Recorded Tuesday 31 Jan, 2023
Cameron 00:06
Welcome back to QAV, everybody. This is episode 605. We’re recording this on the 31st of January 2023. How are you, TK?
Tony 00:16
I’m okay. I’m recovering. In recovery mode.
Cameron 00:20
You’re in recovery, not just from alcohol, but from COVID.
Tony 00:25
From COVID. Yeah, I’ve been pretty sick for the last four or five days with COVID, which I think I got from Barnbougle. Don’t know for sure.
Cameron 00:34
That’s not a sex position, that’s like a golf course or something.
Tony 00:40
It is a golf course, yeah, a golf course in Tasmania, which I was at weekend before last. Got back on the Sunday night, Monday one of the guys on the trip texted everyone and said he tested positive. And I’d played golf with him a couple of times and chatted with him and sat behind him on the plane back to Sydney and all that. And then I tested positive on Thursday, so I suspect it was Barnbougle, but, you know, could have been something in between, too.
Cameron 01:09
The old Barnbougle. We’re gonna have to use that now for something,
Tony 01:13
It was a great trip, so I’m sad it had a sorry end.
Cameron 01:18
How bad were your symptoms? You said to me on Friday that you were doing okay.
Tony 01:24
Pretty bad. I mean, I’ve just got asthmatic lungs, so I always get bronchial things doubly bad. Yeah, I was pretty bad Thursday, Friday, and then I got the antivirals on Friday. Did a tele health consult with the doctor and read out my symptoms, and he said, sure, he’d prescribe them. So, sent me an escript and Jenny went and picked them up, and ever since then it’s been improved. So, they’ve helped.
Cameron 01:51
I haven’t heard of the antivirals before, although, when I mentioned that you were taking them to, Jan, my mom, she said that she caught it in Turkey and when she got back, they gave her antivirals, too. I thought it was just a rich white man thing, but she’s not rich or a man.
Tony 02:06
An old white people’s thing, I’d say.
Cameron 02:08
Oh, right. I thought only Donald Trump got the antivirals. So, what is this? Is this just a tablet that you take?
Tony 02:15
It’s actually six tablets. I’m guessing it’s kind of so new that they rushed in without trying to get the dosage right into one tablet, but it’s three in the morning and three in the evening.
Tony 02:26
Just once?
Tony 02:27
No, for five days.
Tony 02:29
Oh, right.
Tony 02:30
And interesting thing was the doctor said not every chemist will have them, so ring your pharmacy and make sure before your wife goes down. So, I did that, and he said, “yeah, we’ve got them,” and he said, “but do you have,” a some kind of doctor’s prescription, some category which I forget, and I said, “look, I’m not sure.” He said, “well, it makes a difference because there are about $1,500 a course if you don’t have the proper doctor’s prescription.” But as it was, it was fine, it was only $30. So, there’s quite a bit of government subsidy going on with them.
Cameron 03:01
Along with the fifty million RAT tests that they’re going to have to throw out in a couple of weeks.
Tony 03:07
Well, they can send some to my place because I’ve run out. I’ve been testing for the last week. I need some.
Cameron 03:15
Couldn’t get RAT tests for the longest time, now they’ve got too many. Just hard to get the balance right.
Tony 03:22
It’s how government procurement usually works, isn’t it?
Cameron 03:24
Yes. Well, I’m glad that you’re on the mend, Tony.
Tony 03:28
Yeah, thank you. I was saying before off air all the symptoms are back down to, like, dialled down to a one, so they’re pretty much gone. But the body just is so weak, it just wants to sleep and recover. Build up strength again.
Cameron 03:40
It’s probably a good thin you’ve been off the booze for a few months. I’m serious.
Tony 03:44
I dunno, maybe alcohol might have been a good block for it. Could’ve killed the germs on the way in. Who knows?
Cameron 03:50
It’s like that old Dave Allen sketch. Did you ever watch Dave Allen when you were a kid.
Tony 03:54
I loved Dave Allen when I was a kid.
