ROLES OF SHADOW BANKING, P2P LENDING AND SOLUTIONS FOR USURY TO REDUCE URBAN-RURAL DISCREPANCIES FOR

International Journal of Mechanical and Production Engineering Research and Development (IJMPERD) ISSN(P): 2249-6890; ISSN(E): 2249-8001 Vol. 10, Issue 3, Jun 2020, 3897-3912 © TJPRC Pvt. Ltd.

ROLES OF SHADOW BANKING, P2P LENDING AND SOLUTIONS FOR USURY TO REDUCE URBAN-RURAL DISCREPANCIES FOR VIETNAM SOCIAL ECONOMIC DEVELOPMENT IN INTEGRATION ERA DINH TRAN NGOC HUY1, DO HONG NHUNG2, NGUYEN QUYNH TRANG3, TRAN DUC THANG4 & NGUYEN DUY MAU5 1

Banking University HCMC, Ho Chi Minh City Vietnam, International University of Japan, Japan 2,4 3

National Economics University, Hanoi, Vietnam

Accounting and Auditing Faculty, Thuongmai University, Hanoi, Vietnam 5

DaLat University, Vietnam

ABSTRACT Since the introduction of a peer-to-peer lending model, people have been provided with online lending services at a lower service cost than traditional loan service costs, because of the company's low operating costs. Therefore, P2P lending will contribute to reducing urban-rural gap and the discrepancies between rich and poor. In this paper, we analyze and

aspects: positive and negative. P2P lending model is a lending process where borrowers and lenders meet on an online platform without a financial intermediary like a bank. Experiences of black credit and consequences for the economy, and P2P lending online in China became a lesson for Vietnam as well as developing countries. Control solutions, P2P lending development orientation, black credit (usury), legalizing regulations and interest monitoring, risk management in peer-to-peer lending and usury is essential to ensure the role of these activities in supply chain financing, lending to SMEs and consumers, and addressing deficiencies of the commercial banking system. The safety period for lenders and

Original Article

evaluate the roles of shadow banking system (HTNHN) in Vietnam and peer-to-peer lending (P2P lending) in both

borrowers is an issue that needs to be discussed, towards the topic of sustainable development for the shadow banking system, thereby contributing to social security, creating conditions for low-income people to borrow capital to support production and business, thus contributing to the reduction of the rich-poor discrepancies.

KEYWORDS: Peer-To-Peer (P2P) Lending, Rich and Poor Discrepancies, Urban-Rural Gap, Black Credit, Usury, Shadow Banking, Policies, Sustainable Development JEL: O11, O18, O20

Received: Jun 10, 2020; Accepted: Jun 30, 2020; Published: Jul 17, 2020; Paper Id.: IJMPERDJUN2020372

INTRODUCTION The commercial banking system in Vietnam in recent years has played an important role in developing all aspects of the economy. 

Besides, there is still a shadow banking system and peer-to-peer lending. P2P lending operations platforms vary in type and manner of implementation. However, these platforms have specific commonalities, with the following roles:



Providing additional options other than bank deposits for investors;



It effectively conducts financial resources to those in need thanks to their high specificity;

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It provides credit to the economy in the event that normal banks are in a bad state, thus helping to alleviate credit hunger;



It constitutes a source of risk dispersion for the formal banking system.

Since the introduction of a peer-to-peer lending model, people have been providing online lending services at a

lower service cost than traditional loan service costs, because of the company's operating costs. low P2P loan. As a result, investors (lenders) will gain higher profits than depositing or investing in any other products of the bank. Meanwhile, borrowers enjoy lower interest rates (even though the peer lending company has deducted the costs of building an online rating and credit rating system.) Therefore, it helps to improve loans for low-income households, support production and business, and reduce the gap between rich and poor.

The paper is organized as follows: after the introduction, it is the research issues, reviewing and comparing previous studies. Next, part 3 will include methodology and data and part 4 will present the main research results. Section 5 provides us with some policy discussion, conclusions and recommendations that will be covered in section 6.

RESEARCH CONTENTS Research Issues The scope of this study will include: 

Research Issue 1: The role of HTNN, peer-to-peer lending P2P lending, and black credit in a developing economy - the case of Vietnam



Research Issue 2: Risks and mitigation measures, risk management in shadow banking, P2P lending and black credit.

