A Financial Consumer Organization for Canada
Balancing the Financial Services Marketplace

CCRC Position Paper #4

(December 1997)

"If I could fix one thing, it would be to see that we have a more vital consumer advocacy function generated by real participation."

Hon. John Manley, Federal Minister of Industry
Canadian Press story (December 13, 1994)

I. Background on Canada's Financial Institutions

(a) What Depositors Do For Canada's Banks

Canada's big five banks are the largest corporations in Canada (based on total value of their assets, in order of size: the Royal Bank, CIBC, Bank of Montreal, Scotiabank, Toronto Dominion). These assets include loans which borrowers have to pay back to the bank, government bonds, shares in other companies, buildings, property etc.

However, the basis of all these assets is the money over 20 million Canadians deposit in the banks. According to the Canadian Bankers Association, the deposit accounts of individual Canadians make up the largest single bank deposit category, both in number and total amount. When individual deposits are combined with the deposit accounts of businesses, they total $676 billion and make up 93% of the total capital base of the big five banks at the end of April 1997. In contrast, shareholders investments in banks total only $46 billion.


(b) What Canada's Governments Have Done for Banks: Decades of Privileges and Protection

Canada has one of the most highly concentrated banking sectors in the world. We have half as many banks as Japan, one-fifth the number of banks as Germany, one-seventh the number of banks as France, one-eighth the number of banks as Britain, and the United States has 200 times as many banks as Canada.

Our banking sector is so concentrated because our banks have, since 1967, enjoyed legal protection from competition by foreign banks, and very high costs are an effective barrier to anyone trying to start a new bank.
As a result of protection from foreign competition, and that the federal government has allowed them to operate in almost every area of the financial services industry, the big five Canadian banks control many areas of the financial services industry, as follows:

Taxpayer dollars totalling $4.5 billion facilitated bank takeovers of several failing trust companies in the past several years (especially 1991-92), so that banks now own over 15 trust and loan companies (the only large independent trust company left is Canada Trust). Between 1984 and 1993, the total assets of trust and loan companies associated with the banks increased from $36 billion to $150 billion. In addition, even though the federal government allowed banks unrestricted access to the mutual fund industry only nine years ago, the list of the 10 largest mutual fund companies in Canada already includes five banks and these banks control 30% of the total industry assets.


(c) Record Bank Profits: A Result of Privileges and Protections

These privileges and protections have helped Canada's big five banks reach record profit levels in the past three years. In 1995, the big five banks were amongst the seven corporations with the highest profits in Canada, their profits have almost doubled since 1993, and in 1996 the Royal Bank recorded the highest profit ever by a Canadian company ($1.43 billion). In 1997, the big six banks are again reporting record profits, and they will likely exceed $7 billion in total profits, an increase of over 10% over 1996.

Banks would have reached their record profit levels years ago if they had not over-exposed themselves to speculative real estate investments in the late 1980s. In 1992 the big five banks total loan losses were almost $7 billion, close to $4 billion more than in 1991. This huge increase in losses occurred mainly because they lost about $2 billion on loans to Olympia & York, a huge real estate company that went bankrupt in 1992. As a result of these losses, bank profits decreased from $3.8 billion in 1991 to $1.5 billion in 1992.

As mentioned above, several trust companies were also over-exposed to risky real estate investments in the early 1990s, which lead to several failures that cost taxpayers billions in bailouts. In one case, taxpayers (through the Canadian Deposit Insurance Corporation (CDIC)) underwrote the takeover of Central Guaranty Trust by Toronto-Dominion Bank at a cost of $1 billion. In another, the losses of Confederation Trust were a main cause of the collapse of the 123-year old Confederation Life Group of Companies.


(d) Privileges and Protections Mean Greater Responsibility

Bankers like to characterize Canada's big banks as private corporations which should give priority regard to shareholders interests, with their employees and customers coming second and third.

However, given that the banks would not be as large or as profitable as they are without individual Canadian's deposits and the privileges and protections granted them by Canadian governments, banks are much more like public utilities.

Public utilities such as hydro-electricity, water, telephone, and cable-TV are granted the significant privilege of usually almost exclusive rights to generating and exploiting a natural resource. Similarly, banks have been given the significant privilege of playing the major role in generating and exploiting an human-created resource, namely money. Both utilities and banks are in a position of public trust with regard to the resources they manage.


