bickering between him and his sister, and there is not a moment in the day we don’t think of him.”

Acting Officer in Charge of Traffic Services Branch, Inspector Jaimi Burns said the kindness of the Anderson family will no doubt have an impact on motorcycle riders who visit the Road Safety Centre.

“Nathan’s motorcycle serves as a reminder of the vulnerability these road users face, whilst also remembering his story,” Inspector Burns said.

“Last year 18 motorcycle riders lost their lives on our roads, and four more have lost their lives in 2025.

“Riders will also be able to use the new motorcycle simulator to test their skills in handling, distraction, navigating riding at a range of speeds and avoiding unexpected road hazards.”

The simulator enhances the rider’s learning with a ‘lived experience’ to help them explore their limits safely and subsequently motivating safer road behaviours.

With 209 riders receiving serious injuries in 2024, the use of protective clothing is also a key lesson at the Road Safety Centre. A new mannequin shows the details of the contrasting impacts of life-saving protective clothing in the event of a crash.

Half of the mannequin wears full motorcycle safety clothing and equipment, scuffed in places a motorcyclist would typically experience impact to the body in the event of a crash. The other half wears torn casual clothing and a show a range of typical, and often horrific, motorcycle crash injuries like skin lesions, protruding broken bones and head injuries.

“The new simulator and mannequin are part of a motorcycle safety session which covers the licencing scheme, safety equipment, choice outcomes, risks and consequence, as well as other relevant topics,” Inspector Burns said.

Register for the next session ‘A Guide to Obtaining your Motorcycle Licence – Road Safety Session’ on Eventbrite.

Source:

CFA is urging landowners to stop burning off activities today due to strong winds across the state, which has seen more than 40 grassfires since midnight.

Landowners are also encouraged to check their recent burn-offs from the last 24-48 hours.

CFA Chief Officer Jason Heffernan said conditions today and over the next 24 hours are dangerous for burning off.

“Firefighters have responded to multiple escaped burn-offs today, many which have reignited from burn-offs over the weekend,” Jason said.

“We’re asking the community to be aware of your local conditions and stop burning off activities until safe to do so.

“We know burn-offs can flare-up several days afterwards, so it is important residents are consistently monitoring wind conditions before and after their burning day, while also notifying their neighbours to be mindful of smoke.

“If you light a fire to burn-off, you own it. Please don’t leave your burn-off unattended and always make sure it is extinguished properly with water.

“Victorians should be registering their burn-offs online through the Fire Permits Victoria website to help agencies manage fire risk effectively.”

Before burning off, ensure:

• You are following regulations or laws by CFA and your local council.
• A fire break is established with no less than three metres cleared of all flammable material.
• You register your burn-off using the Fire Permits Victoria website or by calling Triple Zero Victoria on 1800 668 511.
• Check for more information on how to prepare your property and burn-off safely on www.cfa.vic.gov.au/prepare

Submitted by	CFA Media

Source: Australian Capital Territory Policing

New domestic building contract laws in Victoria will update and simplify the rules for building and renovating homes. They’ll give people greater confidence and peace of mind when working with builders. 

The new laws will also help the building industry in Victoria build more homes for the community. 

The Domestic Building Contracts Amendment Bill 2025 passed the Victorian Parliament on Thursday 11 September 2025. The new laws will take effect by 1 December 2026.  

The new laws will: 

• provide stronger protections for homeowners when signing domestic building contracts 
• set clear rules on when builders get paid. Deposit limits, progress payment stages, and progress payment limits can be set in regulations. Any payments for completed work will be subject to a proportionality requirement 
• allow the use of cost escalation clauses for contracts worth $1 million or more. But these clauses can only add up to 5% to a contract’s price, and extra consumer protections will also apply 
• separate preliminary agreements. Builders and clients can make their own agreements for developing plans, specifications and bills of quantity 
• ensure clearer contract requirements for all. Currently, some basic document requirements only apply to major domestic building contracts. These will now apply to all domestic building contracts to reduce misunderstandings and disputes 
• provide a single, simple process for contract variations for major domestic building contracts. This applies whether the homeowner or the builder requests a variation
• set stronger rights for homeowners to end a major domestic building contract. This will make it easier to walk away if needed.  

For now, the current laws remain the same. We will publish further updates in the coming months.

Building and Plumbing Commission  

The Bill also supports a new Building and Plumbing Commission (BPC) by transferring powers from Consumer Affairs Victoria to the Victorian Building Authority.  

The BPC will oversee everything related to building quality — all in one place. This includes regulation, insurance, and resolving disputes. 

Why these changes were made 

After Porter Davis Homes collapsed, the Government reviewed building contract laws to make sure they still work for homeowners and builders. 

The review finished in September 2024, shaped by public feedback and input from consumer groups, banks and industry representatives.