This paper also examines the following two (2) hypotheses: 

Hypothesis 1: Increasing P2P lending will contribute to the development of the economy and reduce the rich-poor discrepancies, the urban-rural gap.



Hypothesis 2: Black credit (usury) can be managed and controlled to benefit the economy.

Previous Studies Pozsar et al. (2010) proposed that increasing capital and liquidity standards for depository and insurance companies would be able to improve the profitability of shadow banking. Therefore, shadow bank (Shadow), in one form or another, is expected to be an important part of the financial system in the near future. Then Vishny et al. (2011) mentioned that under reasonable expectation, the shadow banking system will stabilize and improve welfare. However, when investors and intermediaries ignore risks at a later stage, the expansion of risk lending and the concentration of risks in financial intermediaries create financial weakness and volatility over time.

On the borrower's side, evidence shows that knowledge (directly or inferred) exploits soft and implied information, P2P can provide prices and / or access to potential borrowers. However, social connections require expensive certifications to inform credit risk (Morse, 2015). Empirical research is very consistent with the notion that underground banking is associated with higher profits and risks of commercial banks (Tang and Wang, 2016). Lenz (2016) stated that

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there is no doubt that long-term P2P lending platforms will need a dedicated, unique legal framework for Europe. The research results show that the P2P lending platform between Singapore and Indonesia has similarities. There are no significant differences. But the behavior of societies is different, in Indonesia using P2P more for consumption because the community does not have the habit of saving, while in Singapore, P2P is for important, sensitive time-sensitive purchases.

Government rules in Singapore supported by Fintech transactions are more transparent. While in Indonesia, there is still confusion about Fintech's perception (Yunus, 2018).

Ordonez (2018) argues that banks implicitly improve welfare because it provides a channel to get rid of more valuable regulations for banks that have access to efficient investment opportunities. Caverzasi (2019) questions the views of traditional banks and shadow banking as two parallel and alternative systems, arguing that financialization does not change the role of commercial banks as people. Money creation, which redirects money creation in the financial sector, allows expanding them.

Next, Thaker et al. (2019) consider factors affecting retail investors investing in P2P lending platforms in the Klang Valley, Malaysia. The results show that investment intent is primarily influenced or driven by belief. Other variables, namely perceived risk, ease of use and security, were found to have no impact on investor decisions. A typical P2P business lending model is men, highly educated and relatively wealthy with a degree in science, business or finance (Pierrakis, 2019).

Last but not least, Zhou et al. (2019) found an increase in the proportion of central bank policy that led to a reduction in the growth rate of banks' assets. In addition, they found a positive link between banks and bank risks. The effectiveness of monetary policy increases when banking risks are high. In summary, the research results show that banks are a factor of the bank's risk channel of monetary policy. They suggest coordinating policies between monetary and macro policies and closely monitoring banking activities to reduce risks in the financial sector. So far, many studies have been done in this peer-to-peer (P2P) lending area, however, this article provides specific recommendations based on an analysis of lessons learned by shadow banking, P2P lending and usury in countries around the world including USA, China, Japan.

METHODOLOGY This research paper uses qualitative research and analysis methods, logical analysis, deduction and synthesis to provide direction and solutions, dialectical materialist methods combined with historical materialistic methods. Consider assessing phenomena, things, economic objects, inductive interpretation methods and evidences in the economy to contribute to economic reality.

In addition, this paper uses general data analysis methods and draws lessons from other countries to comment on the results, then propose policies based on these analyzes.

MAIN FINDINGS Overview of Cooperative Activities, P2P Lending, Black Credit (Usury) The European Commission defines shadow banking entities as follows:

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Specialized financial institutions (SPVs) carry out forward / liquidity swaps by securitization operations;

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Money management funds or investment funds that provide services similar to deposits;

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Investment funds providing credit and loan services;

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Financial companies, securities organizations that provide credit services or credit guarantees or conduct forward / liquidity swaps are not regulated like a typical commercial bank;

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Insurance, reinsurance organizations that issue credit products or credit guarantees.

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Securitization



Lending by securities and repo securities.

Thereby, we see: The above entities are legal financial institutions, but not licensed for banking activities. Not

only a commercial bank, but these entities still have the same operations as regular banks except deposit mobilization.

These activities are not illegal activities (this is different from the black credit), but are not within the supervision of the government's financial supervisory agencies, not within the scope of the system's services and Deposit insurance system.

