Banking in Australia is dominated by four major banks: Commonwealth Bank of Australia, Westpac Banking Corporation, Australia and New Zealand Banking Group, and National Australia Bank. There are several smaller banks with a presence throughout the country, and a large number of other financial institutions, such as credit unions, building societies and mutual banks, which provide limited banking-type services and are described as authorised deposit-taking Institutions. Many large foreign banks have a presence, but few have a retail banking presence. The central bank is the Reserve Bank of Australia (RBA). Since 2008 the Australian government has guaranteed deposits up to $250,000 per customer per institution against banking failure.[1]

Banks require a bank licence under the Banking Act 1959. Foreign banks require a licence to operate through a branch in Australia, and Australian-incorporated foreign bank subsidiaries. Complying Religious Charitable Development Funds (RCDFs) are exempt from the licence requirement.[2]

Australia has a sophisticated, competitive and profitable financial sector and a strong regulatory system.[3] For the 10 years ended mid-2013, the Commonwealth Bank was ranked first in Bloomberg Riskless Return Ranking a risk-adjusted 18%. Westpac Bank was in fourth place with 11% and ANZ Bank was in seventh place with 8.7%.[4] The four major banks are among the world’s largest banks by market capitalisation and all rank in the top 25 globally for safest banks. They are also some of the most profitable in the world.[3] Australia’s financial services sector is the largest contributor to the national economy, contributing around $140 billion to GDP a year. It is a major driver of economic growth and employs 450,000 people.[3]

Financial institutions

Four pillars policy

Currently, banking in Australia is dominated by four major banks: Commonwealth Bank, Westpac, ANZ Bank, and the National Australia Bank.

In 1990, the government adopted a "four pillars policy" in relation to banking in Australia and announced that it would reject any mergers between these four banks.[5] This is long-standing policy rather than formal regulation, but it reflects the broad political unpopularity of further bank mergers. A number of leading commentators have argued that the "four pillars" policy is built upon economic fallacies and works against the Australia's better interests.[6]

The top four banking groups in Australia ranked by market capitalisation at share price 1 December 2017:

Rank Company Market capitalisation
Cash earnings
1 Commonwealth Bank of Australia (CBA) A$139.219 billion[7] A$9.14 billion[8]
2 Westpac Banking Corporation (Westpac) A$106.821 billion[7] A$7.82 billion[9]
3 Australia and New Zealand Banking Group (ANZ) A$83.599 billion[7] A$7.22 billion[10]
4 National Australia Bank (NAB) A$79.465 billion[7] A$5.84 billion[11]

Mutual banking in Australia

The Customer Owned Banking Association (formerly known as Abacus Australian Mutuals) is the industry body representing the more than 100 credit unions, building societies and mutual banks that constitute the Australian mutual or cooperative banking sector.[12]

Collectively, Australian customer-owned banks service 4.6 million customers or 'members' (as they are mutual shareholders in the institutions), with total assets of over A$85 billion.[13] The ten largest customer-owned banks in Australia are:[14]

Rank Institution Total assets
1 CUA A$9.0 billion
2 Heritage Bank A$8.5 billion
3 Newcastle Permanent A$7.5 billion
4 People's Choice Credit Union A$6.1 billion
5 IMB Bank A$4.9 billion
6 Greater Bank A$4.8 billion
7 Beyond Bank Australia A$4.12 billion
8 Teachers Mutual Bank A$4.08[15] billion
9 P&N Bank A$2.9 billion
10 Bank Australia A$2.8 billion

Heritage Bank is Australia's largest customer-owned bank, having changed its name from Heritage Building Society in December 2011. A number of credit unions and building societies changed their business names to include the word 'bank', to overcome adverse perceptions of smaller deposit-taking entities. For example, in September 2011 Bank Australia (formerly bankmecu) was announced as Australia's first customer-owned bank.[16]

Three teachers' credit unions have become known as 'banks'; namely, RACQ Bank (formerly the Queensland Teachers' Credit Union), Victoria Teachers Mutual Bank (formerly the Victoria Teachers' Credit Union), and Teachers Mutual Bank (formerly Teachers Credit Union Limited).[17] The Police & Nurses' Credit Union began trading as P&N Bank in March 2013, and some credit unions are electing to use 'mutual banking' as a business tagline, rather than as a business name, as they do not meet the criteria to be called a 'bank'.[18]

Other retail banks

There are other retail banks in Australia. These are smaller and often regional banks, including the Bendigo and Adelaide Bank, Suncorp-Metway, the Bank of Queensland and ME Bank. Other banks, such as Bankwest, St George Bank and Bank of Melbourne, are subsidiaries or alternate trading names of the big four banks.