(e) Problems for Consumers: Not Solved by Governments or Financial Institutions

The results of surveys of over 8,000 Canadians concerning customer satisfaction with various Canadian industry sectors conducted in 1996 and 1997 by the National Quality Institute placed banks in the bottom five of 21 industries along with regulated monopolies such as cable-TV companies and Canada Post. In contrast, respondents ranked credit unions as the third best industry sector for customer satisfaction, and trust companies ranked ninth. The survey measured courtesy, promptness of service, product information, after-sales service and complaint-handling service.

In addition, a study released in June 1996 by ACEF-Centre of Montreal concluded that 3% of Canadian adults do not have an account with a financial institution. Other surveys have shown that low-income Canadians are even less likely to have an account. A Environics poll, conducted in 1995, found that eight percent (8%) of consumers with an annual income of less than $25,000 (which according to 1994 Statistics Canada data would mean at least 400,000 Canadians) do not have an account (See the CCRC's Position Paper #2, Access To Basic Banking Service: Ensuring A Right to This Essential Service for details).

The discussion paper on the 1997 Review of Financial Sector Legislation (released in June 1996) recognized the need for regulation of the financial services sector to solve consumer problems: "There is no question that regulations are required in the financial sector. Regulations not only protect the consumer, they set out the rules of the game so that the sector can operate smoothly." (p. 19) The June 1997 Discussion Paper of the Task Force on the Future of the Canadian Financial Services Sector also states that the financial services sector has traditionally been a segment of the economy where regulation is accepted and expected. (p. 6)

However, based upon an examination of Canadian governments actions to date on financial institution regulation, in particular the federal government's actions, the CCRC concludes that Canadian governments have failed to enact effective measures to address key issues of concern to financial consumers.

For example, during the consultation period on changes to the Bank Act and other financial institutions legislation between April 1995 and July 1996, Doug Peters, then Secretary of State for International Financial Institutions and responsible for the changes, held 45 meetings, all with industry representatives, and gave nine speeches, all to industry associations. During this consultation period, Mr. Peters did not meet with any consumer groups.

The federal government's February 1997 proposed changes to the Bank Act and other laws reflected the bias in Mr. Peters' consultation process. Despite the fact that the government's own research has shown that voluntary self-enforcement rarely works as well as regulation for solving consumer problems, the government did not require financial institutions to do very much at all to protect consumers, as follows:

In the area of home, car and business insurance, a survey of over 1600 adult Canadians conducted by Insight Canada Research in August and September 1996 on behalf of the Insurance Bureau of Canada found that (among other things), despite efforts by the industry to inform consumers on key issues:



Background on Citizen and Business Groups

(a) Creating and Funding Citizen Groups: Some Systemic Barriers

The lack of responsiveness by Canadian governments and financial institutions to consumer problems highlight the lack of resources citizens have for advocating their interests and ensuring that governments and the financial services industry address their issues of concern.

Canadian governments have helped create and fund a variety of non-profit citizen groups for decades. However, while this funding has facilitated the development of citizen groups in many sectors, dependency on government funding has also created problems by limiting the resources and public participation in many of these groups.

First, government funding has often been adequate for many groups to pursue limited activities in their area of interest, but not enough to provide services to a significant percentage of citizens, or not enough to provide certain services at all. For example, many groups receive funding to conduct research into a problem, but few receive funding to solve the problem or provide services to alleviate the problem.

Second, dependency on government funding has at times compromised the independence of the activities and viewpoints of some groups. Often, governments want research conducted into a problem the government views as a priority, while groups have other priorities they would like funded. At other times, government will provide funding to groups that support its policy goals, while denying funding to groups which oppose those goals. While this is the prerogative of the government, it denies taxpayer support of groups that may be supported by significant numbers of taxpayers. In addition, some groups tailor their research findings and strategies for public education and advocacy in order not to jeopardize their chances of continuing to receive funding. Whether or not a group compromises in this way, if a group receives funding for specific activities from government, the government then knows the group's strategies and activities for the funding period.

Third, government funding has allowed many groups to remain disconnected from the public, as the groups do not have to reach out to the public for funding in their work in order to be financially viable. Some groups, although they have received annual government funding for over a decade, have never had the resources to maintain broad public participation in their organization. Also, government funding is rarely adequate to support the maintenance of a broad-based, democratic structure for non-profit groups, and so many groups are not democratically-structured.

