Mark-to-Market Accounting: Kill It Before It Eats Us Alive

We need to kill mark to market accounting before it eats us alive. These accounting rules are like The Blob, an alien life form that consumes everything in its path as it grows and grows. Both the Blob and mark to market accounting crawl, creep and eat everything dead or alive in their path. We need to save ourselves by putting mark to market accounting into deep freeze while there is something left to save.

Before I proceed (and get flamed by angry commenters), I want to set the record straight. I believe financial statements should present a conservative, consistent and realistic report of results of operations, financial condition, cash flow and contingent liabilities and assets. Bad assets and poor management decisions should not be hidden behind accounting manipulations. Loan loss and other reserves should be conservatively determined and uncollectable assets should be promptly written off. Accounting rules shouldn’t drive business decisions, they should reflect them.

However, mark to market rules distort financial results and business decisions under the false cloak of conservatism. The rules make little sense, produce inconsistent results, lack a basis in reality and provide lots of room for abuse. They should be suspended immediately before more damage is done. And, the damage is a distortion of common sense business decisions and financial reporting.

Mark to market rules are one of the worst manifestations of the “trader” mentality that spread from Wall Street to the rest of the country. Wall Street traders with severe attention deficit must have drafted these accounting rules because they push valuations and reporting of business decisions into the “moment” (which is worse than the short term) and use the equivalent of “financial sound bites” to determine value. The false premise that the price for which an asset can be sold for at this minute is the true value of the asset underpins mark to market accounting. One of the basic claims of the Paulson Plan, that only the government has the patient capital necessary to own financial assets and wait until they pay off at maturity, is the ultimate indictment of the crazy results of these accounting rules.

And, like The Blob the rules keep on expanding and expanding in their application. On January 1, 2009, all merger and acquisition transactions will be subject to mark to market accounting.

So, let’s kill The Blob before it kills us.

Set forth below is “why” we need to get rid of these rules before they eat us alive.

1. Mark to market accounting assumes that what people are willing to pay for an asset is always the same as the asset’s value. This assumption is wrong.

When assets are tradable, transparent and liquid, what people are willing to pay is the “real” value. But, when assets aren’t traded and are illiquid and opaque (like a private bonds or loans), market prices are a worthless measure of value because there is no market to establish value. Not all assets that have no trading market are bad assets; most of them are just private loans to individuals and businesses. Before mark to market accounting, loan loss and valuation reserves were established for uncollectable obligations and assets.

A few years ago I had an experience at an aircraft spare parts trading company that illustrates the limitations of market value accounting. At this company there were many spare parts that had an active bid/ask market and reasonable market values were quickly established without controversy.

However, in one corner of the hanger there were spare nose cones for Boeing 737s. Each nose cone had a historical cost of $10,000. The current market value of each nose cone was less than $1,000 and was equal to its aluminum meltdown value (scrap metals dealers were the only buyers). However, if anywhere in the world a Boeing 737 broke its nose cone; my client would sell one of his cones out of inventory, usually for greater than $50,000.

Mark to market accounting would have valued the nose cones at around $1,000 per cone. Before mark to market accounting, $10,000 would have been their carrying value.

The above example illustrates three flaws with mark to market accounting.

• Mark to market accounting uses quick sale valuations which are non-going concern liquidation values for assets and are almost always lower than going concern valuations. However, a core GAAP assumption is that companies are going concerns and violation of that assumption destroys the value of financial statements.
• Valuing nose cones at melt value shifts income from the period of the mark down to the period of the sale (as well as inflates expenses during the period of the markdown). This distorts the income recognition principal that revenues and expenses should be recognized in the period incurred.
• Mark to market accounting distorts management decisions and market prices. The application of mark to market accounting stops management teams from investing in new assets that are subject to subsequent quick sale liquidation analysis. One of the problems in the current credit crisis is “banker refusal” to make loans to companies and consumers because of the risk of an immediate mark down upon origination. In the above nose cone example, if mark to market accounting is used, no spare parts trading company will replenish supply once their nose cones are sold. The application of mark to market accounting to nose cones will drive the market price of cones to $1,000 despite the ultimate realizable value of $50,000. This type of price distortion is currently driving the market for many financial assets.