Foreign banks

Foreign banks wishing to carry on a banking business in Australia must obtain a banking authority issued by APRA under the Banking Act, either to operate as a wholesale bank through an Australian branch or to conduct business through an Australian-incorporated subsidiary. Foreign banks engaging in retail banking require a full banking licence. Foreign banks which do not wish to obtain a banking authority in Australia may operate a representative office in Australia for liaison purposes, but the activities of that office will be restricted.

According to the Foreign Investment Review Board, foreign investment in the Australian banking sector needs to be consistent with the Banking Act, the Financial Sector (Shareholdings) Act 1998 and banking policy, including prudential requirements. Any proposed foreign takeover or acquisition of an Australian bank will be considered on a case-by-case basis and judged on its merits.

There are a number of foreign subsidiary banks, however only a few have a retail banking presence; HSBC Bank Australia (a subsidiary of HSBC), Delphi Bank (formerly the ‘Bank of Cyprus Australia’, and in 2012 acquired by Bendigo and Adelaide Bank), Bank of Sydney (with a full banking licence since 2001) and Citibank Australia (a subsidiary of Citigroup) have a small number of branches.

Foreign banks have a more significant presence in the Australian merchant banking sector.


Formally, there is extensive and detailed regulation of Australia's banking system, split mainly between the Australian Prudential Regulation Authority (APRA) and Australian Securities and Investments Commission (ASIC). The Reserve Bank of Australia also has an important involvement. However, in practice, banks in Australia are self-regulated through External Dispute Resolution (EDR) schemes, the most prominent of which is the Financial Ombudsman Service (Australia) (FOS).

APRA is responsible for the licensing and prudential supervision of Authorised Deposit-Taking Institutions (ADIs) (banks, building societies, credit unions, friendly societies and participants in certain credit card schemes and certain purchaser payment facilities), as well as life and general insurance companies and superannuation funds. APRA issues capital adequacy guidelines for banks which are consistent with the Basel II guidelines. All financial institutions regulated by APRA are required to report on a periodic basis to APRA. Certain financial intermediaries, such as investment banks (which do not otherwise operate as ADIs) are neither licensed nor regulated under the Banking Act and are not subject to the prudential supervision of APRA. They may be required to obtain licences under the Corporations Act 2001 or other Commonwealth or State legislation, depending on the nature of their business activities in Australia.

ASIC has responsibility for market integrity and consumer protection and the regulation of certain financial institutions (including investment banks and finance companies). However, ASIC does not actually investigate any issues or propose any regulations that concern consumer protection, this authority is delegated to the EDR schemes and the Australian Competition and Consumer Commission (ACCC). The front face of the regulation of financial institutions and financial advisers are the various EDR schemes, the most popular of which is the FOS. ASIC is responsible for the approval of EDR schemes, all of which must comply with ASIC Regulatory Guide 139.[19]

Banks are also subject to obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 as "reporting entities". They are required to identify and monitor customers using a risk-based approach, develop and maintain a compliance program, and report to Australian Transaction Reports and Analysis Centre (AUSTRAC) certain cash transactions as well as suspicious matters and file annual compliance reports.

There have been calls in recent times for an added level of regulation of banks following lending, foreign exchange, and financial planning controversies between 2009 and 2017, highlighted in 2016 Senate inquiries.[20][21] Referring to white collar crime, ASIC's Chairman Greg Medcraft said 'This is a bit of paradise, Australia, for white collar [crime]'.[22] In December 2017 the Australian Government established the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry to inquire into and report on misconduct in the banking, superannuation and financial services industry.[23][24]

