Micro-Cap Performance Outpaces
Micro-cap indices have dramatically outpaced those covering larger companies, says an analysis of key stock market indices in the United States and Europe. The findings from MBH Corporation plc, a diversified investment holding company, looked at the average performance of 40 major indices covering micro-caps, small-caps, mid-caps, and large-caps in Europe and the U.S. for the year ending March 2021. During this time, the average growth of the 10 indices covering micro-caps was 90.89 per cent. The corresponding average figures for the small-cap, mid-cap and large-cap indices were 73.78 per cent, 57.58 per cent, and 45.03 per cent. It says the strong performance of many micro-caps has been due to the fact that many rely more on domestic business and are generally benefiting from hopes for rebounding economies and growing optimism here. Micro-caps tend to be among those that benefit the most from economic recoveries. In addition to this, micro-caps can find it easier to adapt to new market conditions than larger companies and this has enabled many to reduce the impact of the Coronavirus crisis on their operations or even to adapt and take advantage of the new working environment.
Nominal Yields Pressure Real
With shorter break-evens at multi-year highs after a 200bp (basis point) rise since the COVID-19 pandemic started, higher nominal yields are putting pressure on real yields, led by the U.S., says FTSE Russell’s ‘Monthly Fixed Income Insight Report for April 2021.’ Curves are flatter than after the 2013 Taper Tantrum, leaving further steepening possible, given the scale of policy stimulus. Chinese government bonds remain a safe haven, it says. First quarter returns show a sell-off in longer treasuries pressurizing inflation linked and IG credit. The macro backdrop suggests inflation fears and recent bond market upheaval intensified recovery uncertainties. Tensions between the U.S. Fed’s dovish policy goals and the bond market’s more hawkish expectations remain.
Asset Managers Still Have Much To Do
Asset managers in Europe still have much to do to comply with both the spirit and the detail of the EU’s Sustainable Finance Disclosure Regulation (SFDR), says Cerulli Associates. They are now required to incorporate sustainability risks across their investment processes, product governance, and internal systems. Under SFDR, European funds need to be classified by their managers into one of three categories, with the required disclosures tailored to each. Varying degrees of disclosure on environmental, social, and governance elements have to be provided to investors in all funds. Fabrizio Zumbo, associate director, European asset and wealth management research, at Cerulli Associates, says that asset managers face a number of challenges when categorizing products under the three categories of the regulation. For example, it is not clear what constitutes ‘promoting’ environmental, social, or sustainable objectives.
Penad Acquires SeclonLogic
Penad Pension Services Limited has acquired SeclonLogic, an Ontario-based provider of defined benefit pension plan and group benefits administration software solutions. Both have been serving plan sponsors in the Canadian market for well over 25 years. The SeclonLogic team will continue to provide its pension and benefits software solutions to its clients by offering a greater depth of technological and human resource services. Both Penad and SeclonLogic have based their solutions on the SQL Server database technology and as such will now share ideas, technologies, methods, and resources in order to provide the best administrative solutions possible.
Young Has New Role
Pension Plan Position For Future Examined
The ACPM (Association of Canadian Pension Management) will explore key findings and developments from CIBC Mellon’s study of leading Canadian pension funds and review strategic questions as plans assess which activities to perform in-house and which to outsource at its ‘In Search of New Value: How Canadian Defined Benefit Plans are Positioned for the Future’ session on May 19. Alistair Almeida, segment lead, asset owners, at CIBC Mellon; and Asif Haque, chief investment officer; and Derek Dobson, chief executive officer and plan manager, at the CAAT Pension Plan will also discuss current and emerging investment models and expected future impacts to the Canadian pension fund investment space, as many pension funds are reviewing their approach to their investment strategy in light of the pandemic. Information is at https://www.acpm.com/ACPM/Events/Webinars.aspx
Governance Good For Investors
Good corporate governance has been largely good for investors’ pockets during the COVID-19 pandemic. An S&P Global report finds that in the first year of the pandemic, large funds with environmental, social, and governance (ESG) criteria outperformed the broader market. The analysis included 26 ESG exchange-traded funds and mutual funds with more than $250 million in assets under management. From March 5, 2020, to March 5, 2021, 19 of the funds grew between 27.3 per cent and 55 per cent, outpacing the S&P 500 index’s 27.1 per cent rise. While ESG investing has often been criticized as failing to maximize returns, the analysis is the latest piece of mounting evidence that such funds outperformed their peers and the broader market during the pandemic.