2. Inaccurate proxies and bottom feeders have become the “market” for accounting purposes.

By definition, assets without a liquid and trading market don’t have a market in which to determine market value. Accountants have been using “proxies” to estimate the market for illiquid assets. But the use of proxies is flawed.

• Often, accountants are using proxies that are themselves illiquid and thinly traded. Applying the principal of “garbage in, garbage out”, it is easy to see why estimating an asset’s market value based upon a proxy that doesn’t have a clear market value isn’t good.
• When accountants can’t find a market or a proxy, they are using distressed quick sale prices. Most illiquid assets are illiquid because they have individual qualities and can’t be valued without a lot of buyer work to understand the risks and benefits of the investment. Due diligence and analysis are inconsistent with quick sale analysis. Fundamental value investors don’t purchase assets in quick sales. However, bottom feeders “live” to purchase illiquid assets with limited due diligence. Bottom feeders hedge risk through low price. Since the mark to market rules favor quick sale prices and bids, valuations migrate to bottom feeder values regardless of the quality of the assets. Again, management decisions are distorted as accounting valuations migrate to bottom feeder prices.

3. Sometimes the whole is worth more than the sum of its parts. Mark to market accounting values the sum of the parts.

Mark to market rules value each component part of a business rather than the business as a whole. When I was a kid, I decided to take apart the family lawnmower. Before I messed with the mower it was worth about $100. However, once it was spread apart across the floor of my parents’ garage, the mower had little value. Each part was just valueless junk. If I could have put it back together, the mower would have again been worth $100.

Mark to market accounting values each component part of a business or a portfolio on a stand alone liquidation basis rather than as a whole.

GAAP accounting continues to expand valuing each component part at its quick sale value. In January, 2009, changes to merger and acquisition accounting will be phased in and will continue this trend to “spare parts” valuation.

4. Mark to market accounting isn’t uniformly applied across companies and industries. “Form over substance” is about to rule the day.

Further confusing investors, mark to market accounting has inconsistent application across industries and companies. As an example, insurers and banks account for similar transactions differently, as do banks and brokers.

Different accounting for the same transactions and investments confuse investors and is inconsistent with the objectives of GAAP.

And, mark to market accounting favors private companies over public companies. Private companies don’t have to worry about this ridiculous accounting rule and will over time be more likely to attract capital. Mark to market accounting is contributing to the destruction of the U.S. stock market and capital markets and is another unintended consequence of these rules.

Accounting should be the same for the same transaction regardless of the form or ownership structure of the company.

5. Mark to market accounting allows management teams to manufacture earnings.

Mark to market accounting is a “double edged sword” – it can and has been used to manufacture earnings. It is no coincidence that Lehman Brothers failed after manufacturing $2.4 billion in pre-tax profits by “marking to market” its liabilities. Mark to market accounting assumes that a borrower, like Lehman, can go into the market and purchase its debt at the “market price” rather than repaying it in ordinary course. Sure…enough said about that.

Mark to market accounting needs to go. We need consistent, conservative and realistic financial statements and reject the bottom feeder trading valuations of mark to market accounting.

We need to kill The Blob before it eats us.

Comments

[Chris B:]

Excellent points and well written.

Shouldn't 30 year mortgages be bought with the intent of holding until maturity? I wonder how much of a crisis there would be today if companies declared their mortgages to be worth principle plus interest minus an estimated loss provision. I suspect we would be closer to 90 cents on the dollar than the current 30 cents.

Does anyone know of any companies out there that are taking on this opportunity? As the author points out, they would probably be private.

I might call Countrywide today and offer them 30 cents on the dollar for my mortgage! According to their accounting, that might be more than it's worth!

2008 Sep 29 02:10 PM

[levin70:]

Mark

Let me take your post down 1 at a time.

Point 1) FAS 157 would not make the airplane parts wholesaler mark his nose cone down to $1,000. The scrap metal market is not the "market" for the parts wholesaler. In this case, if no bid/ask for sales of nose cones existed outside of scrap metal dealers, than these assets clearly would move to L3 status and the parts wholesaler would be more than welcome to use whatever models were available to him to value his inventory. Also - an airplane parts wholesaler is not dealing in financial assets and liabiltiies and thus FAS 157 has not yet required implementation for non-financial assets and liabilities, so your airplane wholesale part example is plain stupid

Part 2) For assets that don't trade, L3 status, which may use any myriad of valuation techniques are available. But remember, we are talking about financial assets and liabililities here - you mark your stocks everyday, so banks have to mark their loan portfolios. You seem to have this idea that everything out there is hold to maturity - when in fact almost nothing is held to maturity. If the stuff was held to maturity - why was everything funded with short-term, even so far as repo funing? Hmm?? more to come later

2008 Sep 29 02:13 PM

[epps:]

I agree. Valuation of a company is a complex thing. Mark to mark accounting cannot come close to estabishing tru value.

