Sunday, May 11, 2014

Mexico's Bond Market

Mexico's New Regulatory Envorinment

Beginning in 1997, the Mexican Ministry of finance (SHCP) created reforms to open its access to buy and sell government securities. These reforms included the improving of regulatory bodies within finical systems through the creation of the National Banking and Securities commission (CNBV ), the National Financial Services (CNSF) and the National Savings System for Retirement (Consar), through the umbrella agency, the Federal regulatory Improvement Commission (Cofemer).   These regulatory bodies helped to create a solid foundation for Mexico’s internal municipal bond market, which became operational in 2001.  

These structural considerations encouraged the use of credit ratings and structured finance in order to leverage retirement accounts (AFORES) to be used as guarantees for financing infrastructure within states and municipalities. The traditional method for issuing government debt was only operational through the auctions that big investors, who only had access.  Now retail debt through a system call CETES Direct gives small investors the opportunity to buy government securities without intermediaries.  

Bond issuers

Bond issuers are generally, the offices that  process the bonds for issuing through a process of underwriting.   When a bond issue is underwritten, one or more securities firms or banks, forming a syndicate, buy the entire issue of bonds from the issuer and re-sell them to investors. The security firm takes the risk of being unable to sell on the issue to end investors.  Issuers help to identify the type of loan a subnational government needs, adjusts their public finances, and helps to find the type of guarantee that will be provided and negotiates with the appropriate banks to syndicate the loan. Therefore ordinary investors can  invest in the bond within the Mexican “wall street” as any other type of low risk investment government security investment.

Friday, May 02, 2014

What are some examples of Government Faliure?

The following provides a justification for either government intervention on market failures or the antithesis, suggesting a need for less government intervention due to government failure.

a. Interstate Highway Grants are federal grants for states to maintain and construct the interstate highway system. First, we must analyze whether road construction could be provided by a purely-private market. Roads could and are made in the open market; they are both excludible and rivalries. In order to make them non-rivalry, toll roads are built. But if the ideal is to ensure that the highway connects every state in the union, this makes inter-state highways a non-excludible and non-rivalries type of market. Therefore, if you believe that it is important to unify the country through the inter-state highway system, this is a perfect example of how government can intervene into the market place to provide a public good. That is not to say, many people object to the formula devised by Congress which assess the allocation of the resources, which could be conceived as a government failure, depending upon your state’s specific appropriation.

b. Environmental Protection creates a positive externality for all of us and for future generations. The EPA’s regulations on the environment especially for water and air pollution protects the American people from harmful and potentially life threatening diseases and lifestyles. Air pollution, for example is a public good, a non-exclusive- non-rivalry market. Factories would over pollute as much as they wanted without the consequence of paying a fine. Plus if they over polluted there would be a negative externality for those living in the area and had to breath in the bad air. Furthermore, many people may have an Intertemporal Resource Allocation, or consume today all the products from our forests, coral reefs, fish stocks, oil, species, etc., all the without harvesting regulations and preservation acts to take care of them. Yet with all these overarching benefits to America, some business argue there is over supply of regulation, they find the bureaucracy over cumbersome and even other have difficulties applying for permits suggesting potently bloating of the system.

c. Media Regulation is the FCC’s regulation of the electromagnetic spectrum to allocate permits for companies to use specific frequencies for radio and TV stations. The frequencies themselves, without the regulation, fall in with the tragedy of the commons or a common pool resource problem because they are is rivalry and they are not excludible. Scientists suggest that is an infinite number on the spectrum and therefore should be regulated. Furthermore, it can be argued that the FCC prevents a monopoly of media provided to the public. The FCC’s regulations were copied from the ICC model discussed further later.

d. TANF is the US welfare program to assist children living in poverty. Child poverty is a problem of Acceptability of Preferences. Americans, for one reason or another, deems it unacceptable. Often suggesting it’s Moral Unacceptability because children do not predicate where they are born. Furthermore, providing aid to children can be considered a positive externality or a tax benefit to needy families who fall below the poverty line. The government aid also helps the local economy of where the families live and spend the money.

How to Run a Constitution....