Interbank lending market

During the course of every day, each bank executes a large number of transactions, such as payroll, retail and business purchases, credit card payments, etc. Some involve cash (or its equivalent) coming into the bank and others of cash going out. Banks do not have a reliable way of predicting what or how much those transactions will be. At the end of each day banks must reconcile their positions. The bank that finds itself with a surplus of cash would miss out earning interest on the cash, even if it’s for only one night. Other banks may find that they had more money going out than coming in, and the bank must borrow cash to cover the shortfall. To meet its liquidity obligations, the bank with the shortfall would borrow from a bank with a surplus in the interbank lending market. Depending on the bank's assessment of the type of shortfall and costs, the bank may take out an overnight loan, the interest rate of which is based on the cash rate, which is set by the Reserve Bank (RBA) every month (currently 2%); or else take out a "short duration loan", known as "prime bank paper", for a term of between one and six months and whose interest rate is called the "bank bill swap rate" (BBSW), which is set by the commercial banks.

A body called the Australian Financial Markets Association (AFMA) determines the BBSW rate. Until 2013, AFMA would every morning at 10am ask each of the ‘prime banks’ what interest rates they will be offering or asking for that day. AFMA would then calculate the BBSW rate as the average of those quotes. Normally, the longer the term, the higher the offered rate. The system required some level of subjective judgement by the banks, because they would not know at that time of day what their end-of-day position would be. In addition, the system was open to abuse if banks lied to the AFMA, opening the BBSW rate to manipulation to some bank's advantage.[25] To avoid a repeat of alleged manipulations, AFMA changed the method of calculating the BBSW rate to the use of actual market transactions, which, however, is still open to possible manipulation. Besides effecting the BBSW rate, many other financial rates are based on it.[26] The Australian Securities and Investments Commission (ASIC) monitors the BBSW system and prosecutes those that manipulate the system.[26]

There arises from time to time a situation when there are insufficient funds in the interbank lending market to enable the banks to balance their books. Some banks, for example, may be experiencing a bank run or may be withholding funds from the market expecting a heightened demand in the near future. The Reserve Bank's role includes ensuring liquidity in the banking system, including acting as lender of last resort in times of a liquidity crisis.[27]

International cooperation

The United States has enacted the Foreign Account Tax Compliance Act. (FATCA) which came into effect on 1 July 2014, which aims to prevent tax evasion by US tax residents who hold foreign accounts by requiring foreign financial institutions to report details and interest income to the US Internal Revenue Service (IRS). Australia has signed an Intergovernmental Agreement (IGA) with the United States which sets out rules to enable Australian financial institutions to report to the Australian Taxation Office (ATO) which in turn passes the information to the IRS. FATCA affects US citizens, US tax residents and certain types of organisations that are controlled by them. To comply with FATCA, Australian banks ask customers to declare their US tax status.[28]


Early history

Between white settlement in Sydney in 1788 and 1817, there were no banks nor much currency in the colony. The first bank in Australia was the Bank of New South Wales, established in Sydney in 1817.[29] During the 19th and early 20th century, the Bank of New South Wales opened branches throughout Australia and Oceania: at Moreton Bay (Brisbane) (in 1850), then in Victoria (1851), New Zealand (1861), South Australia (1877), Western Australia (1883), Fiji (1901), Papua (now part of Papua New Guinea) (1910) and Tasmania (1910). It was by far the most dominant bank throughout Australia until into the 1960s. The Commercial Banking Company of Sydney was established in 1834, and the National Bank of Australasia establish in 1858, and set up branches in other Australian colonies: Tasmania (in 1859), Western Australia (1866), New South Wales (1885) and Queensland (1920), and a London branch (1864). After acquiring a number of other banks over the years, these two banks merged in 1982 to form the National Commercial Banking Corporation of Australia, which was renamed the National Australia Bank.

In 1835 a London-based bank called the Bank of Australasia was formed[30] that would eventually become the ANZ Bank. In 1951, it merged with the Union Bank of Australia, another London-based bank, which had been formed in 1837. In 1970, it merged with the English, Scottish and Australian Bank Limited, another London-based bank, formed in 1852, in what was then the largest merger in Australian banking history, to form the Australia and New Zealand Banking Group Limited.

A speculative boom in the Australian property market in the 1880s led to the Australian banking crisis of 1893. This was in an environment where little government control or regulation of banks had been established and led to the failure of 11 commercial banks, even the National Bank of Australasia.

Until 1910, banks could issue private bank notes, except in Queensland which issued treasury notes (1866–1869) and banknotes (1893–1910)[31] which were legal tender in Queensland. Private bank notes were not legal tender except for a brief period in 1893 in New South Wales.[31] There were, however, some restrictions on their issue or other provisions for the protection of the public. Queensland treasury notes were legal tender in that state.