So: 

Shadow bank is a term for companies and organizations that are not banks but operate and function almost like a traditional bank.



Shadow banking system is a credit intermediation system involving entities and activities that are not part of the normal banking system.



Shadow banking is also known by: underground bank, shadow bank.



Besides, the simple peer-to-peer lending model is based on online, online P2P lending platform, which can be accessed via computers, laptops, tablets, tablets, mobile phone APPs, etc. P2P companies acting as an intermediary do not bear the credit risk of 2-side fees collected from lenders and borrowers, investors (lenders) will be subject to credit risk and liquidity risk if the borrower the loan cannot be repaid. If lending in foreign currency or gold (if allowed), there will be additional risks of exchange rates and risks of price or inflation.

The summary of a simple peer loan model is as follows:

Figure 1

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Peer to peer lending is also known as social or crowd lending. Or to put it simply, peer-to-peer lending is a business model that uses an online platform that connects investors (with idle money) to those who need it.

The peer-to-peer lending system provides credit access to those who will be denied by regular credit institutions or to consolidate student loans with more favorable interest rates. 

Peer-to-peer lending helps individuals and organizations, especially small and micro enterprises not qualified for bank loans, without collateral to easily access finance this is an important and important contribution to help countries in their efforts to develop comprehensive finance.



Lending procedure is simple and fast, after 30 minutes, customers can borrow with a flexible amount from a few million to several tens of millions.

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The operating costs of a peer-to-peer lending platform are low because transactions are done online quickly with a compact, inexpensive management system.

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The emergence of peer-to-peer lending will limit black credit activity. These online P2P loan platforms are suitable for individual borrowers and lenders, and then evolved into a platform for micro and SME businesses.

The reason for the existence of peer-to-peer lending and private sector lending is because it has the advantages and remedies of deficiencies of the existing commercial banking system: 

First, higher profits for lenders and lower costs for borrowers than traditional banks. It is clear that the peer-to-peer lending model has significantly reduced operating costs in the lending process by eliminating the intermediary role of the bank.



Second, allowing access to credit for borrowers who cannot borrow from the bank.

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Third, peer-to-peer lending has more social value than traditional banks.



Fourth, technological innovation has improved service quality and speed.



Fifth, Simple lending procedures, quick disbursement time

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Sixth, Reach customers unfamiliar with bank loans

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Seventh, create favorable conditions for households and low-income people to access loans



Eighth, contributing to the gap between rich and poor and urban-rural gap Next, "black credit" is a form of lending, borrowing or raising capital at an interest rate in excess of the interest rate imposed by the State or by the law, by individuals, groups of people or groups. financial services business organizations, often associated with illegal debt collection and appropriation of properties. (Source: Law newspaper)



Forms: pawnshop, debt collector, playboy, online loan with high interest



Failure to pay the debt may result in threats or property seizures

Some Issues of HTNHNN, P2P Lending, Black Credit (Usury) Firstly, the issue of barriers and legal corridors should be clear with clear criteria in the process of developing the legal framework, such as creating a healthy playing field and appropriate income tax, creating opportunities for P2P businesses

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access the CIC credit information system in a safe, transparent, risk management, and controlled manner according to the operational process. Secondly, the issue of personnel and the quality of appraisers and credits for peer-to-peer lending activities P2P lending. It is about how to ensure staff quality training to meet fintech-based credit operations. Thirdly, it is the issue of the size of the loan and the credit growth rate in the P2P banking lending activity, which is controlled and oriented in each financial year. Fourthly, the issue of controlling interest rates on deposits and loans in P2P lending needs to be transparent and competitive.

Fifthly, establishing a clear, transparent relationship between P2P lending activities and the system of commercial banks and credit institutions.

Finally, risk mitigation includes credit risk, as analyzed below.

Risk Analysis of HTNHNN, P2P Lending Because P2P companies are only loan brokers, debt collection is owned by lenders, so there is a credit risk when borrowers are unable to repay. This is the first problem, giving rise to the need of credit risk management.

The second problem, the newly launched P2P lending system, does not have as much lending experience as credit institutions and banks, so there is a risk that lending capacity will also need to be addressed. This is also a form of risk related to lending experience, customer credit rating and customer rating experience.