In the book, To Run a Constitution, John Rohr advises us that the word “administration” is not mentioned once in the constitutions. Yet today, when we think of the American government we think of the bureaucracy that manages and implements (and sometimes establishes) many of the policies that run our country. Therefore when Richard Neustadt argued that the notion of the “separation of powers” is miss leading was because in the US we have separate administrative institutions sharing these powers. That is again to say, that today’s bureaucracy not only sets policy, it manages and implements it too.

We learn from Rohr, the notion of the “separation of powers” originates from the Federalist vs. Anti-federalist arguing over power, and finally suggesting that not one authority within the federal government should be omnipotent. Rather there should be a balance between the executive, judiciary and the legislative bodies. America’s Founding Fathers created the laws of checks and balances that could over-ride congress, the president and the judiciary’s roles in government.

Yet, the first problem framers encountered was to manage the separation of power within the Treasury department. They analyzed how the three separate powers could manipulate and influence its operations. This was the first administrative agency in which the framers needed to create direct lines of control. Ultimately, the framers nominated that congress, the most representational body of government, to control the bureaucracy through committee, which still exits today.

Woodrow Wilson, with his interpretive view of the constitution, established the politics-administration divide, making him the father of modern American public administration. In his 1889 prolific essay and subsequent lectures, Wilson proclaimed, “Administration was the most obvious part of government…which proceed the independent of legislation and even of constitution”(Rohr 68). He stated that the constitution is a political act but that administration predicates the good will of the people. This notion is what concerns Neustadt.

Furthermore with Wilson’s new deal programs in the plight of the great depression, created the largest expansion of government in US history. Therefore more emphasis was needed to be place on whether the “bureaucratic administration” separated itself from politics or not. Therefore if the administration was not separate from politics, it may be omnipotent to a particular issue. The courts and congress are highly involved in the administrative actions of most bureaucracies.

Frank Goodnow believed in Wilson’s legislative supremacy. The example provided in Rohr’s book was the fight over the establishment and implementation of policies within the Interstate Commerce Commission (ICC). Goodnow described how Thomas Cooley managed to regulate and expand the ICC while navigating the political games in Washington, which legitimized his work. Further work by the various agencies, legal battles and the like substantiate this work.

Ultimately the “separation of powers” question depends on whether the administrative-state blends the powers of constitutional legitimacy predicated on one’s belief in the separation of politics and administration and what type of constitutional review they take.

What is the relationship between capitalism and democracy?

Lindblom’s Politics and Markets highlights the relationship between capitalism and democracy. Writing in 1977, he makes a comparative analysis of the American system of government with other world political and economic systems. Particularly he is concerned with the privileged position of business in a democracy, its efforts towards growth and the indoctrination of Americans to incorporate a pro-business bias.

Lindblom divides the political economy into a government/people and business/market dichotomy. Suggesting that it is the will of the citizen voters who are both consumers of goods and policy. They make up the collective decision making in a polyarchy. Lindblom argues that decisions are more complex than rational choice economics suggest, particularly in the political realm. Therefore, politicians use persuasion to sway voters to believe in what would be good for them. This persuasion is often tainted due to the types of controls they might have, such as wealth, organization and access, etc.

Lindblom believes that businesspersons hold a privileged position within a democratic society. They exist in a market system where “…income and wealth, deference, prestige, influence and power, among other things…” define someone. (Lindblom, 175) Furthermore they are obligated to the American people because they are responsible for the wellbeing of our society to assist in its economic growth. An effort to build the economy helps businesses. “Urban renewal, for example, comes to the aid of retailers, banks, theaters, public utilities, brokers, and builders.” (Lindblom, 177)

This is in contrast to a communist system, which is led by strict government action of how to build and strengthen its economy. In a democracy, policy circles and interest groups make decisions. Businesspersons have the incentive to encourage development through their sectors and create interest groups to represent them. This lobbying would be unnecessary in a communist system and may provide waist for the actual development of a country. Lindblom is not only analyzing the US, but he is seeking to contrast it from other world powers of the time, like Russia and China and their levels of development and growth.

Lindblom suggests that liberal pluralism focuses on how interest groups shape policy. Yet, public policy should be dependent on the market/business decisions. People vote in representation and they may be pro-development or people-focused. These two areas polarize the American people’s vote. What molds their opinion is indoctrination, provided by education, to vote pro-business.