Cameron 03:56
Me too. I remember this sketch where he’d be, like, “a teacher stands up in front of his classroom and he has a glass of scotch.” I don’t know why I’m doing a Scottish accent when he’s Irish, but “a glass of scotch and an earthworm. And he puts the earthworm in the glass of scotch. The earthworm dies.” He says “now students, what have you learned?” And they say, “if you drink lots of scotch, you won’t get worms.” The thing that I loved most about him when I was a kid is how hard he went after the church, which in the 70s was quite shocking. You didn’t hear many people go after the church. It was him, Billy Connolly would have a laugh, and the Pythons, but it was sort of a no-go place for public discourse.
Tony 04:39
Not just that, but he’d have a go with Reverend Ian Paisley and the whole troubles in Ireland. Yeah, he was quite fearless. He used to do the Reverend Ian Paisley impersonation: “there’ll be gnashing of teeth in the streets!”
Cameron 04:55
And famously for people who don’t know who Dave Allen was, he was an Irish stand up, comedian, who had a TV show forever. But he was missing the end of one of his fingers, and he used to do this great picking his nose routine by putting the knub in his nostril.
Tony 05:10
And he’s always say you could spot a butcher in a bar because they’d asked for five scotches.
Cameron 05:16
And hold up two fingers. Good stuff.
Tony 05:21
And he used to sit and drink scotch during his set. He wasn’t really a stand-up comedian, he used to sit on a seat, on a stool, with a smoke and a scotch the whole way through.
Cameron 05:31
Yeah. Let’s get into the stuff, the real stuff, our portfolio updates, Tony. Did my weekly report, my weekly email for QAV club this morning. The dummy portfolio is down a bit this week, we’re running at about 17.5% per annum since inception, September ’19, versus the STW, which is running at about 8% per annum over the same period. And we’re down a bit this week, down from about 19, I think it was, last week, largely thanks to coal. In the light portfolio, some of those are down as well. NHC, Newhope Coal, took a big hit this week. It’s down about 12% in the last week, but as I pointed out in my light email that went out yesterday, since I bought it for one of our live portfolios last April, it’s up over 100% still. So, I’m not complaining it’s down a little bit. But yeah.
Tony 06:30
Funny story. When I saw that I thought, “I wonder why coal’s down,” because I’m also affected by this while I have Whitehaven Coal in my portfolio. And so, I thought, “hmm, I’m going to ask Chat GPT.” So, I asked Chat GPT why coal’s down, and it gave me a fairly anodized answer saying, “because people don’t want to invest in coal and renewables are on the rise.” And I thought, okay, so I then asked it how come the price of coal has more than doubled in the last twelve months, and it gave the reverse answer that emerging markets are using coal and the war in Ukraine has raised the price.
Cameron 07:07
Well, the problem with using Chat GBT is in its current iteration, it’s not connected to the internet. So, it can’t tell you anything about what’s going on in the world today. Its knowledge base is based on everything that it’s read, but it doesn’t give you real time, up to date answers in this iteration. I think the next iteration Chat GPT 4, which is due out this year, will be connected to the internet, so it’ll be able to answer that kind of question more accurately, hopefully.
Tony 07:35
Yeah. I just thought it was funny I got different answers to the same question asked differently. But I did Google it to get the right answer, and it looks like the coal price has come off a little bit because winter is ending in the northern hemisphere, and it wasn’t as harsh as people predicted. So, they haven’t used as much coal to heat their homes.
Cameron 07:53
That’s what I read, too. Of course, going into winter in the northern hemisphere there was a lot of concern because of the war and supply issues. If it was a really bad winter, people were going to be freezing. There’d be millions of people freezing to death across the northern hemisphere. As it turns out, the gods were on their side, they had a mild winter, and now they’ve probably overbought a lot of coal. Not good for our portfolios, but a short-term problem, I’m sure. The dummy portfolio, just for the people that are interested, for the financial year, we’re currently running at about 6.83% per annum versus the STW, which is running at 21.5%. So, it’s going from strength to strength. We’re doing okay, but we’re still nowhere near the STW on a short-term financial year basis. So, getting back to thermal coal, this idea of the coal price being seasonal because of heating requirements in the northern hemisphere, should we factor that in next year? Should we be selling out of thermal coal as winter’s coming to an end? I had a look at the coal chart from last year. The coal price didn’t start to go down until March last year. It’s coming down a lot earlier this year. So, prefacing my question about seasonal selling with that, that it’s not necessarily an accurate indicator, you know.