The third problem, P2P lending model is a form of fintech so there will be risks related to IT, digital technology and e-commerce need to be addressed, and also risks related to security and data security. Data protection and network security.

Fourth, the risk management process with traditional steps including how to assess, assess and monitor risks will work in the P2P lending technology platform.

Fifth, legal risks. In Vietnam (as in many other economies), peer-to-peer lending is still within the legal gap that has not been filled.

Sixth, operational risk. Peer to peer lending is based on a technology development platform, so operational risk can occur when software fails or stops working.

Seventh, moral hazard. This is when the borrower cannot repay the debt due to ethical reasons. The risk is also potential when the company operating a peer-to-peer lending platform uses the money invested for the wrong purpose, deliberately deceiving the investor, leading to the investor's ability to lose capital.

Eighth, there is no protection of the financial compensation program, like the deposit insurance of the Government.

Finally, among the 40 P2P lending companies in Vietnam, with some from China, Indonesia and Singapore, some of the companies with poor performance turned to black credit in need of processing and framework of regulatory diligence.

Risk Analysis of Black Credit (Usury) Limitations that need to be addressed with black credit are:

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Interest rate is too high > 100% / year

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Debt collection through property appropriation, intimidation, debtor mental persecution

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Capacity risk: credit appraisal, credit rating and assessment of borrowers are limited

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DISCUSSION AND FUTURE RESEARCH DIRECTIONS Thereby we see that shadow banking has the risks and disadvantages that need resources to handle them are: 

Unattended, the intangible banking system may be prone to risks leading to disruption when customers withdraw their assets;



Due to the chain operation, interest rates may rise in many stages, posing a risk to the financial system;

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Because of no supervision, the intangible banking system is prone to excessive competition regardless of risks and causes formal commercial banks to compete;

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The collapse of the invisible banking system can affect the mainstream banking system.

The disadvantages of black credit are: 

Loan shark (loan), which is not recognized by law



Capital raising interest rate > 50%, lending rate > 100%



Lending without a mortgage, without a project



Causing social insecurity, illegally arresting people, intentionally causing injury, appropriating property.

Positive Sides of Black Credit 

Help players have capital immediately, LS is not too high such as playing hui, pawn shop jewelry



Help to overcome the shortcomings of commercial banks in residential loans, friendly to small businesses and consumers. According to the World Bank, 70% of Vietnam's population has not accessed bank loans yet.

LESSONS FROM THE US, CHINA AND JAPAN Shadow Banking is Very Popular in the US and Thrived Right Before the 2008 Crisis. 

American economists all believe that the development of these underground banking organizations is one of the main causes of the 2008-2009 financial crises.



The danger of an underground bank is that the companies and agencies are not nominal banks, so they are not strictly regulated by lawmakers.



Therefore, these companies can lend dangerously (lending more than the amount of money and assets on hand; and when these loans become bad debts they will go bankrupt. ).

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Bankruptcy of these companies will cripple a part of the economy's production and consumption, causing a crisis.

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Shadow Banking in China After the global financial crisis of 2008-2009, HTNHN flourished in the Chinese market. The number of P2P lending platforms in China from 2010 to 2019 is shown in the following figure:

Figure 2 The market value is up to 9.5 trillion USD, the amount of assets accounts for 80% of the national GDP. Risks of China's shadow bank will focus on off-balance sheet activities: asset management products (WMPs) and Trust companies.

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Figure 3 HTNHN has been under control for the last 2 years, but with the economic slowdown, these activities are coming back with risks for investors.

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A major risk factor in the informal credit sector that has recently emerged in the country are "independent asset management companies", a group of financial companies that specialize in issuing Capital raising tool for wealthy investors with very high yields.



While non-bank credit has been purged almost entirely by the Chinese Government over the past few years, this sector did not suffer from too many strict conditions. As a result, companies have had a boom period and become the main capital channel for many businesses that are short of cash. It is estimated that there are 8,000 companies in this field, and the assets of some of the leading companies in the market have increased by 4 times in just the past 4 years.

However, fears were ignited in July when Noah Holdings, one of the leading companies in the field, announced

some assets worth 3.4 billion yuan (about 500 million USD) may have been compromised in a fraud scandal. The damage from such incidents could be even greater because it is not strictly managed. 

However, according to experts, because only focusing on wealthy customers, the influence of this independent asset management bubble (if any) may not be too great for the economy. In addition, Chinese officials have begun to pay more attention after the scandals and are expected to issue regulations governing the underground banking sector soon.