Finally, Lindblom highlights the efforts of public education and popular education to further disseminate this privileged position for the business community.  He argues that in a society there is three control methods: exchange through markets, authority by government or persuasion by preceptoral systems. The last item is what dominates in America. The role of the media is important in a democratic system. It helps with the indoctrination of the people to vote more pro-business. This inherently, promotes business to dominate and promote growth for the country.

Inter-governmental Relations in the US

The Price of Federalism according to Paul Peterson (1996) is the cost of doing business for a government when various levels (national, state and local) are segmented the bureaucracy. For him, modern federalism in the US has evolved far away from what the forefather’s originally envisioned. Today each level of government has its own independently elected political leaders and its own separate taxing and spending capacity.
Functional theory argues that the appropriate level of government should be used to provide the public services to the people. By and large, it argues that economic development policy should be managed at the state and local governmental levels, while the national government should be in charge of redistributing wealth. This is a more normative view of how government “should” operate. On the other hand, Legislative theory says that modern federal system is shaped by political needs and legislatures are responsible for its design. Politicians strive to distribute benefits and push off costs. This is a more realist argument, which focuses on the pork politics of the politicians and how much re-allocation of the national treasury is allocated for a particular locality.
Ultimately, Peterson argues that although traditional functionalism is theoretically superior, realistically legislative affairs intervene into the policy making process thus costing America more. He describes the problems with modern federalism as the costs of welfare; the creation of fiscal inequalities; and the expensive of providing public services in central cities.
In regards to welfare policy, Peterson identifies distinctive areas of functionality for government funds separated into developmental vs. redistributive grants. Developmental funds are designated for infrastructure, roads, mass transit, sanitation systems, public parks and institutions to protect the public like for health and education. Redistribution is aid that helps the elderly, disabled, unemployed, sick, poor, and indirectly helps economic development. Functionalism argues that local governments are equipped to design and administer development problems because market forces and political processes discipline them better. As defined in public choice theory, it is the marginal resident and business that determines the market value of property in a locality (page 18). Citizen choices at the local level will select the optimal level of market-based outcome for the basic services. Although citizens are likely to eschew income tax and relay on property taxes, user fees and misc. taxes to pay for public goods, political pressure is minimal at the local level.
Yet if local governments are allowed to provide both development and redistributive policies, areas will concentrate between the rich and the poor creating huge inequalities. Concentration of poor unable to pay for basic services will grow and rich municipalize will promote politics of Not In My Back Yard (NIMBY). Therefore Peterson argues that the national government should be in charge of redistribution. Likewise, legislative theory acknowledges that national federalism is shaped by political needs of legislatures responsible for their jurisdictions. Politicians lobby for resources and claim credit and shift the burden to other levels of the federal system, which could create a distorted allocation of resources. These contradictions result in fiscal inequalities of national benefits.
Finally, Peterson argues that inter-cities receive a grunt of the burden. He suggests that diseconomies of scale that occur in big cities government are less likely to offer market-based information. With more density, cities have increased inequality and must pay more for maintenance and management but have the diminishing costs of providing public services. Big cities problems are hard to tackle. They are ridden with crime, welfare dependency, poor schools and high unemployment rates. Similar to developing countries, big cities have large amounts of inequality. Functionalists expect territorial inequities in fiscal resources among states to be distributed through federal grants. Yet, Peterson is less optimistic that legislative theory can offset fiscal inequalities at the state and local levels by federal grants.
            Peterson empirically tests whether state’s political and institutional history will have a legacy of fiscal consequences, suggesting that more professional states will spend more. He uses coefficient of variation (CV) to measure the differences between states by the following independent variables: population density, taxable resources, poverty rates, and population living in urban areas, minority percentage, partisanship, and professionalization of state politics. He concludes that social costs of federalism are considerable. States with higher poverty rates spend no more on redistribution than those with lower poverty rates. Redistributive expenditures are not responsive to social need, all things being equal, and actually are reduced in states with higher percentages of minorities.
Additionally, Peterson tests for the possible “welfare race to the bottom.” He studies states provision of Aid to Families with Dependent Children (AFDC) reforms. In the 1990s President Clinton shifted welfare policies from categorical grants (funding for specific policy outcome) to block grants, which provided state’s discretion for federal funding. Peterson argues that while categorical grants have a redistributive purpose (programs with specific target populations and needs), block grants help development objectives (because they are managed by each state). He argues that in order to have progress, the state government needs to have more of a say how federal aid should be distributed. He is an advocate of the block grants program.
Contrary evidence of this political divide was provided in the McFarlane and Meier (June 1998) article, which evaluated the cost effectiveness of re-allocating categorical/entitlement programs into block grants. They looked at family planning and evaluate the long-term outcomes of the policy after the national government changed its funding mechanism allowing the states to decide how to implement the program. They argue that spending was reliant on the state’s political and historic legacy; more conservative states wouldn’t pay for birth control,  while more liberal one would. Furthermore they suggested that it is of the countries best interest to have better family planning to help curb unwanted pregnancies, which will ultimately also relieve future
poverty rates.
Ultimately, Peterson argues the direction of the price of federalism. Functional theories suggest the price is diminishing with each level of government outperforming the next. Legislative theory anticipates the price with climb and for sees higher levels of government taking credit for financing popular development programs. Peterson argues for its decline and suggests movements different between Great Society programs and the Reaganomics. He adds that each level of government is increasingly focused on the policy area in which it has the greatest competency (i.e. local governments with economic development/national government with redistribution). Legislative theory increased levels of federal development grants between 1957-1977 (pg 83). Yet tax indexation, congressional centralization, fiscal deficits and budgetary crisis have imposed greater political costs on legislative spending proposals. But ultimately, it’s up to the readers to decipher their own verdict.