Tony 09:21
It’s not. And I mean, it’s the classic trade to for both oil and coal; to buy them before the American, or sorry, the northern hemisphere winter and to sell them afterwards. But if you look at Coal over the last couple of years, it’s been going up pretty solidly anyway. So, yeah, I think the other things that work with coal would been trumping the seasonality of it, for sure.
Cameron 09:45
And that’s thermal coal, too, because when I looked at the chart over the last few years, the price is, sort of, crazy. Price has been really strong for coal over the last few years. It’s not just, I mean, I know metallurgical coal, coking coal’s, you know, driven by manufacturing out of China and India and places like that, but thermal coal as well has been going through a terrific streak over the last five years.
Tony 10:09
No, for sure. I think it’s a bit like oil in that it’s on the blacklist in terms of investments, so there’s not as much new development as there is to meet the demand needs. And so that’s why the price… It’s classic supply and demand. So, that’s why the price has been going up over the last few years. There’s still plenty of demand for coal, particularly in, as you say, China and India, but other emerging countries. In Asia in particular, Southeast Asia, Indonesia, they’re heavy coal users still.
Cameron 10:38
Thanks for that. Chanticleer retired. Tony Boyd, who’s been the Chanticleer columnist for the last thirteen years announced his retirement from the seat last week. He’s being replaced or has been replaced, one of the two, by another guy. But I was reading their farewell to him in the financial review. It said, “along with his wise analysis of the big corporate news stories of the day, Tony generously shared details of his own self-managed nest egg known as the Chook’s super fund with readers, including during periods of underperformance unlike many professional fundies.” So, I went and had done a search on the Fin for the Chook super fund and reading some of the stories. It doesn’t sound like it did very well, his fund, his self-managed super fund.
Tony 11:29
Well, when you say it didn’t do very well, I think it probably achieved market performance over the years and he saved himself the fees. But it didn’t outperform, no. And I think that was one of his admissions, was it hasn’t outperformed.
Cameron 11:43
Right, which I mean, again, just sort of, I don’t know, it always sort of surprises me when you have this guy who’s been a columnist for The Financial Review, at least writing Chanticleer for thirteen years, I would expect — before we did this show — I would expect that these financial journalists who have access to all of the best investors, investor knowledge funds, would be doing really, really well with their own investments. And as we know, when we had Alan on, not a big investor, as it turns out. Alan Kohler this is, we had him on earlier in the show.
Tony 12:21
I’m pretty sure he used to be Chanticleer many decades ago.
Cameron 12:25
Really? Okay. And then Tony Boyd, again, not really killing it. I mean, doing okay as you say, market returns, but he could have bought, you know, a Vanguard or something like that, and probably got a similar sort of result.
Tony 12:38
You would think that a financial journalist, especially someone who’s connected as him, would be getting lots of inside information, really.
Cameron 12:45
Well, inside information or just, you know, good solid investment advice. Or have developed a skills or a methodology from the thousands and thousands of stories about investors and investing that he must have written over a decade plus. But no.
Tony 13:03
Well, I guess the sound of the phone not ringing is him not calling, but if he ever wants to interview someone, I’d be happy to talk to him. But you’re dead right. I mean, it’s a well-trodden path. These people, even if they’re not giving inside tips, they should have been able to separate the wheat from the chaff. And I had a look at that link you sent me for one of the articles, I think the most recent one about his Chook fund, and he bought a bitcoin miner which grew to be a large part of his portfolio and then crashed 70% this year.
Cameron 13:36
Yeah. So, the last article that he wrote about the Chook’s super fun in August last year, there’s a table in here where he’s comparing his returns to the index and to Australian Super, Media Super. Just for people that are interested. So, it does ten years going back to FY ’12. Net returns, this is, for FY ’12: Chook Superfund net return up 2.3% versus the index, which was down 1.62. FY ’13 up 22 versus the index up 16. FY ’14 up 17 versus the index up 15. FY ’15 up 11 versus the index up 5. FY ’16 up 4.7, the index basically just broke even. FY ’17 up 13, index up 11. FY ’18 he was up 11.5 versus the index up 10.5, FY ’19 up 11, the index up 8. FY ’20 he was up 10, the index went down 0.79%. FY ’21 up 13.76, the index was up 20, and FY ’22 down 9.63 versus the index down 3.78. So, I mean he beat the index and beat it nicely a number of years there, but certainly not getting QAV returns. But if I compare him to the super funds that he’s got here, Media Super and Australian Super, in most years he very safely beat them — although they didn’t go back as far as he did in FY ’22. And there’s a couple of years that they beat him. But all in all, he beat the super funds.