Finally, we see that in recent years P2P lending has been limited in China due to high risks, especially in the period of economic recession:

Figure 4 We can make comparisons between shadow banking in China and Europe, US: Table: 1 In China Internal financial system Mainly operated by bank system Less development of secondary market Low securitization ratio Low leverage ratio Transactions performed by individual investors Implied risks in initial development stage Unusual capital raising and lending activities

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In US, Europe Foreign and internal financial system Operated by credit institutions NOT banks Developed secondary mrket High securitization ratio High leverage ratio Performed by institutional investors Stable development stage Usual, less risky capital raising and lending activities

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Black Credit (Usury) in China In the initial phase, the P2P lending model was creative, effective and met the loan needs of the people, overcoming bank deficiencies.

But later turned into black credit and was stopped in China.

In Japan, loan shark or yamikinyu is legally included in the Civil Law and Money Lending Business Law.

Figure 5 In Vietnam: some black credit cases: • The line of usury loan via online applications "Vaytocdo", "Moreloan" and "VD online" has been destroyed. The police counted over 60,000 customers who borrowed over VND 100 billion. After 78 days, customers have to pay the principal, if not being fined up to 3% -4% / day. • For legalization, black credit sets LS <20% + multiple fees • Broken Cocobay Danang condotel project due to high profit commitment of 12% • Illustrative example of usury loan Cashwagon 17-19 Ton That Tung Q1.

CONCLUSION AND POLICY RECOMMENDATIONS Advantages of shadow banking: 

Immediately meet cash needs of borrowers when customers need them.



The loan procedure is quite simple, just need ID card or other relevant documents such as driver's license, student card.



Customer time can meet customer needs with only 30 minutes.



Providing credit capital to the economy when the traditional commercial banking system is not sufficient.



Ability to apply high technology and flexibility in management.

Disadvantages of shadow banking: 

Not really under the management and supervision of state agencies.



Risks to financial system stability.



Not diverse in financial products.

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Capital mobilization and lending activities are risky.

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Negative impact on underground banking system risks to financial stability.

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Loss of control over bad debts of the underground banking system leads to losses or bankruptcy.

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Transparency in the operation of underground banking system.

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Lack of a system to assess the ability to cope with shocks in financial markets.

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For P2P Lending: 

Vietnam has not licensed peer-to-peer lending services. Only a few companies that provide online loans are registered as financial consulting companies such as Finsom, Lenbiz, Tima, SHA, Mobivi, etc.



There have been thousands of customers making loans and borrowing transactions through Tima with outstanding loans worth trillions of dong, mainly operating in HCMC market. Meanwhile, Lendbiz operates in the Hanoi market in association with Tima platform to target small and medium-sized business loans, with a loan size of up to VND 1 billion without a mortgage.



Some businesses operating under the peer-to-peer lending model almost act as brokers, with the function of connecting lenders and borrowers. Therefore, it is really impossible to recognize these enterprises as credit institutions so that they are subject to the current Law on Credit Institutions.



Therefore, the author proposes: Recognize and authorize the operation of P2P service providers as an intermediary organization connecting lenders and borrowers on the basis of business registration under conditions prescribed by law.

In addition, propose solutions for black credit: 

Strengthening the policy of low interest loans for poor households through social policies, limiting black credit



Deploying cooperative models to borrow less or more effectively, reducing the demand for black credit. These cooperatives, for example in the field of agriculture, need to provide financial support to each other on the basis of an in-depth understanding of agricultural, cultivation and husbandry, and take advantage of the cooperative model. Commune in the former Soviet Union.



Issue warnings about organizations, websites, black credit apps to citizens



Providing a legal framework for supervision and adjustment of credit institutions with lending products to businesses and households through P2P loans, interest rates of 12-20%, obligations ...



Credit rating, credit rating for black credit borrowers, access guidelines, assessment of black credit loan customers limit credit risk

Lessons learned from China: 

Firstly, in order to minimize the negative impact of underground banking system on financial stability, it is necessary to strengthen control, risk management, and closely supervise the operations of private banking systems.



Second, enhance the information transparency in the operation of the underground banking system through the collection of complete information data on the size of total assets, the amount of credit supply to the economy

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Thirdly, developing a system of criteria to evaluate the resilience of shadow banking.