What is liberation management?

Whereas Kettl (2005) has argued that the attempts at governmental reform has been prompted by efforts at efficiency and cost reduction, Light (1997) suggests that too many reforms have come and gone and have not made any major impasses. Regardless of which you believe is more relevant, one could argue that the national bureaucracies have had to changed their behaviors to meet the various rigor required by these reforms.
In the Tides of Reform, Light agues that there has been too much management reform in government. He groups them into four major categories: scientific management, war on waste, watchful eye and liberation management. He contends that political leaders want to make their mark on the administration and promote reforms to manage mounting bureaucracies. (Although it is well known that every forty years, the US has seen major progressive-style increases in budget. For instance the creation of the 1880s progressives, the 1930s New Deal, the 70s style Great Society, etc.)  Regardless, there are many “tides” of reform promoted either through presidents or by congress to decrease the waist and manage the bureaucratic system to behave more effectively and efficiently.
First, scientific management is one of the founding theories within public administration theory. It stands for the business-like management of government, making tight hierarchal controls with chains of command and specialization of groups to get things done. The acronym of PODSCORB (P-Planning, O-Organizing, D-Directing, S-Staffing, C0-Cordinating, R-Reporting B-Budgeting) integration in public administration came through the scientific management movement. This was the first in the field of PA, which suggested that government could be more effective if it was driven by business management principles.
Next was the “war on waste,” which emphasized inspectors, auditors, cross-checkers and reviewers. This was the first response to fight off “pork” politics. It sought to scare government employees to follow the books and rules set by top management of the agency. It promoted that inspectors and the general media could find waste through audits and investigations. This created headliners for congress to seize and exploit their competencies to manage the growing bureaucracy.
The watchful eye, followed in its footsteps, suggesting that citizens should watch the corrupt behavior of government through sunshine rules, which provided public access to agency procedures and practices. It emphasized that experts could provide key insights and created new roles for citizen participation.
Finally, Light describes liberation management highlighting Al Gore’s initiative to let “managers manage” and promoted networking to improve performance. Kettl in his book The Global Public Management Revolution, among others, later referred to this tide as New Public Management. It has clearly dominated the PA literature for the past quarter of the century.
Kettl argues that this movement began with the progressive governments of New Zealand which used prioritization and corporatism to provide government services; created performance contracts for its employees; out-sourced items; created performance based budgeting and strategic plans to force government to be more cost effective. Kettl argues that these reforms reached the US but were implemented more incrementally and created a less drastic effect. He states that it began with the Hoover Commission, continuing through the administrations of Nixon, Ford, Reagan, and Clinton Administration. He emphasizes NPR in promoting decentralization, downsizing, cost effectiveness, work better at jobs, shrink the role of government and promote information technology to do the job.
National bureaucracies have changed as a result of these reforms. For example, Golden (April 1998) and Yackee and Yackee (Feb. 2006) studies the “notices and comments” section within the rulemaking process highlight the US government agencies incorporating the watchful eye reforms. The added time for bureaucratic rule making allows citizens and business associations to be apart of the process. Furthermore, Light quotes Barzelay and Armajani to refer to the post bureaucratic paradigm of how the American people after the 1950s went beyond thinking that scientific management dictates the bureaucracy, but rather agencies needed to be more customer driven (pg 193-4). This suggests that the main paradigm from 1880s to the 1950s was that government should follow management’s lead to scientific management and the shift focused on the reemphasis of NPR and liberation management. 
A final example illustrates the war on waste reforms, with the creation of Office of Management and Budget and its various reporting mechanisms, evaluations and audits has modified each bureaucratic agency to do more report writing than ever. Furthermore, one can argue that the contemporary public servant is no longer a street-level bureaucrat  (Lipsky 1983) taking care of the public good, but rather a report-writing, contracting officer who prepares for audits, evaluations and budget submissions. Ultimately the evaluation of these jobs is at the heart of the study of public administration.