With governments cutting back on funding many non-profit groups, the problems of lack of resources to adequately serve and represent citizens, and lack of public participation in many groups are becoming even more acute.

For many existing non-profits, new sources and methods of funding are a top priority. Many groups are seeking funding through direct mail and door-to-door canvassing. However, these fundraising methods require funds to start up, and many organizations have found that the costs of direct mail are not covered by the donations received. Governments only rarely provide funding to citizen groups for start-up of direct appeal fundraising or to help cover the costs of such fundraising.

As a result, few citizen groups are able to build a broad base of individual donors that will sustain them, especially not advocacy groups who often do not have access to charitable donations. And even if they do build a broad base of supporters, the costs of fundraising often mean that the group is just barely sustained (for example, it often costs $3 to raise $5, which means that a large group can have annual revenues of $1 million but $600,000 will go to fundraising.

Some non-profit groups are trying to replace government funding with funding from corporations, but are finding that they are still lacking resources, still constrained in their activities, and still disconnected from the public. Funding from corporations for consumer advocacy groups is particularly problematic because the groups are supposed to be watching over corporations on behalf of consumers.


(b) Business Group Funding: Guaranteed and Substantial

In contrast to citizen groups, corporations have little trouble raising funds for their activities such as lobbying. Why not? Because corporations can easily shift revenues they raise from the sale of goods and services to whatever purpose they desire. Ironically, they can also easily pass on the costs of advertising, lobbying and other types of advocacy to their customers. For example, if the banking industry needs a $1 million for a lobbying campaign, the banks could simply add 5 cents to a service transaction charge, and if their 20 million customers each completed the transaction once, the industry would have the $1 million in hand.

The ease with which corporations can raise and spend funds to advocate their interests means that they have an enormous advantage in terms of influencing public opinion and governments. For example, the big 5 banks in Canada (Royal Bank, CIBC, Bank of Montreal, Scotiabank, Toronto Dominion) devote the following resources to influencing the public and governments, through their own offices and the Canadian Bankers Association (CBA):

In contrast, citizen groups working on financial services issues have far fewer resources, as the Office of Consumer Affairs of Industry Canada only provides grants of at most $250,000 each year for work on these issues, and very little funding is provided by any provincial or territorial governments for this work. There are no citizen groups working on financial services issues that have an extensive, national membership base, or resources adequate to help financial consumers with complaints or provide services across the country.



The U.S. Citizen Utility Board (CUB) Model: Helping Citizens Band Together to Form Citizen Groups

The U.S. Citizen Utility Board (CUB) method of forming and funding non-profit citizen groups provides a viable alternative that solves the problems set out above without creating new, more significant problems. All available information suggests that the CUB method has proven to be a low-cost, effective means of facilitating citizens banding together their financial resources, energy and social capital to set up organizations that serve their needs and interests.

A CUB is an independent, democratically structured, non-profit and non-partisan organization of residential utility ratepayers that educates, provides services and advocates on behalf of ratepayers. CUBs exist in four U.S. states; three are statewide and one is municipally based.

The CUB method of forming and funding citizen groups is to enclose a flyer in utility companies' billing envelopes. The key to CUBs is the right, by law, to enclose a flyer in companies' billing envelopes. Some action by the government is usually needed to allow the CUB access to the companies' billing envelopes, and to provide funding (a grant or loan) to print the first flyer. The flyer informs ratepayers about the CUB and invites them to join for a nominal annual membership fee (usually $10-15).

"Piggybacking" the CUB flyer with the utility bills has proven to be an effective way to reach all ratepayers at little or no cost to government or utilities. About four percent of ratepayers usually join a CUB. For example, the first flyer for Illinois CUB was sent out in 1983 and within six months the group had 170,000 members and an annual budget of $1.7 million. Since then, it has saved ratepayers over $4 billion by successfully opposing proposed utility rate-hikes.

While membership levels in the CUBs have fluctuated over the years, the CUBs have always remained self-sustaining. Illinois CUB has a board of directors elected by CUB members across the state, while other U.S. CUBs have used other methods for electing their boards and involving their members in setting the mandate for the CUB.