CAAT Adds New Members
Sanofi Pasteur and St. John Ambulance have joined the Colleges of Applied Arts and Technology (CAAT) Pension Plan’s DBPlus. Under DBplus, matching contribution rates typically range from five per cent to nine per cent and, once established at joining, are fixed. Sanofi Pasteur is a biopharmaceutical company focused on human health. It works to prevent illness with vaccines and provide innovative treatments to fight pain and ease suffering. About 1,000 members joined from Sanofi Pasteur. The St. John Ambulance charity operates with a mission to improve people’s health, safety, and quality of life. It provides training to over 500,000 students in Canada each year in first aid and CPR. About 500 members joined from St. John Ambulance. Since DBplus was introduced in 2019, CAAT has welcomed about 60 employers from coast to coast including Brink’s Canada, Torstar, the University of Saskatchewan, and the United Way of Greater Toronto.
Plan Designed For Small Business
Medavie Blue Cross has launched ‘Benefits for Small Business,’ a life and health plan that gives small business employees the protection they need and expect. Available to established companies with up to 10 lives in Ontario and Atlantic Canada, the program provides coverage for extended healthcare, including vision care, prescription drugs, dental, and disability as well as life and travel insurance. As part of the plan design, claims are pooled together with other small businesses that have been operating for at least six months. This approach lowers the financial impact of high claims activity and ensures the plans remain cost-effective for businesses over time. The plan also provides added flexibility with a health spending account option and employee-paid optional coverage for critical illness, accidental death, or dismemberment, and additional life insurance.
Equity ETFs Lead Canadian Flows
Equities ETFs led the way as $4.7 billion flowed into Canadian ETFs in March, with investments in small-cap and value funds accelerating, says a report from National Bank Financial. Fund flows reflected the broadening of the market rally from the technology and healthcare sectors into cyclicals such as energy, financials, and industrials. Small- and mid-cap funds also benefited as the inflows into these ETFs have accelerated month over month in 2021, bringing this category’s first quarter total net flows to $374 million, or 29 per cent of 2020’s year-end assets under management. March’s ETF flows compared to $5.8 billion in February, bringing the first-quarter total to $13.4 billion. Equities ETFs accounted for more than 60 per cent of total net flows in March, with $1.8 billion going to international equities ETFs and $1 billion to U.S. funds, primarily those focused on environmental, social, and governance (ESG) investing. Cryptoasset ETFs continued their strong performance after debuting in February, with $483 million flowing in last month. Cryptoasset ETFs grew by 77 per cent in one month and assets crossed the $1 billion milestone, settling at $1.3 billion at month-end, said the report.
CPP Investments Developing Office Space
RMZ Corp, a privately owned real estate developer in India, and the Canada Pension Plan Investment Board (CPP Investments) have entered into a joint venture to develop and hold commercial office space in Chennai and Hyderabad. The investment will allow for the expected development of 10.4 million square feet of high-quality commercial office sites. Of the 10.4 million square feet included in the transaction, 7.5 million square feet is already under active development with construction of the remaining space due to commence in the coming months.
Morgia Has New Role
Aligning With Net Zero Examined
Ten live webcasts with national and international experts will be featured at the ‘RIA Virtual Conference’ from June 7 to 11. It will feature a CEO roundtable on leadership and governance for a sustainable and inclusive Canada; strategies and practices for investors to align their portfolios with net zero; achieving the SDGs by 2030. Information is at https://riaconference.ca/
Cost Burden Of Marriage Breakdown Not Addressed
While the Financial Services Regulatory Authority of Ontario (FSRA) is consulting on the administration of pension benefits upon marriage breakdown, the effort does not address the issue of the cost burden to plan administrators and other plan members. In comments on the ‘Proposed Guidance on Administration of Pension Benefits upon Marriage Breakdown’ and the ‘Guide for Members and their Spouses on Pensions and Marriage Breakdown, Carly Wybrow, a consultant and actuary at Actuarial Solutions, says it is not clear how much power FSRA has to increase the maximum fee that can be charged. And, since it is much more of an issue for the smaller pension plans, this is not always top of mind. Her view is it is unreasonable to expect any party outside of the marriage to subsidize the expense of this process. “In my opinion, it should fall solely on the shoulders of the affected member/former spouse going to through the marriage breakdown,” she says. She would also like to see a system put in place where independent actuaries are again responsible for calculations (funded entirely by the affected plan member/former spouse), but where the former spouse could still access their portion of the family asset. “Or, at a minimum, see the maximum fee that a plan administrator can charge be increased to something which better reflects the complicated nature of these calculations and, in particular, the fact that outside consultants/lawyers/actuaries are often required (increasing the cost to the plan),” she says.