What is liberalism and how do we study it?

In the End of Liberalism, Lowi (1979) makes a sweeping argument that in the 20st century the United States political system has been “captured” by interest group politics and has ended traditional liberalism—defined as the opposition to fight against capitalist economic domination. He argues that this new political culture to fight for “left leaning” or “conservative leaning” favors has drawn an end to socialism/Marxism. Instead the US draws on partisan politics of democrats and republicans appease public interest groups for political favors. He argues that neither left nor right leaning groups have the complete interest of the public. Rather the sense of commons is lost within the American political system.
            Furthermore, Lowi argues that the “automatic economy” of the post industrial revolution has also converted into the “automatic society.” He stresses that the capitalist ideology has transformed a sense of pluralism. People are more passive and are “content” with more consumerism. The competition with their neighbors over the latest consumer goods overrides their need to help their brothers in need. Ultimately, the end of statism has lead to the embrace of positivism government. Lowi suggests that administration is the central key to positivism. He argues it’s the most rational unit to manage interests. These interests are what make up society and “interest-group liberalism.” Furthermore, democracy is designed to manage conflict.
What’s more Lowi continues and adds that the US government has taken over society by monopolizing direct financial domination, licensing and underwriting risk. Lowi suggests that the government has omniscient power to control the controllers. The state of permanent receivership suggests that policies can be modified without an “immediate transfer or funds, therefore no treasure or congressional or budgetary clearances” (pg. 290). He suggests that the receivership of regulation and discretionary fiscal policy is now in the hands of the government and there are few strings to pull to manage the complete system. Notwithstanding, this awesome power was recently tests and denied with the most recent bailout of the banking sector.
If we take Lowi’s main thesis of interest-group liberalism to describe the role of today’s democracy, we can accept that liberalism is optimistic about government and will develop an expansive role to build what is good for society. In addition we will agree that public interests amalgamate the desires of groups through the struggle of democracy. Therefore the way to have your interest met is to be involved with the system. Participation is the proxy for managing the awesome power of government. In that vein, we can agree with Lowi that there is an intrinsic bias towards business because they are more organized and have more influence on government. Conservatism or business interest are heard more often than the public good because they are richer, more organize and therefore more powerful.
Empirical evidence furthermore agrees with Lowi’s thesis of interest-group liberalism. Golden (April 1998) evaluates the rulemaking process and the notices and comments section within three US government agencies,  EPA, NHTSA and HUD,  to evaluate who participates in the policy process. She finds that the business interests were dominated within the rule-making process at EPA and NHTSA, but had mixed results at HUD with some participation by other government agencies, public interest groups and citizen advocacy groups. Yackee and Yackee repeated Golden’s study in Feb. 2006 and found similar conclusions. They looked at OSHA, ESE, FRA and FHWA from 1994-2001 and also found that the business interest enjoyed disproportional influence over rule making output despite the supposedly equalizing effect of the notice and comments procedures. Therefore one could argue that the public does not get equally represented in the administrative policy process, but business has an upper hand at influencing the government.