A key facet of CUBs is their role within the whole relationship between citizens, businesses and governments. In a way, the CUB name is not that descriptive, because they are not really "boards" in the way we think of regulatory agencies having boards. The CUBs do not decide or set utility rates, they represent consumers before utility regulatory boards or agencies which are setting rates. CUBs are also not ombudsman offices, or dispute mediators. Instead, they represent consumers who are complaining to an ombudsman, or who are involved in dispute mediation with a utility.

In other words, CUBs are still needed even if you have a utility board, ombudsman or other mediator that makes decisions on issues and situations involving consumers and business (even if the decision-maker is required to make decisions in the public interest). Why? Because the decision-maker needs to hear from both sides, and corporations have lots of resources for stating their case. CUBs give consumers access to similar resources for defending their interests before decision-makers.

Also, no matter what market theory they subscribe to, everyone agrees that government can only protect consumers to a certain degree, and that consumers must be organized and informed to protect themselves. Everyone also agrees that organized and informed consumers aid regulators in their enforcement efforts. And everyone agrees organized and informed consumers enhance the operation of the marketplace and the industry, increasing competition and standards of customer service.

In Canada, using flyers sent out in envelopes to inform, fundraise and advocate for specific causes is not a new concept, even though no CUBs exist here yet. Many water utilities enclose a information/fundraising flyer periodically from a group called WaterCAN, which works on water projects in developing countries. Alberta auto insurance customers are offered in their premium statement envelopes an opportunity to add a nominal sum to their premium which is transferred to Alberta police departments to fund specific programs to combat auto theft.

Financial institutions often promote their own products or products of their subsidiaries through their mailings. In addition, financial institutions promote their interests or other causes through flyers enclosed in envelopes mailed to their customers.

For example, a flyer produced by the Canadian Association of Mutual Insurance Companies which advocates their position on the issue of whether banks should be allowed to sell insurance through their branches was sent out in premium statement envelopes mailed to many customers of mutual insurance companies. A flyer produced by the federal government promoting census day was enclosed in many financial institution credit card billing envelopes sent to customers in April 1996. Also in 1996, a flyer promoting the Canadian Olympic Association and a contest was enclosed in Royal Bank mailings to its credit card customers. Finally, the Royal Bank has also enclosed, in mailings its credit card customers, a flyer promoting an exhibit the bank sponsored at the Metro Toronto Zoo.

All of these examples illustrate that this method has been tested, is workable, and feasible. There is no reason for the federal government to reject the proposal to use this method to facilitate the banding together of financial consumers, as worthy a cause as any of the examples set out above.



A Financial Consumer Organization for Canada: Balancing the Marketplace Using the U.S. CUB Model

The creation of a Financial Consumer Organization (FCO) in Canada using the U.S. CUB method will help solve many of the problems set out above that prevent citizens from banding together into a group that will increase their capacity to educate themselves and advocate their interests on financial services issues. As a result, the creation of an FCO will also balance the financial services marketplace by levelling the playing field somewhat in terms of the resources available to financial consumers to advocate their interests as compared to the resources available currently to financial institutions.

Also, an FCO can be created in Canada using the U.S. CUB method for little or no cost to government and no cost for financial institutions.

A Financial Consumer Organization (FCO) in Canada could help consumers in many areas. Overall, the existence of an FCO would encourage more responsible decisions and activities by financial institutions because the institutions would be very aware that a broad-based, well-resourced, consumer-oriented organization would be watching them very closely.

Canadian financial consumers are currently completely on their own when they try to compare the over 500 services and products offered by financial institutions. There is no organization that compares products and services, no consumer magazine that conducts regular comparisons; in short there is no independent, consumer-oriented place where consumers can call if they are trying to figure out what service or product is the "best buy."

Some may argue that consumers can always hire a financial planner or broker to help them with purchasing decisions. This is an unsatisfactory answer for several reasons:

As Canada's chartered banks control more and morre of the financial services industry, and will possibly be granted permission to move into the area of selling insurance post-1997, it becomes even more important that all consumers have an easy and inexpensive means of comparing financial services and products and learning all the details about who exactly is selling them the service or product, and what ties they have to other financial institutions.