Fourthly, the State Bank needs to participate, monitor and monitor the HTNHN to have policies to adjust accordingly in each different period.

Besides, the author also proposed some additional solutions as follows: 

Shadow bank: need binding regulations, guidelines, transparency and sanctions for subjects participating in SI



P2P lending model: It is necessary to regulate the constraints of lending implementation on par with advanced technology and risk management for SMEs and households. Lending platforms such as Home credit, FE credit, etc. should be checked and assessed to better stipulate interest rates and credit risk management measures. Basis should be checked before lending, during and after lending.



With unsecured loans, borrowers do not need to mortgage assets, operate in the form of unsecured loans. With secured peer-to-peer lending (usually large loans), borrowers need to mortgage assets such as cars, airplanes, etc. like a traditional bank mortgage. P2P loans such as student loans, loans to buy phones, computers, small cash loans can be considered as consumer loans. P2p can also lend cars and real estate… with the form of collaterals or collaterals like banks lend to businesses. In addition, interest rates are set by the p2p company's rating system on the basis of analyzing credit account information, social networking information and many other sources of information depending on the culture of each country.

Basically, the credit rating system will be divided into corresponding types of customers of traditional banks. For

most P2P companies, investors' capital is not guaranteed. 

Black credit: it is necessary to increase the models of lending co-operatives to limit negative aspects of black credit, implement risk management, control lending interest rates within the appropriate threshold, evaluate and rate borrowers.



Consider whether or not P2P lending can be controlled and oriented in peer-to-peer lending and black credit to support consumer financing, SMEs and supply chain financing (e.g. planting cultivation of animal husbandry in supermarkets, restaurant markets, restaurants, frozen hotels, export logistics ...).



In terms of risk management, we need to consider the case of China with the number of P2P lending companies increasing rapidly to thousands of companies during the period of 2011 to 2015 (with some common applications like Ali pay, Wechat pay) have increased the size of the risk, that is, risk with big scale.



Next, we need to increase the quality of the evaluation of the information provided by the borrower: credit history, occupation, salary, marriage, household registration, etc.



For financial market, stock market: it is necessary to set up appropriate mechanism to create a secondary market for P2P lending activities to increase liquidity. Finally, this research paper also helps guide future research, for example, we can propose legalization of black credit and peer-to-peer lending. In the following content, we will propose some solutions to control and manage IT risks in P2P lending and black credit based on Fintech platform.

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PROPOSAL ON IT RISK MANAGEMENT AND OPERATIONAL RISK We see the level and risk of loss for P2P lending and technology-based credit (Fintech) through the following figure:

Figure 6 Because P2P lending is based on Fintech platform, which can cause the risk of large-scale loss once it happens, it is necessary to propose IT risk management solutions (information technology) as follows: 

Set up procedures, data backup program (data), data security to prevent risks of data loss or hackers entering data stealing systems, effective anti-virus software ...



Develop and implement the process of data security and IT risk reduction according to specific steps, thereby protecting the entire personal information of borrowers, friends, coalers and relationships of borrowers. avoid the hacking of hackers.

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While the banking system has Basel standards for managing operational risks, Fintech P2P lending platforms also need to have their own and similar concepts of operational risk management.



Applying network security laws to prevent IT risks.

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Prevent hackers to steal information and passwords from which to steal money in lenders and borrowers accounts, Fintech P2P should provide risk management solutions such as setting up security information v6 account. on two different information channels, increasing data protection and security firewalls

ACKNOWLEDGEMENTS I would like to take this opportunity to express my warm thanks to Board of Editors, Professors, my family, my colleagues in assisting convenient conditions for my research paper.

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EXHIBIT

Impact Factor (JCC): 8.8746

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Roles of Shadow Banking, P2P Lending and Solutions for Usury to Reduce Urban-Rural Discrepancies for Vietnam Social Economic Development in Integration ERA

3911

Exhibit 1: Inflation, CPI Over Past 10 Years (2007-2017) in Vietnam.

Exhibit 2: GDP Growth Rate Past 10 Years (2007-2018) in Vietnam.

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3898

Impact Factor (JCC): 8.8746

Dinh Tran Ngoc Huy, Do Hong Nhung, Nguyen Quynh Trang, Tran Duc Thang & Nguyen Duy Mau

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NAAS Rating: 3.11