2008 Sep 29 02:29 PM

[oldtimerCPA:]

I'm almost ashamed to call myself a CPA. We continue to be a collection of pompous blowhards who don't have a clue when it comes to the impact of techonology and connectivity. Our Y2K antics were simply amusing. We were a laughing stock but we were harmless. This time though we have blood on our hands. We continue to think that the marketplace works like it did when people grew apples and brought them to the marketplace in town on wagons.

2008 Sep 29 03:19 PM

[Pj568:]

What everyone forgets is that "mark to mark" came about because the investor community demanded it. They wanted the transparency, the accountants wanted to stay with historical numbers due to its simplicity and ability to be verified; NOT because it produced a more accurate picture.

Mark to mark is what the large staffs of institutions and hedge funds were doing within their own organizations in attempting to value a company. So I don't see what's so wrong in making it available to the public.

Face it, its not an accounting problem but a poor management decision to create, buy and hold these various assets (liabilities) that they didn't understand.

2008 Sep 29 06:08 PM

[User 170780:]

I agree with your well written article it cleared up many points on Mark to Mark accounting. I liked your nose cone analagy, it is not unlike the housing industry with all it's moving parts and value both labor and material. As in banking housing is a whole industry not a parts and pieces calculation. I agree with your thoughts on an accounting method designed to arbitrarily and capricously value a product and an industry that the accountants have little knowledge of. Is a "garbage in garbage out", survey. Which opens the door for abuse and potential criminal actions. As for the bailout. I believe that the best solution would have been for the feds to give the banks. ( all of them not selective discretion) a five year tax credit at ten percent per year to write down loans that actually fail due to market conditions. While the bank, who truly knows the industry. Is allowed through free market practices to remain making a profit. And lending. As for capital needed by the banks to operate and increase lending the Banks should in turn offer the common stock holders up to $8.00 per share of preffered stock to instill some confidence in investing in their company. This plan in my opinion would do far greater good than a bailout which will do little good. To those who will be hurt by the hedge funders and the corrupt government that has been seduced by greed. and Mark to Mark calculations designed to instill fear or fantastic. Depending on what is needed to paint a picture with hidden agenda.

2008 Sep 29 10:04 PM

[Steven Hansen:]

i agree that mark to market accounting is not helping the current situation - but that does not make it the villain. levin70 is correct about the rules. enron triggered this rule change. i protects the investor. you have everything to lose if a company cooks the books. everyone (international and national companies) are accounting on a level playing field. don't get caught up in this hysteria about mark to market - it is the system abusers who want to go back to the old rules.

and please demonstrate to seeking alpha how this rule change has caused any company to fail. it was the toxic waste and leverage which has screwed the market.

2008 Sep 30 02:47 AM

[RSchult43:]

The hand says that levin70 is correct about the rules but he says that a bank must mark its loan portfolio to market. I am a banker and we do not mark our loan portfolio to market. We never have and I would be at a loss as to how to proceed to that end. There is no active/liquid market for the loans we make. Banks (commercial banks) suffer from an activity that is analogous to mark to market and that is the requirement to re-appraise real estate over the life of a loan. In the real estate down cycle we are experiencing most appraisals come in lower each time. The new appraisal requires the loan to value be brought into line with policy and or regulations FDICIA. The internal options are to make a specific loan loss allowance reserve or a write down of the loan. The downward spiral is painful and may or may not represent the market or the lack of a market. Appraisers frequently say there aren't any comparable sales; nevertheless, the appraisals come in lower and the required debits and credits increase expense. Thank someone we do not have to mark to market. I believe mark to market is a tool that is heavily used by investment banks and they have gotten themselves caught up in the lending world and have created for themselves a monster not a useful discipline. As the British economist Fredrich Schumacher said, I believe investment banks are experiencing a conflict in principles(loans vs. securities) where their choice was to prevail as opposed to understanding and adapting.