After federation

Private bank notes and treasury notes continued in circulation until 1910, when the federal Parliament passed the Australian Notes Act 1910 which prohibited the circulation of state notes as money and the Bank Notes Tax Act 1910 imposed a prohibitive tax of 10% per annum on 'all bank notes issued or re-issued by any bank in the Commonwealth ... and not redeemed'. These Acts put an end to the issue of notes by the trading banks and the Queensland Treasury. Also in 1910, the Australian pound was first issued as the legal tender in Australia. Now, the Reserve Bank Act 1959 expressly prohibits persons from issuing bills or notes payable to bearer on demand and intended for circulation.[32]

The federal government established the Commonwealth Bank in 1911, which by 1913 had branches in all six states. In 1912, it took over the State Savings Bank of Tasmania (est. 1902)[33] and did the same in 1920 with the Queensland Government Savings Bank (est. 1861). As with many other countries, the Great Depression of the 1930s brought a string of bank failures. In 1931, Commonwealth Bank took over two faltering state savings banks: the Government Savings Bank of New South Wales (est. 1871) and the State Savings Bank of Western Australia (est. 1863). In 1991, it also took over the failing State Bank of Victoria (est. 1842).

As a response to the Great Depression, banking in Australia became tightly regulated. Until the 1980s, it was virtually impossible for a foreign bank to establish branches in Australia; with the consequence that Australia had fewer banks compared to countries such as the United States and Hong Kong. Moreover, banks in Australia were classified as either savings banks or trading banks. Savings banks paid virtually no interest to their depositors and their lending activities were restricted to providing mortgages. Many of these savings banks were owned by state governments. Trading banks were essentially merchant banks, which did not provide services to the general public. Because of these and numerous other regulatory restrictions, other forms of non-bank financial institutions flourished in Australia, such as building societies and credit unions. These were regulated by state laws and were subject to less stringent regulations, could provide and charge higher interest rates, but were restricted in the range of services they could offer. Above all, they were not allowed to call themselves "banks".

1969 ABC news report on the introduction of ATMs in Sydney. People could only receive $25 at a time and the bank card was sent back to the user at a later date.

From 1920, the Commonwealth Bank performed some central bank functions, which were greatly expanded during World War II. This arrangement caused some discomfort for the other banks, and as a result the Reserve Bank of Australia was created on 14 January 1960 and assumed the central bank functions previously performed by the Commonwealth Bank, including managing the currency, the money supply and exchange control.

Adoption of new technology

Banks have adopted new technologies in order to reduce operating costs. The rollout of automated teller machines (ATMs) commenced in 1969. There are currently a number of ATM networks operating in Australia, the largest five of which are: the Commonwealth Bank-Bankwest network (with over 4,000 machines), NAB-rediATM network (with over 3,400 machines), Westpac-St.George-BankSA and Bank of Melbourne network (with over 3,000 machines), ANZ (with over 2,600 machines) and Suncorp (with over 2,000 machines), and others.[34] Financial institutions are linked via interbank networks.

The use of the Bank State Branch (BSB) identifier was introduced in the early 1970s with the introduction of MICR on cheques to mechanise the process of data capture by the banks as well as for mechanical sorting and bundling of physical cheques for forwarding to the payer bank branch for final cheque clearance. Since then, BSBs have been used in electronic transactions (but is not used in financial card numbering).

EFTPOS technology was introduced in 1984. Initially, only the banks' existing debit and credit cards could be used, but in 1985, the ATM (Financial) Network was created to link EFTPOS systems to provide access for all customers. Cards issued by all banks could then be used at all EFTPOS terminals nationally, but debit cards issued in other countries could not. Prior to 1986, the Australian banks organized a widespread uniform credit card, called Bankcard, which had been in existence since 1974. There was a dispute between the banks whether Bankcard (or credit cards in general) should be permitted into the proposed EFTPOS system. At that time several banks were actively promoting MasterCard and Visa credit cards. Store cards and proprietary cards, such as fuel cards and Bartercard, were shut out of the new system, though they use compatible technology.