An FCO is the best way to ensure that all consumers have access to this information. An FCo would also fulfill the following functions:

For several reasons, an FCO is also a necessary complement to the current bank ombudsman system, especially because the current system has significant flaws. First, an FCO would be independent of government and the banks, mandated to represent consumers in disputes, and directed by consumers. An FCO is needed to help consumers make their case before any bank ombudsman. Second, the current ombudsman do not handle complaints by customers of other financial institutions, whereas an FCO could help these consumers. Third, an FCO would represent consumers before the government, government agencies and the courts. The bank ombudsman do not fulfill this role. Fourth, an FCO could provide educational services to consumers; bank ombudsman do not fulfill this role. And finally, consumers will be notified of the existence of the FCO periodically when they open their bank statement, credit card bill or insurance premium statement envelopes. In contrast, it has been shown that few bank customers know of the existence of the bank ombudsmen.

The federal government has shown that it has no problem with the banks having their own ombudsman that they select, fund and direct. If it is consistent, the federal government should have no problem with financial consumers having their own Financial Consumer Organization which consumers fund and direct.



Creating A Financial Consumer Organization for Canada: The Key Steps

Federal Industry Minister John Manley, who is also responsible for consumer issues, stated in mid-December 1994 (as quoted at the beginning of this Position Paper) that he wants to build consumer advocacy in Canada based on participation by consumers. He also stated publicly in April 1996 that he supports the idea of a financial consumer organization and will assist in the formation of a financial consumer organization if citizen groups are gathered together to push for the creation of the group. His commitment is to push the banks to enclose the flyer in their mailings if they refuse to do so voluntarily.

In addition, the B.C. Attorney General, Ullaj Dosanjh, who is also the B.C. Consumer Minister, proposed that a nation-wide financial consumer organization be created at the annual meeting of consumer ministers from across the country, held in Regina in early September 1997. According to media reports, the consumer ministers decided that the proposal merited further exploration, and they plan to research it further and come up with resolutions to consider at their meeting next year.

The research completed in the U.S. on the history and experiences of U.S. CUBs has shown that the following elements are key to the success of the U.S. CUBs:

  1. Does the CUB organize consumers and band them together?
  2. Is the CUB independent of government and industry?
  3. Does the CUB foster individual consumer participation in the CUB, and in regulatory and legislative proceedings?
  4. Does the CUB ensure effective education, comparative-shopping and complaint-handling services for CUB members?
  5. Is the CUB democratically-governed by the CUB members?
  6. Does the CUB facilitate the expression of diverse viewpoints if they exist on the consumer issues the CUB addresses?

These are the key considerations which the CCRC has taken into account when developing a model for a Financial Consumer Organization (FCO) in Canada based on the U.S. CUB model.

In addition, the CCRC has taken into account a nation-wide survey of 2,000 adult Canadians conducted by Environics Research Group in December 1996 on behalf of a working committee of consumer groups in a project funded by Industry Canada (as made public in September by the B.C. Attorney General, Ullaj Dosanjh). The survey found that, among other things:

These survey results show strong support for the creation of a financial consumer organization in Canada based upon the U.S. CUB method and model.

Taking into account the history of U.S. CUBs, and the results of the research conducted in the U.S. and Canada, the following is a reasonable projected result if financial institutions included a one-page flyer in their mailouts to customers inviting them to join a nation-wide Financial Consumer Organization (FCO):

First, the flyer would be sent to about 22 million people. Although the survey by Environics indicated that 11% of people are very likely to join such a group, a conservative estimate of 5% is probably a good place to start (based on the experience of U.S. CUBs). This would mean that, through four mailings, 1.1 million members would likely join in the first year. If the membership fee was $20 (with a lower fee for students and people with low incomes) the annual budget for the FCO would likely be between $15-20 million.

The cost of reaching the 22 million people would be about $350,000 each time (according to U.S. experience). The government could either grant or loan the FCO the funds to print and send the first flyer. For the first year, the FCO would have mailing costs of about $1.5 million.

After the first year, the FCO would likely send out flyers twice a year (based on U.S. experience), as well as sending mailouts itself to its 1.1 million members two or three times a year (e.g. a newsletter, action alerts etc.).

In addition, the FCO would maintain offices across the country, along with a national headquarters. The FCO would hire or contract out the services of lawyers, researchers, and experts, have comparative shopping and complaint handling staff and, of course, administrative staff. The FCO would also produce and distribute educational materials to FCO delegates and members across the country, pay for an assembly of delegates' from across the country every couple of years and, of course, hold board meetings on a regular basis.