2008 Sep 30 07:15 AM

[eddie6442:]

I have been posting for weeks that Mark-to-Market and SARBOX personal liability for Officers/Directors has placed unreal pressures on Balance sheets and Financial results. These have been exploited by those who have SHORTED stocks into the abyss. Another example of the governments propensity to perpetuate the "Rule of Unintended Consequences. All because a few CEO's in the ENRON/WORLDCOM era were bad?
If these two pieces of legislation were rescinded and morgages were revalued closer to the value of the underlying house, Balance Sheets would be reflated up near 70-80%. Capitalization ratios would automatically be restored to strength. Rating agencies would adjust ratings upward. and pressures would be taken off share prices immediately to seek their true level. Thirdly, the SEC "must" restore the UPTICK rule and "prosecute" NAKED SHORTERS........no more SHO report..........becaus... there can be NO SHARES NOT DELIVERED.
You see folks, THERE IS A SILVER BULLET, and in this case it can save the taxpayer ~ $500 Billion!!!!!!!!!!!!!
Wanna be PRESIDENT????????? Implement this for AMERICA........
IMHO

2008 Sep 30 09:21 AM

[formerhawk:]

rschult43 exactly why you see all of the investment banks hooking up with real banks... so they don't have to mark-to-market. I think this rule has already done its damage. This is actually a good old fashioned run on Wall Street and not of the bulls. Now for the next part money, if you can borrow it, will be expensive. Even if you can afford the debt service it will impact your bottom line because the cost is higher than projected. Result folks, a lot more failures and not just in banking. Look at Libor if you don't believe me.

2008 Sep 30 09:31 AM

[petyaczar:]

IMO

Congress created this problem thru Sarbanes Oaxley and the "mark to market nonsense.

Solution is as follows

1)Eliminate the "mark to market" nonsense immediately and forever
2)Reinstate the uptick rule
3)Reinstate Glass Steagall Act separating comm/investment banks
4)Raise margin to 50% on ALL commodities futures trading oil/gas
5)throw money into the system -Money is the best deodorant
6)Provide guarantees and establish an insurance fund

This D/A mark to market nonsense and Congressional reaction against "Wall Street" can be described metaphoirically as follows

I am captain of an aircraft carrier (The financial system)
the ship cmes into port for minor repairs
The idiots in Congress decree all ballast shall be removed from the ship (Mark to Market is equivalent to removing the stabilizers from the balance sheet = Sarbanes Oaxley ACT)
The captain returns and says WTF have you done? you screwed up the balance of my ship, it will become top heavy, unstable, and capsize without the ballast in the bottom of the hull (Balance sheet)
The Congress insists the captain takes the ship out without ballast
The captain does as told, begins aircraft carrier operations AND
the aircraft carrier is now unstable and capsizes.

The Congress blames the Captain for incompetence,

Pass the emergency measure, and eliminate Mark to market along with the above and this problem will disappear. Its "root cause" is that it is an accounting problem.

IMO

2008 Sep 30 09:38 AM

[A Hoodbhoy:]

Let the Private Equity firms and the Super Rich (who control and have huge amounts of cash on the sidelines currently invested in T-Bills)rummage through the rubble of all the companies and banks that have toxic loans. Without a doubt this group has the experience and resources to do their due dilligence and make offers to buy or make mutually acceptable business deals on assets that are worth salvaging. The only roles the Government should play are to help expedite this process and allow the surviving companies to write off their losses on a reasonable favorable time table. This can all be done without the $700 Billion bailout.

2008 Sep 30 11:05 AM

[petyaczar:]

Dear A hoodbhoy

Au Contraire.

It cannot be done without government $$$ AND seller funded insurance to guarantee against default the questionable securities to buyers.

ALSO the idea of a $700 Billion cost to the taxpayer is false, a gross mischaracteriztion foisted upon the ignorant by those who know better.

The actual headline should read.

"Taxpayers may be hard assets at 20- 30 cents on the dollar from strapped investors and speculators AND THEN RESELL those assets with insurance attached back to other institutional investors for 60 to 80 cents on the dollar"

This is not a bail out, it is an opportunity for the government to use the strength of its balance sheet to provide liquidity, purchase performing and nonperforming assets for pennies on the dollar, then thru a seller and buyer financed govt insurance fund, Resell those self same assets back to other institutional investors. The margin on this deal and the size of the deal can potentially generate enough profit to wipe out the current account governement deficit.