Activities Make Financial System Fragile
Pensions and endowments’ investment strategies aid and abet activities that make the financial system more fragile, says a report from the Predistribution Initiative, a group that focuses on governance, investment practices, and the systemic risks of investments. It says the growing scale of institutions and the large amounts of money they need to deploy into high-risk investments is leading to consolidation among asset managers, higher global debt levels, short-term corporate behaviour, and market instability. The paper lays out a case that institutions’ investment strategies are in conflict with environmental, social, and governance goals to which they are increasingly committing. Capital markets have become institutionalized and the institutions’ only option in many cases is to put billions of dollars to work in the largest public and private companies. That results in companies, for example, taking on unsustainable amounts of debt.
Over the next few months, inflation will rise higher than many predict and will stay at this level for some time, says Manoj Pradhan, head of the global economics team at Morgan Stanley and co-founder of the macro-economic consultancy firm Talking Heads. Speaking at an event organized by fixed income ETF provider Tabula Investment Management, he said while inflation in the U.S. is currently running at 1.7 per cent, it could reach three per cent later this year. This rising inflation will make “asset returns harder to extract” and will threaten the independence of central banks as politicians seek to avoid taking action to control prices. However, “there is still some complacency it is going to fall and this risk needs to be challenged,” he said. Persistently higher inflation is on the way because current fiscal stimulus programs are going directly into the real economy, in contrast to similar programs following the global financial crisis which largely went into the financial system. “Increased inflation will mean the yield curve steepens and attempts to control it will push inflation even higher, with the result that asset returns will be harder to extract,” he said.
Employees Prefer Hybrid Work Arrangements
As more companies are calling workers back to the office, a study by Robert Half shows that about one in three professionals currently working from home due to the pandemic would look for a new job if required to be in the office full time. More than half of all employees surveyed (51 per cent) would prefer a hybrid work arrangement, where they can divide time between the office and another location. The need for organizations to offer flexibility is emphasized as professionals are hesitant about working from home full time because they fear relationships with co-workers could suffer, fewer career advancement opportunities could arise due to a lack of visibility, and productivity could decrease while at home. Employers may want to consider easing the transition back on-site by giving employees the freedom to set preferred office hours, paying employee commuting costs, and relaxing dress codes. However, David King, Canadian senior district president of Robert Half, says “companies should be prepared for a potential disconnect between their ideal work structures and that of their employees.”
Pace Of Vaccinations Impacts Economies
The near-term outlook for global growth is likely to be determined by two key factors: the pace of COVID-19 vaccination programs and fiscal stimulus, says the AB ‘Global Economic Outlook for April 2021. The U.S is at a significant advantage over other advanced economies in these areas and economic growth there is expected to reach 6.5 per cent in 2021 and 4.6 per cent next year. This would push the level of output above the pre-pandemic trend. With rising COVID-19 cases likely to delay the reopening of economies in Europe, the view is more cautious on the euro area’s prospects. Output there is not expected to reach pre-pandemic levels until well into 2022. In China, output is already above the pre-pandemic trend. With economic and social stability paramount, China is likely to exert a stabilizing influence on global growth. However, it says the global economy is on the cusp of a new, more inflationary, regime. The first signs of this may become evident as base effects and higher commodity prices push headline inflation temporarily higher. This is a more challenging backdrop for central banks and while the U.S. Federal Reserve has been surprisingly relaxed about rising bond yields, it may be approaching the limits of its tolerance ‒ especially if the equity market comes under pressure.