Tony 15:23
And I think somewhere else in the article it gives the CAGR for the last ten years, and I think from memory he was something like 9.68%, which was a slight outperformance of Media Super, which is what he was trying to beat.
Cameron 15:39
Oh, yeah. Last paragraph. “Over the long term, the fund has beaten its benchmark. Media Super’s Balanced Fund has returned 8.7% a year over the past ten years compared to the Chook Super Funds 9.89% return per annum over the past eleven years.” So, you know, good work to Tony, but he’s got thirty-five years’ experience as a finance journalist. I mean, again, I’m not trying to be mean here, but again… Because I was completely ignorant about this kind of stuff until we started the show, my assumption would have been, as I said before, that the professionals knew what they were doing, being the fund managers and the finance journalist, guys like this, but apparently…
Tony 16:30
Well, I mean, I agree with you. However, the finance journalist is about chasing stories, isn’t it?
Cameron 16:36
Yeah, but they’re stories about finance and investing.
Tony 16:40
But it’s like, there’s probably one story a year about how to do it yourself properly or about value investing, and there’s another ten thousand other stories, so I understand why they get swamped. But I agree, I mean, why isn’t the editor of the AFR or the editor of Chanticleer out there telling people how to invest for themselves in a much more profitable way than the standard way of doing it?
Cameron 17:03
Yeah. I mean, you would think that was sort of your mission statement, really.
Tony 17:10
But again, it’s like how these industries evolve. Evolutionarily, he’s not going to succeed by teaching people how to invest better. He’s going to succeed by earning the trust of the corporate types who provide him with more articles, and more importantly, with advertising for the AFR. So, he’s not about to say, “well, you know, don’t invest in Bitcoin,” because then the AFR loses all the Bitcoin advertising. So, there is an evolutionary element to all these things, too.
Cameron 17:40
So, who has the job out there of teaching people how to… Tony’s putting his hand up in the background. A visual joke for our YouTube watchers, all four of them. Yeah, but I don’t know, like, outside of podcasts, in the mainstream media, who is trying to teach people how to do it? I mean, you’ve got the Barefoot Investor who I gather did a reasonably good job with his books and the stuff that he did before he stepped away from that a year or so ago. Anyone else that you’ve seen that does a good job?
Tony 18:19
Well, you know, people like Roger Montgomery were the ones that were doing it when I first started. Jeff Wilson to a certain extent, so yeah.
Cameron 18:27
But they’re not journalists.
Tony 18:28
No, correct. And I’ve got to tip my hat to industry super funds. I mean, they’ve done a great job of delivering market returns at a lower cost than the for-profit funds. So, that’s there, but no one’s teaching it. No, you’re right. And interestingly enough, people like the Barefoot Investor proved there’s a market out there for it. But you know, as we’ve seen, every door you open in this industry, the incentive is not to teach you how to do this cheaper and better. The incentive is there to pay someone to do it for you so they can earn a living. So, like, the more I think about our last four years, the more that, you know, the path we’re going down is just to disintermediate this industry. Teach people how to do it for themselves, all around the world, potentially, in the end, and you know, just wake them up to the fact that they don’t have to pay high fees for underperformance.
Cameron 19:21
And I got an email from a listener recently, like in the last week, who’s thinking about becoming a QAV Club member and he had a bunch of questions. And one of the questions he asked was, “are any of your listeners getting the same sort of returns you’re getting?” And I said, well, the reporting that we get back from them is that yes, they are. And in fact, in many cases, they’re doing better than we are. I said, “listen, don’t take my word for it. Sign up to the two-week free trial, get on the private QAV Club Facebook group and ask them. Ask the question, and see what sort of feedback you get, because we know that a lot of the Club members are kicking it out of the park. They really have learned how to follow the system very well. And you know, the returns speak for themselves,” as I think we mentioned on last week’s show. Yeah. Okay, well, that’s Chanticleer. FMG. We talked about FMG, Fortescue Metals, a week or so ago with the sudden resignation of yet another CFO. You were suggesting that maybe there was some bad news to come, and the CFO was trying to distance himself from it. Well, the opposite happened. They came out with what Chanticleer called a “stunner” result. Forrest says China’s ready to roll.