The study of the bureaucracy

The study of the bureaucracy is at the heart of public administration, given that it is the organism that executes the policies created by politicians. Since the Pendleton Service Act of 1883, there has been a distinctive political/administration dichotomy or the separation of power between political leaders and the merit-based appointment of professional permanent civil servants. Elected officials are chosen by ‘the people’ they represent and their actions are held “in check” by periodic elections, which is not the case for bureaucracies. The theory of representational bureaucracy argues that policy implementers should also represent the public and can do so by having an equal proportion working within the various agencies.
 Furthermore the theory of political control of the bureaucracy comes from principle-agent theory. It is associated with matters of compliance or responsiveness of elected officials’ wishes. Politicians will attempt to control the activities of bureaucrats by influences policies and platforms. Therefore academics study the outcomes of policies and evaluate their relationship to agencies influence. Related is the theory of bureaucratic capture, which argues that the agencies are ruled by elites and suggests that there is too much political control of bureaucracies.
Seeing as bureaucracies are ultimately organizational structures managed by humans, their behavior is studied in bureaucratic politics. Since bureaucrats are not elected, the public should scrutinize their actions to ensure they are working for the public good and not for their own benefits. Wilson (1989) studied how and why bureaucratic discretion was exercised to produce government action. He distinguishes between managers and executives to examine administrative compliance. In addition, it is theorized that bureaucracy’s reputation is based on an agency’s autonomy. Once an organization has become legitimate, based on the uniqueness of its purpose, it will be able to forge new relationships with other public agencies and a broad range of political actors. This required political legitimacy (Carpenter, 2001) enables the bureaucracy to later demonstrate its capacity to provide the public with “benefits, plans, and solutions”.
Empirical work to test these theories is vast and somewhat inconclusive with various scholars finding a wide range of conclusions. For example, Ringquist (1995) addresses the issue of political control by studying the Environmental Protection Agency (EPA) and efforts by the politicians to alter agency outputs. He evaluates EPA enforcement actions and policy outcomes under the Clean Water Act from 1974-1987. He finds that for political control of bureaucracy to be lasting, it must be institutionalized. Agency’s political appointees must share the same political values and goals as the management and agents attempting to control their efforts. Finally, Ringquist confirms Gormley (1989) theory that the more salient policy area, the more likely to have political involvement (e.g. air pollution vs. water pollution).
From the opposing view, Balla (1998) evaluates if administrative procedures enhances political control of the bureaucracy toward policy choices preferred by legislator-favored constituencies. His interest is whether the Health Care Financing Administration (HCFA) was able to “stack the deck” and influence the outcome of notice and comment process or vice versa. He finds that the agencies were responsive to physicians and didn’t necessarily imply congressional influence over the decision making process. 
Moe (Nov. 2005) searches for the source of bureaucratic power. He argues predominate theory overlooks the role that bureaucrats have used to control politicians. He theorizes that the rank and file bureaucrats can also exercise power in elections to coordinate their behavior through collective action to change policy outcomes. He studies teacher unions in California, NEA and AFT like that of the AFL-CIO, and found that although politically active, unionized teachers provide evidence of influencing their outcomes.
While Moe’ findings did not make definite claims about this power-relationship, O’Leary (Oct. 1994) study of the Department of Interior (DOI) attempts to implement a bill pertaining to an irrigation project in Nevada did find bureaucrats undermine higher-ranking administrators. In her qualitative study, Department of Wildlife employees ignored agency protocol and formed partnerships with outside groups like the Chambers of Commerce, environmental, conservation, and Native American groups to lobby support and change the bill. Her study found bureaucratic administrators specialized environmental matters were not only able to outpace Washington’s laws, but also use their specializations for the public good.
Finally, to conclude, Coleman Selden, at el. (July 1998) examined bureaucratic representation of racial and ethnic minorities in government agencies by studying the policy outcomes of Farmer’s Home Administration (FmHA) and whether or not they reflected minority interests. They found minority interests were pursued in policy outcomes and it was dependent on the bureaucrat’s education, their perception of work role, age, and political party identification. These finds suggests that the normative theory of representative bureaucracy does not necessarily produce favorable policy results for those groups represented. People might have interests that they strive for which does not necessarily focus on their gender, race, ethnicity or the like. A bureaucrat’s public dedications to a specific issue may override their concern with their own minority identification. Therefore this suggests, empirical evidence is important to validate theoretical opinions within the literature, because they might produce unexpected outcomes.

Registro de Revistas sobre Administración Pública, Gestión y Política Pública en Latinoamérica

Aqui esta un Registro de revistas que trabaja los temas de administración pública, gestión y política pública en Latinoamérica .  Falta ...