Manulife Offers Physiotherapy Program
Manulife is offering its plan members basic access to Phzio Canada’s MSK360, a virtual physiotherapy program. With approximately one in five employees experiencing a musculoskeletal condition annually that impacts their ability to perform in the workplace, employees are struggling with physical injuries, functional restrictions, or limited mobility and plan sponsors see an increased need for treatment programs, accommodations, and time away from work. This includes injury prevention content, early intervention, therapeutic programs, and preferred rates for virtual providers that can be claimed using the plan member’s benefits coverage. Plan sponsors will have the option to upgrade access to MSK360 for their plan members and provide unlimited virtual evaluations and treatments, ergonomics assessments, and physical conditioning plans. With this option, plan sponsors will also gain access to advanced metrics for pre-disability patterns, utilization, consumption, and member satisfaction.
Stephen Chairs Alliance Board
Pain Management Examined
The Benefits Breakfast Club will look at ‘Pain Management, Stressors and Coping Strategies.’ In the May 6 session, Dr. Christine Lay, a neurologist at Women’s College Hospital, will discuss pain management; and Jamie Marcellus, president of Humanacare will look at stressors and coping strategies. The workplace impact will be addressed by Mike Mousseau, national wellbeing and engagement consultant at AJ Gallagher. Information is at BBC Webinar – Pain Management – May 6, 2021 (connexhc.com)
Banking Bosses Conflicted On Climate Change
Canada’s banking bosses are too conflicted to take climate change seriously, says an analysis by DeSmog. It says the directors of Canada’s top five banks hold more extensive ties to polluting industries than their international counterparts and this may prove a barrier to taking specific steps to decarbonize their financing, as they have publicly promised. It studied the current and past connections of board members of the banks to the world’s most carbon-intensive industries. Its findings show Canada stands out in the analysis as the region with most ‘climate-conflicted’ bank directors who currently have ties to high-emitting sectors, compared to international peers. The research found that 62 per cent of Canada’s bank directors have current connections to high-carbon companies, compared to 44 per cent for the U.S. banks, 34 per cent for Europe, and 31 per cent for the UK. When past and present connections are included, more than 82 per cent of board members across Canada’s banks held positions in environmentally damaging companies. The analysis showed 35 per cent of directors were linked to the energy sector alone, revealing long careers spent in the oil, gas, and coal industries. DeSmog manages several climate change misinformation databases.
Annuity Tops Billion Dollar Mark
Willis Towers Watson, in collaboration with Sun Life, iA Financial Group, and Brookfield Annuity, has provided a group annuity buy-out transaction of $1.8 billion for over 6,000 members of the General Motors of Canada Company salaried pension plan who retired prior to June 1, 2020. Under an annuity buy-out, an insurance company assumes responsibility for making pension payments to plan members in exchange for a premium from the pension plan sponsor. This group annuity transaction involves the largest asset in-kind transfer in Canadian history. In this arrangement, most of the pension plan investments were not sold, but transferred to the insurance partners in kind. Marco Dickner, retirement risk management leader, Canada, at Willis Towers Watson, says, “This deal is ground-breaking because it demonstrates that Canadian insurers can now effectively meet plan sponsors’ needs for jumbo transactions, a milestone in the evolution of pension risk transfers in Canada.”
Risk Assets Adopted Back Into Portfolios
Sovereign wealth funds and other institutional investors are gradually adding risk assets back into portfolios as the COVID-19 pandemic lingers, with investors deploying some accumulated cash and reducing fixed income positions, says a report by the International Forum of Sovereign Wealth Funds and State Street. It found that institutional risk sentiment across asset classes also broadly improved in the period to March, particularly for foreign exchange, commodity-sensitive assets, and equity reallocations. Investors started 2021 with a more neutral stance across asset classes than the underweight positions in risk assets they held in 2020, the report says. Cash levels still remain high, but “there is evidence of a sustained rotation from cash and fixed income into equities since July 2020,” it says.