Tony 20:40
That doyen of financial investigation, Chanticleer? Well, to be clear, I wasn’t saying that the result would necessarily be bad, I was saying that the CFO couldn’t put their name to the result. Sorry, allegedly, I’m suggesting the CFO couldn’t put his name to the result.
Cameron 20:57
That could possibly be one explanation. But yes, they came out with a very good result. Fortescue shipped 49.4 million tonnes of iron ore, setting another record for the December quarter and taking exports for the first half of the financial year to a record 96.9 million tonnes. It was the fifth consecutive year of first half export growth, which kind of reminds me about China’s reporting on its economy, which you’ve taken some swipes at in the past. It’s always a record year, regardless of what happens. It’s going to be a record year.
Tony 21:34
The thing I find amusing about China’s reporting is that, in every other western country, it takes two or three months for the government to report the stats. In China it comes out in a couple of weeks.
Cameron 21:43
When you’ve got two billion people doing the reporting, Tony, you can get it done quickly.
Tony 21:48
Especially when they do what they’re told.
Cameron 21:52
Chanticleer says, “but if there’s one number that really points to Forrest’s juggling skills, it is surely the US $700 million increase in cash Fortescue enjoyed over the quarter due to a US $4 billion which helped net debt, that is cash minus debt, fall to just us $1.2 billion.” Now, I know as we said on the recent show, you’ve long been a big fan of Andrew Forrest as a businessman and an entrepreneur. So, okay, on one hand we’ve got the CFO suddenly resigning and then a week or so later we have this very, very good-looking result. As a sceptic, as I know you are, how do you read this as an investor?
Tony 22:35
I’m still cautious because of the finance resignations. It seems like a good result. And I checked the numbers today, Fortescue Metals Group has fallen off the buy list because the price has gotten a bit high, so the price to cash flow is below our lower hurdles. So, it’s a bit of an academic discussion, really. If it was still on the buy list, it’s a tough one, isn’t it? On the one hand we have red flags, and on the other hand we have a good result. So, I’m still cautious. I mean, that is the classic red flag, isn’t it? And typically, if there is a problem, and I don’t want to make allegations here against anyone, but when I’ve seen this sort of thing happened in the past, that the independent director resigns or the CFO resigns and the company keeps churning out good results, it doesn’t do it forever. So, won’t be this one that causes the problem, it’ll be in a year-or-so’s time when things catch up with whatever was going on that the CFO wasn’t happy with.
Cameron 23:29
When the results came out on the 27th, or the night of the 26th which was Australia Day — so, somewhere between the 25th and the 27th — the share price jumped. It went from $22.43 on the close of the 25th. On the morning of the 27th, it was over $23.21. But then it slid right back down to $22.03 by the 30th. It has been edging back up to $22.56, but it’s just around about the same place it was the night before the results came out now. So, what does that mean?
Tony 24:07
Oh, well, it probably means that the big investors thought the results were going to be as they were as they came out.
Cameron 24:14
Factored in?
Tony 24:15
Yeah, they were factored in, there were no upward surprises for them, and, you know, it was business as usual for them. No one was racing to jump in and buy up shares dramatically.
Cameron 24:24
Well, they were. It spiked on that first morning. It jumped nearly 10% and then slid back down again within twenty four hours.
Tony 24:34
Yeah, so my read of that, for what it’s worth, would be that there were some institutional buyers who were waiting for the results, saw that they came in good, pulled the trigger straightaway. And then in twenty four hours when everyone had a chance to look at it, they went “yeah, okay. It’s what we expected,” and so the buying dried up.