The widespread acceptance of credit cards and the development of SSL encrypted technology in mid 1990s opened the way to E-commerce. Telephone banking was introduced in the 1990s, with internet banking being introduced after 2001 and mobile banking after 2010s. Bain, Research Now and Bain[35] along with GMI NPS surveys in 2012 found that 27% of Australians have had mobile banking transactions in the previous three months.[36] These innovations have resulted in significant shifts in banking in Australia away from the use of bank branches, and resulting in branch closures and staff cuts.[37][38]

Deregulation and concentration

The banking industry was slowly deregulated. In the mid-1960s, the distinction between and separation of trading and savings banks was removed and all banks were allowed to operate in the money market (traditionally the domain of merchant banks), and banks were allowed to set their own interest rates. Building societies were allowed to take deposits from the public. Foreign exchange controls were abolished and the Australian dollar was permitted to float from December 1983.

Banking in Australia is notable by the small number of large banks in the market. Much of this concentration is the result of bank acquisitions. English, Scottish and Australian Bank was acquired by the ANZ Bank in 1970. In 1982, Bank of New South Wales merged with the Commercial Bank of Australia to form Westpac. There were many other bank mergers and acquisitions throughout Australia's banking history. The boom and bust of the 1980s was a turbulent period for banks, with some establishing leading market positions, while others being absorbed by the larger banks. Beginning in the 1980s, several building societies sought to convert to banks, but were required to demutualise before they were permitted to do so. This included NSW Building Society, which became Advance Bank, St.George, Suncorp, Metway Bank, Challenge Bank, Bank of Melbourne and Bendigo Bank. A change in regulations allowed building societies and credit unions to become banks without having to demutualise, and several including Heritage Bank have converted since 2011 while retaining their status and structure as mutual organisations.

In 1990, the government adopted the "four pillars policy" in relation to banking in Australia and announced that it would reject any mergers between the four big banks.[5] The four pillars policy, however, has not prevented the four major banks from acquiring smaller competitors. In 2000, CBA acquired the Colonial group, which had emerged as a major bank–insurance combine in the 1990s, after the Colonial Mutual insurance group took over State Bank of NSW in 1994. The Commonwealth Bank also acquired the State Bank of Victoria in 1990 and BankWest in 2008. Westpac acquired the Challenge Bank in 1995, Bank of Melbourne in 1997, and St.George Bank in 2008.[39]

The Australian government's direct ownership of banks ceased with the full privatisation of the Commonwealth Bank between 1991 and 1996. There was also increased competition from non-bank lenders, such as providers of securitised home loans. A category of authorised deposit-taking institution (ADI) was created for a corporation which is authorised under the Banking Act 1959 to take deposits from customers. The change formalised the right of non-bank financial institutions — such as building societies and credit unions — to accept deposits from non-members.

Following the Wallis Committee Report, the Australian Prudential Regulation Authority (APRA) was established on 1 July 1998 to take over from the RBA the oversight of ADI's and other financial institutions in Australia, eg., banks, credit unions, building societies, friendly societies, general insurance and reinsurance companies, life insurance and most members of the superannuation industry. The Payments System Board (PSB) was also created, to maintain the safety and performance of the payments system.

At the time, consumer credit in Australia was primarily loaned in the form of installment sales credit. The arrival of hundreds of thousands of readily employable migrant workers under the post-war immigration scheme, coupled with intense competition amongst lenders, discouraged proper investigation into buyers.[40] Concerns about the possibly inflationary impact of lending created the first finance companies in Australia.[40]