Global ESG Assets Double
With global ESG (environment, social, and governance) assets in mutual funds and ETFs (exchange traded funds) doubling in the five years to June 2020 and reaching almost US$1.7 trillion by the end of 2020, there is growing recognition that the financial system has a crucial role to play in the transition to a low-carbon and climate-resilient economy, says the EDHEC-Risk Institute. Its ‘Measuring and Managing ESG Risks in Sovereign Bond Portfolios and Implications for Sovereign Debt Investing’ publication sets out a formal framework for incorporating ESG criteria into risk management and investment decisions involving sovereign bonds. The main objective is to assess whether it is possible to incorporate ESG constraints through a significant improvement of the portfolio ESG score without a substantial increase in absolute and relative risk budgets, or a substantial decrease in expected performance. The study finds higher environmental scores for developed countries and higher social scores for emerging countries are associated with lower costs of borrowing for issuers and consequently with lower yields for investors. As well, negative screening leads to more diversified portfolios and lower levels of tracking error, while positive screening leads to higher levels of improvement of ESG scores, at the cost of an increase in absolute and relative risk budgets. It also shows a dedicated focus on absolute or relative risk reduction at the selection stage allows investors to reduce the opportunity costs along the dimension that is most important to them. Finally, ESG momentum strategies in sovereign bond markets can be used to further reduce some of the aforementioned opportunity costs.
Link Partners With Purpose
Link Investment Management Inc. has partnered with Purpose Advisor Solutions (PAS), a technology platform and services provider for independent financial advisors and portfolio managers, to offer group plan solutions in the Canadian workplace. Purpose has also invested in a Link financing round alongside an undisclosed group of investors. This strategic partnership will support independent portfolio managers and advisors by adding Link’s online employer experience platform ‒ which includes paperless plan administration and support for a wide range of group savings, pension, equity, and health spending plans ‒ to the ecosystem of services and digital tools provided by PAS. The partnership offers a wide range of plans, including defined contribution pension plans (DCPPs) and group TFSAs and RRSPs; plan support for employers, empowering them to select the plan that is right for their employees; and greater reporting and insights which can be used by advisors to help guide employee decision making.
CDPQ Invests In Solmax Acquisition
Solmax, a global producer of polyethylene geomembranes for industrial and environmental applications, will acquire TenCate Geosynthetics, a global provider of geosynthetics and industrial fabrics, from Koninklijke Ten Cate in the Netherlands. The Caisse de dépôt et placement du Québec (CDPQ) and Fonds de solidarité FTQ, Solmax’s long-term financial partners, are both investing in this transaction.
Cooke Leads Health And Benefits
Legal Update Provided
The CPBI Southern Alberta Region’s ‘Legal Update’ will provide updates on legislative and regulatory developments over the past year of interest to administrators of pension plans with Alberta members. April 27, Sean Maxwell, a pensions and compensation lawyer at Blake, Cassels & Graydon LLP, will outline recent case law developments involving pension and benefit arrangements and potential discrimination complaints that may arise in the context of such plans, and look at considerations for employers in developing COVID-19 related testing and vaccination requirements in the workplace. Information is at https://www.cpbi-icra.ca/Events/Details/Southern-Alberta/2021/04-27-Legal-Update
Commuted Value Interest Rate Assumptions
The interest assumptions required to calculate commuted values and marriage breakdown values for an event which occurs in any month up to and including April 2021 are now available at www.an-actual-actuary.com. An Excel spreadsheet on the website contains nine worksheets:
- Commuted Values February 2011 CIA
- Marital Breakdown: CSOP 4300 ‒ January 2012
- Ontario (Bill 133) Prior Rates – Rates for Ontario Marital Breakdown with valuation date prior to January 1, 2012
- Annuity Proxy for Solvency Calculations for Non-Indexed Fully-Indexed Pensions
- Minimum Interest on Employee Required Contributions
- HISTORICAL Marital Breakdown: CSOP 4300 ‒ May 2009 (Now Frozen)
- HISTORICAL: Commuted Values ‒ 2009 Basis (Now Frozen)
- HISTORICAL: Commuted Values ‒ 2005 Basis (Now Frozen)
- HISTORICAL: Commuted Values ‒ 1993 Basis (Now Frozen)
You can use this spreadsheet to compare the interest rates which you may have calculated and/or you can download the spreadsheet to your own computer. Another actuary has already provided a peer review of the updated rates in this spreadsheet and determined that he/she agrees with the results.