Cameron 24:52
But as you say, it’s not in our buy list. So, it’s somewhat academic for us, but we’ll see what happens. The last story I’ve got, Tony, to talk about, is the stuff that’s happened with Adani over the last week or so. I first got hint that this was coming in the Wall Street bets Subreddit, which I continue to follow for my own amusement. These are the guys that were pumping all of the short-sold stocks over the last couple of years. An activist investor group, Hindenburg Research, came out with a very large damning report on Adani last week. Here’s the Guardians article on it: “US activist investor who accused Adani of biggest con in corporate history dares Indian group to sue. Hindenburg research accusations denied by Adani as baseless while activist investor claims legal action will reveal accounting fraud. Hindenburg’s research report has already wiped billions of dollars of value from the sprawling empire of Gautama Dani, the world’s third richest man, and drawn into contentious Carmichael Coal and Rail project in Queensland.” And then a couple of days after that, I saw an article in the Financial Review: “Adani route hits $92 billion as fight with Hindenburg intensifies. The Adani group took another blow on Monday with the stock rout going to US 66 billion or 92 Australian billion and it’s dollar bonds sold as the fight with short seller Hindenburg research escalated. While the broad sell off continued with Adani total gas and Adani transmission down as much as 20% again, there were signs of a divide emerging among traders. Adani Enterprises, the flagship of billionaire Gautam Adani, as well as Adani ports and special economic zone rebounded following a rebuttal of Hindenburg’s fraud allegations.” So, I wanted to just ask you what you think about these activist investors coming out with reports like this and crashing the share prices of these companies? Now, I believe Hindenburg are short sellers, this is sort of their MO; they pick a target that they think is doing something dodgy, they short sell it, then they drive the price down. As an investor, what are your thoughts about these sorts of guys?
Tony 27:14
Mixed. So, you’ve got to be careful that the people like the Hindenburg group aren’t just doing this to crash the share price after they’ve shorted it. And, you know, in this case they’ve made a lot of allegations and the market’s reacted quickly and sold the shares. And it would take, I guess, a fair bit of a deep analysis to work out whether what they’re saying is true or not. And, you know, I’ve noted in today’s press that Adani’s back up 10% as people have taken Adani’s response and put it up against the Hindenburg Report, and they’re starting to make their, sort of, detailed minds up about it. But yeah, there’s a fair bit of shocking allegations in the Hindenburg report, which if true, are bad. And they talk about money laundering and hidden control and the breaking of laws on the Indian Stock Exchange, and things like that. So, I can’t really comment on this case, because I don’t know much about Adani or Indian stock exchange laws or Hindenburg. But in general, I find the most detailed research on companies often comes from these short sellers, and they generally have to really, you know, stump up a good argument to have any credibility if they’re going to go up against the company and try and take them down like this. So, that’s the first thing, is that they generally do detailed research and it’s pretty good, as opposed to a lot of analysts who simply take the company PR notice and copy it into a Microsoft deck, a PowerPoint deck, and put it out. Including the AFR that does as well. So, that’s one thing in favour of them. And their arguments always been with the demise of investigative journalism, who out there is doing the detailed research against the company? The brokers aren’t motivated to do that because they’re looking for work from these companies. So, if you look at the broker recommendations and number them, there’s usually very few sell recommendations. The buy recommendations are generally the most, and then the hold recommendations between buy and hold, generally something like two thirds or more of all recommendations are in that category. So, the stockbrokers have to stick their neck out quite far before they make a sell recommendation, because they’ll realise, they won’t get corporate work from that company going forward. So, it’s really only these activist investors that we get out there challenging the results of companies, and they do have a good track record of picking up on the Enron’s of the world and the housing crisis during the GFC in the US. So, there is a fair bit of credence to them. Having said all that, Australia’s in a bit of a different market compared to the rest of the world, because, as far as I know, we only really have one activist investor like this because the defamation laws and the regulations are so stringent around coming out with these kinds of allegations that it’s often not worth the while of an activist investor in Australia. And again, you can see how the industry has evolved that way. If you look at who donates to political parties, it’s not activist investors. It’s the BHPs and the Westfield’s — not the Westfields, Westfield is gone now, sorry — the big corporate Australians. And so, in the past if someone comes out with this kind of report, number one, they’re sued. Number two, the phone gets picked up to the Treasurer saying, “hey, this is really bad for Australian business and the Australian economy. Can you tighten the rules, please?” So, you don’t see much of it in Australia. Having said that, there is one company that’s worth people’s investigation called Bronte Capital, and they run a long, short fund. They have some track record of doing activist investing around the world. I don’t think they tend to operate in Australia because of our laws, but they are based here. And it might be worthwhile getting someone from Bronte on the show, not so much to necessarily talk about activist investing, but they’ve developed a list of red flags over the years which would be interesting to go through and get their take on on things like the Fortescue Metal CFO resignation. But also, other red flags that they’ve used successfully to short companies with.
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Cameron 54:13
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