While the FCO's total annual revenues may seem like a substantial sum, it is relatively small in comparison to the resources of the big six banks and other financial institutions and, when spread across all of the above services and activities, it will not likely result in a surplus of funds.

If the FCO also accepted donations to a fund that would be used for grants to existing groups who work on financial services issues, it would also greatly increase the resources available to groups working on financial services issues across the country, and allow the FCO to fund groups working on financial services issues that have not been deemed a priority by the delegates of the FCO, or from a perspective not reflected in the FCO membership.

It should be noted that, even if the conservative estimates made above are too generous, and only half the people estimated actually joined or donated, the FCO would still be a very large, very broad-based and well-resourced organization, and the funds available for granting to existing groups would still be larger than all the funds currently available for financial consumer issues work in Canada.

Based upon these projections, the creation of an FCO in Canada based on the U.S. CUB model would balance the financial services marketplace, providing financial consumers with an organization that will help them with comparing products and services, assist them with complaints, and advocate their interests.


VI. CCRC Recommendations

Taking into account the history of U.S. CUBs, the key elements of success for U.S. CUBs, and the results of the research conducted in Canada, the CCRC recommends the following as the best model for the creation of a Financial Consumer Organization (FCO) in Canada:

  1. The creation of the FCO should be coordinated by representatives of a broad-based coalition of existing citizen groups which work in, or are concerned about, the area of financial services, and these representatives should be chosen by and from amongst the member groups of coalition. The FCO should be incorporated as a new, non-profit corporation.
  2. Canada's federally-regulated bank, trust, and life and health insurance companies should work with the coalition to start up the FCO by enclosing the FCO's flyer in their mailing envelopes sent to their customers. If they do not do so voluntarily, the federal government should work with the coalition and financial institutions to start up the FCO, after legislating the FCO's right to enclose its information and solicitation flyers periodically in mailouts that federally-regulatedbank, trust, and life and health insurance companies send to their customers. (e.g. in monthly statement, credit card bill, and annual premium statement envelopes).
  3. The federal government should either grant or loan the FCO funds to cover the costs of printing the first flyer, enclosing it in financial institution mailouts, and setting up an office to receive the responses from consumers.
  4. Following the lead of the federal government, provincial governments should also require provincially-regulated financial institutions to enclose flyers in their mailouts inviting consumers to join the FCO.
  5. The FCO's purposes should be to educate consumers about financial service industry issues, provide comparative shopping services and help with complaining about products or services, and advocate for consumer interests before the legislatures, regulatory agencies and the courts. These purposes and the FCO's structure should be set out in the FCO's by-laws or, if necessary,in the legislation creating the FCO and its right to enclose the flyer in industry mailings. The by-laws or legislation should also state that the FCO will be non-partisan.
  6. The FCO's flyer should describe the purpose of the group, its accomplishments (once it is up and running) and solicit members at an annual membership fee of between $20-$30 (with a lower feefor students or people with low incomes).
  7. The FCO's flyer should ask for donations in addition to the membership fee, so those who don't want to join but want to donate to the FCO and the financial consumer movement generally can do so.
  8. The membership fees should be used to cover the costs of FCO activities, including contracting out work to existing groups which are providing services adequately to consumers in variousareas of the country. The donations above membership fees should be placed in a fund out of which the FCO board will issue grants to existing citizen groups who work on financial servicesissues.
  9. As with some of the U.S. CUBs, any federal electoral riding with 100 or more FCO members should have the right to elect a delegate from amongst the local members. Once every two years,the delegates should be invited to a national assembly, at the expense of the FCO, at which general policy proposals are debated and approved, and at which a national board of directors of 13people is elected from amongst the delegates.
  10. The FCO's national board should be elected based on jurisdiction, with one representative fromevery jurisdiction in Canada and one chair, and no one with any ties to the financial services industry (e.g. an employee of, or lawyer for, the industry) should be allowed to be either a delegate or a board member.
  11. The board should be permitted to seek the advice of representatives of existing citizen groups which work in the financial services area, including appointing them to committees which advise the board on specific issues.
  12. The FCO should maintain offices in every province or, if resources do not allow for offices in every province, there should be offices at least in every region in Canada.


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