Stronger Recovery Now In Cards
A stronger recovery is now in the cards for the global economy, thanks to policy support and COVID-19 vaccines. However, there is a dangerous divergence emerging across and within countries, says the International Monetary Fund (IMF). Its latest ‘World Economic Outlook’ is now projecting global economic growth of six per cent in 2021, up 0.5 percentage points from its January forecast and 4.4 per cent in 2022, up from 4.2 per cent. The IMF estimated that global growth contracted by 3.3 per cent in 2020. The upgrades in global growth were mainly because of improvements in the outlooks for advanced economies to 5.1 per cent this year from a previous 4.3 per cent estimate, and to 3.6 per cent in 2022 from a 3.1 per cent forecast. However, diverging recovery paths are likely to create wider gaps in the standards of living across certain countries versus pre-pandemic expectations. Low income countries are expected to record an average annual loss in per capita GDP for the period 2020 to 2024 of 5.7 per cent, while in emerging markets the loss is expected to be 4.7 per cent. These losses are reversing gains in poverty reduction.
TDAM Joins ICGN
TD Asset Management Inc. (TDAM) has joined the International Corporate Governance Network (ICGN) as part of its commitment to promote and support high standards of corporate governance and sustainability. Established in 1995 as an investor-led organization, the ICGN mission is to promote effective standards of corporate governance and investor stewardship to advance efficient markets and sustainable economies worldwide. ICGN members are from over 50 markets with assets under management in excess of $54 trillion and include pension funds, insurance companies, and asset managers such as TDAM. As part of joining ICGN, it is also endorsing the ICGN Global Stewardship principles, which set out ICGN’s best practices in relation to investor stewardship obligations, policies, and processes. These include influencing policy by providing a reliable source of investor opinion on governance and stewardship; connecting peers at global events to enhance dialogue between companies and investors around long-term value creation; and informing dialogue through education to enhance the professionalism of governance and stewardship practices.
Sustainable Energy Group Created
The Canada Pension Plan Investment Board (CPP Investment) is creating the Sustainable Energy Group (SEG), an investment group that combines the organization’s expertise in renewables, conventional energy and new technology, and service solutions. It will generate investment opportunities for the fund, positioning CPP Investments as a global energy investor. Through the combination of the energy and resources and power and renewables groups, SEG will have approximately $18 billion in assets. According to the ‘Bloomberg New Energy Outlook 2020’ report, around US$15.1 trillion is expected to be invested in new power capacity alone by 2050. SEG is well-positioned to pursue a variety of opportunities in this and the broader sustainable energy market, having combined expertise in conventional energy, renewable energy, and carbon capture as well as emerging and disruptive opportunities through its innovation and technology and services team.
Equity Markets Gain
Despite renewed volatility in March, most equity markets gained in the first quarter, while government bonds fell, says FTSE Russell’s ‘Monthly Performance Report for March 2021.’ Vaccine and stimulus fueled optimism in the recovery of the global economy and corporate profits. This carried risk assets higher for most of the period, but worries about a potential destabilizing rise in bond yields reversed some of those gains. Despite higher volatility in March, most equity markets gained in the quarter, although fixed income returns were broadly negative, with 10-year U.S. and UK inflation-linked bonds being the worst performers. Investment grade underperformed high-yield credit. Oil and copper rallied strongly, while gold ended lower.
CI Acquires Full Ownership
CI Financial Corp. will acquire full ownership of alternative fixed income investment firm Lawrence Park Asset Management. CI currently holds a minority interest in Lawrence Park which manages approximately C$600 million of assets specializing in credit-focused strategies, including a hedge fund, a liquid alternatives fund, and an ETF. Lawrence Park employs a relative value approach to identify and profit from inefficiencies in global corporate bond markets (Canada, U.S., and Europe) and utilizes an active portfolio management process.
Solar Project Acquisition Closes
Leeward Renewable Energy, LLC, a growth-oriented renewable energy company and portfolio company of OMERS Infrastructure, has closed the previously announced acquisition of a utility-scale solar project platform of approximately 10-gigawatts (GW)AC from First Solar, Inc. The project development platform includes 773 megawatts (MW) of projects that are expected to commence construction in the next two years, as well as the 30-MW Barilla Solar Project, which is operational.
Iacoucci Has New Duties
Vaccination Program Outlined
‘Inoculating against misinformation – A case study on a successful work place Vaccination program’ is the focus of a CPBI Pacific session on April 28. Ajit Johal, founder and clinical director of Immunize.io, will look at the Richmond School District (RSD38) comprehensive workplace immunization services for staff. The program has resulted in an increased uptake in immunizations and significantly higher vaccination completions than the national average. Information is at https://www.cpbi-icra.ca/Events/Details/Pacific/2021/04-28-Inoculating-against-misinformation-A-case