See also


  1. ^ Australian Government Deposit Guarantee Design & Operational Parameters, Department of the Treasury accessed 18 June 2010
  2. ^ Exemption Order No. 1 of 2017
  3. ^ a b c Australian Treasury, The strength of Australia’s financial sector
  4. ^ "Imbal hasil bank asal Australia Jawara". 12 June 2013. 
  6. ^ Marks, Bob; Young, Owen (22 August 2005). "Four pillars debate needs refining: AFR Economic Briefing". Archived from the original on 5 February 2008. Retrieved 24 January 2008. 
  7. ^ a b c d "ASX 200 List of Companies – Directory". www.asx200list.com. Retrieved 2016-02-10. 
  8. ^ "fy15-media-release-asx" (PDF). www.commbank.com.au. Retrieved 2016-02-14. 
  9. ^ "Westpac_FY15_financial_results" (PDF). www.westpac.com.au. Retrieved 2016-02-14. 
  10. ^ "fy15_results_investor_discussion_pack_-_final_asx_lodgement" (PDF). www.shareholder.anz.com.au. Retrieved 2016-02-14. 
  11. ^ "2015%20asx%20announcement" (PDF). www.nab.com.au. Retrieved 2016-02-14. 
  12. ^ "Australian Mutuals". Abacus. Retrieved 2012-06-06. 
  13. ^ "Fact Sheets". Abacus. 2012-02-01. Retrieved 2012-06-06. 
  14. ^ "Building Societies and Credit Unions: 2011" (PDF). 2011-11-22. Retrieved 2013-12-28. 
  15. ^ "www.tmbank.com.au". Retrieved 2013-12-28. 
  16. ^ "Australia's First Customer Owned Bank bankmecu - responsible banking". bankmecu. Retrieved 2012-06-06. 
  17. ^ "Teachers Credit Union to re-brand". Banking Day. 12 October 2011. Retrieved 5 April 2012. 
  18. ^ "Home - Select Credit Union". Selectcu.com.au. Retrieved 2012-06-06. 
  19. ^ Australian Government;. "RG 139 Approval and oversight of external complaints resolution schemes". Australian Securities and Investments Commission . Retrieved 17 January 2016. 
  20. ^ "Scrutiny of Financial Advice". Australian Parliament House. Canberra: Australian Government. Retrieved 17 January 2016. 
  21. ^ "The impairment of customer loans". Australian Parliament House. Canberra: Australian Government. Retrieved 17 January 2016. 
  22. ^ "Trouble in paradise: Greg Medcraft's white collar crime comments get people hot under the collar". The Sydney Morning Herald. Retrieved 17 January 2016. 
  23. ^ Turnbull, Malcolm (1 December 2017). "Appointment of Royal Commissioner". Prime Minister of Australia (Press release). Canberra. Retrieved 1 December 2017. 
  24. ^ Gribbin, Caitlyn (1 December 2017). "Banking royal commission: Government appoints former Judge Kenneth Hayne to lead inquiry". ABC News. Australia. Retrieved 1 December 2017. 
  25. ^ "ASIC sues Commonwealth Bank for interest rate fixing on eve of royal commission". The Newdaily. 31 January 2018. Retrieved 31 January 2018. 
  26. ^ a b "Why you should care about the bank bill swap rate". The Newdaily. 12 April 2016. Retrieved 31 January 2018. 
  27. ^ Liquidity and the Lender of Last Resort, speech by Glenn Stevens, Governor of Reserve Bank of Australia, 15 April 2008.
  28. ^ "Australia-US Intergovernmental Agreement (IGA) to improve international tax compliance and to implement FATCA (the US Foreign Account Tax Compliance Act)". Australia Department of the Treasury. 
  29. ^ M. J. B. Kenny. "Biography - Edward Smith Hall - Australian Dictionary of Biography". Adb.online.anu.edu.au. Retrieved 2012-06-06. 
  30. ^ "Bank of Australasia (incorporated by Royal Charter, 1835), London Office, no. 8, Austin Friars : paid up capital £900,000, Directors ... - Version details - Trove". trove.nla.gov.au. Retrieved 2016-02-10. 
  31. ^ a b Pitt 2013, p. 180.
  32. ^ "The Australian note issue". Commonwealth of Australia. Retrieved 14 November 2014. 
  33. ^ Amalgamations
  34. ^ Which bank has the biggest ATM network in Australia?
  35. ^ "Customer Loyalty in Retail Banking Global Edition 2012" (PDF). Bain.com. Bain. Retrieved 24 July 2015. 
  36. ^ See List of countries by mobile banking usage
  37. ^ Parliament of Australia, 2002-04, Chapter 2 - Bank branch closures in rural, regional and remote Australia
  38. ^ Weekly Times Now, 8 November 2017, Bank branch closures across rural Australia put towns on brink
  39. ^ Westpac-St George merger won't topple four-pillars, The Age, 15 May 2008
  40. ^ a b Myers, Margaret G. (September 1961). "The Control of Consumer Credit in Australia". The Journal of Finance. 16 (3): 409–422. doi:10.2307/2977336. JSTOR 2977336. 

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