PS The Alternative was demonstrated during the "little depression" of 1929 when due to a lack of liquidity the banks failed, credit dried up,jobs disappeared, tax reveunes evaporated and bread lines ensued.

The alternative to the Paulson plan and my suggestions above is a financial panic followed by a GREAT DEPRESSION.

IMO

2008 Sep 30 11:57 AM

[Mark Sunshine:]

The author here,

A few observations/comments.

First, from are article today in Bloomberg...."ABA, which has been lobbying policymakers and regulators for months, upped the ante recently as more and more banks told the association their accountants are advising them to use the fire-sale value."

I firmly believe that mark to market accounting is a self reinforcing race to the bottom of valuation and what the ABA said (eventhough it is a lobbying group and therefore we must be suspect) is correct.

Second, FAS 141r ("r" is for "restatement") will change the purchase accounting rules and extend mark to market accounting into non-financial assets and for all assets of all firms. What company is going to publish one set of financial statements only to have potential acquirers announce that if they purchase the company the financials will be massively restated as a result of mark to market accounting. Like the Blob, mark to market accounting will keep on growing, and growing and growing until it eats us alive.

Third, mark to market accounting is pretty much only endorsed by people that are "traders" and want "transparency" for ease of trading. While I don't have anythng against traders, the trading mentality has limitations and pushes everything and everyone into short term analysis. CEO's complained about how quarterly earnings releases were ruining their companies because they were too short term. Well, how much more short term is mark to market accounting?

Thanks for reading the article and thanks for taking the time to comment. Even if I don't agree with your position I appreciate that you took the time to read what I wrote.

2008 Sep 30 02:45 PM

[happybob:]

petyaczar wrote:
"This is not a bail out, it is an opportunity for the government to use the strength of its balance sheet to provide liquidity, purchase performing and nonperforming assets for pennies on the dollar, then thru a seller and buyer financed govt insurance fund, Resell those self same assets back to other institutional investors."

The strength of the government's balance sheet?

Would this be the government that is currently $9+ trillion in debt?

The Government that is planning to run a $400+ billion deficit next year -- before any bailout?

The Government that currently has $53 trillion in unfunded liabilities?

The government's "strength" comes from its ability to issue more debt, not from a reserve. This seems like the same backwards thinking that got us in the current mess.

2008 Oct 03 07:30 PM

[Haris Pilter:]

Good article & discussion. It's not obvious to me then what the alternative asset evaluation methology should be...

2008 Oct 08 02:54 PM

[IwishIknew:]

I think too many people misunderstand. Mortgages securities were sold with ratings. When a group of mortgages (a securitization) realizes losses they hit the lower level tranches first. With true losses hitting 15 or 20 percent in many deal the lower tranches are wiped out. Many deals are seeing the b and lower bonds as worthless already, no need to wait 30 years there are already enough losses. As losses build in the trust how high will they hit. As investors run the numbers they see AAA bonds were probably B at best. What was considered a ridiculously low valuation last year is reality today. If home prices drop another 10 percent how much value is erased from bond holders? DO you really think a simple rule change would allow the Treasury to not need to send Freddy another 35 billion in the coming weeks?


On Sep 29 02:10 PM Chris B wrote:

> Excellent points and well written.
>
> Shouldn't 30 year mortgages be bought with the intent of holding
> until maturity? I wonder how much of a crisis there would be today
> if companies declared their mortgages to be worth principle plus
> interest minus an estimated loss provision. I suspect we would be
> closer to 90 cents on the dollar than the current 30 cents.
>
> Does anyone know of any companies out there that are taking on this
> opportunity? As the author points out, they would probably be private.
>
>
> I might call Countrywide today and offer them 30 cents on the dollar
> for my mortgage! According to their accounting, that might be more
> than it's worth!

Jan 25 12:09 PM

[Xorthfred:]

Good article. Mark to market accounting eliminates demand by publicly held institutions to buy mortgage securities. It also increases supply as banks dump holdings for substantial discounts. No one has discussed the impact of mark to market accounting on non-performings. Current performing mortgages are classified non-performing. Then the OCC forces an increase in reserves as a percentage of non-performings. Mortgages that are not late are being written off. It is self flagellation.

Feb 09 02:05 PM

[Jhon:]

Great article about Mark to Market Accounting: Kill It Before It Eats Us Alive how supper the article , it is an opportunity for the government to use the strength of its balance sheet to provide liquidity, purchase performing and nonperforming assets for pennies on the dollar, then thru a seller and buyer financed govt insurance fund, Resell those self same assets back to other institutional investors.
www.avicennaaccounting.../ ,
you can get more feedback from this.

Feb 12 01:59 AM

[Mark Anthony:]

Mark:

You were so right about the Mark to Market rule. It's really time to abolish it before the market totally collapses. There is simply no fair market value in an unhealthy market like today's.

Mar 02 10:13 PM

[User 371617:]

I have a taco stand worth 3 billion, would you like to invest? Please!!! Pretty Please! Fantasy accounting that wishes away bad assets by merely concealing them.

Mark to market protects the investor by providing transparency, if there in no market for bank assets, then there is no market for bank assets!!

However, far be it for me to stop people from throwing their money into a fire and watching it burn. Instead I have a taco stand worth 3 billion, no really I do, but I dont have to prove it to you.

Mar 07 11:42 AM

[User666777:]

Didn't FDR remove MTM as an attempt to rid himself of the GREAT DEPRESSION(maybe soon thereafter)?

So, we had MTM, a depression, then no MTM, a bull market, MTM again, another depression? MTM, the Depression maker?

Mar 07 09:30 PM

[mbbcat:]

The TRUTH ? - You can't Handle the TRUTH (nor can they!)

So lets all have mark to lie instead ?

maybe not;

/ program - capitalism
Begin

Rule 1 - an item is only worth what it can be sold for right now - no more & no less period

Rule 2 - goto rule 1

Do While earth turns
end

----------------------...


Its that simple.

Mar 16 04:41 PM

[JCC:]

On Mar 07 11:42 AM User 371617 wrote:
"I have a taco stand worth 3 billion, would you like to invest? Please!!! Pretty Please! Fantasy accounting that wishes away bad assets by merely concealing them.

Mark to market protects the investor by providing transparency, if
there in no market for bank assets, then there is no market for bank
assets!!"

Sorry User 371617 - Mark to market muddies the market and does not provide transparency. It unreasonably forces assets to be valued to what is sellable in a distressed market. The M2M approach is ridculous and very difficult to defend.

Something different is required:

1. Suspend M2M when markets are distressed. This is one proposal currently under consideration.
2. Cushion M2M with a moving average based upon thee previous year.

The above two approaches are very different from the lie forced by todays absurd M2M rules. The above two approaches would provide much better investor transparency.

Mar 29 02:19 PM

[LaVern Isely:]

I couldn't agree more. This has been going on for far too long concerning MARK TO MARKET ACCOUNTING and it is eating us alive. It's about time our Attorney General or some committee chairman looks into this very serious problem before our country, as well as the whole world goes bankrupt.
Yours truly, Disgusted Middleclass Taxpayer, Public Citizen and AARP Member, LaVern Isely

Apr 03 04:15 PM

[Mike Razar:]

Hey JCC...I'll pay $1B and not a penny more and you have to throw in a year's supply of hot sauce. Have you noticed that the response to your example is to ignore it or deny it without a shred of evidence? One of the best ways to explain it is to challenge the author to make an investment or loan based on the asset's "true fair value" as if such a thing exists. It is fine for OTHER PEOPLE'S MONEY but never for the author's own money. That's why having the govt. involved is so important. All its money is other people's money (aka taxpayers).
It is claimed that only a trader would mark an asset to market. Then why do banks insists on only lending a certain percent of the market value of an asset?
What about mark to discounted cashflow. What discount rate do you suggest? Someone even suggested a 10% alllowance for default. Good idea, unless the probabilities dictate a 30% allowance.
The only relevant standard is what value would someone using his own money assign to the balance sheet.
But underlying this whole topic is the false assumption (hope?) that accounting rules have an impact on the value of a firm. That is only true if the potential investors are ignorant of what they are buying. Fraud has always been a popular way to overvalue assets. You don't need an accounting rule here; what you need are honest transparent descriptions of the assets. The counterparty can then decide if he is a nose cone buyer or a scrap metal buyer.

Apr 20 04:01 PM