Online Lender Settles with FTC on UDAP, TSR, and EFTA Claims

The Federal Trade Commission’s settlement with an online consumer lending platform, Avant LLC, highlights the importance of legal and regulatory compliance in the fintech space, including—perhaps most importantly—what happens after a loan is made.

According to the Commission’s complaint, Avant offered personal consumer loans through its website. The complaint notes that although the loans were formally issued through a bank partner, Avant handled all stages of the process, and all consumer interactions, including advertising, application processing, and all aspects of loan servicing and collection of payments.

The Commission’s allegations stem primarily from Avant’s collection activities, and Avant’s representations about the payment process, under the Federal Trade Commission Act, the Telemarking Sales Rule (TSR); and the Electronic Fund Transfer Act (EFTA) and Regulation E. The allegations include that Avant:

  • Misrepresented that consumers could pay using credit or debit cards, when such cards were often declined;
  • Misstated the consumer’s payoff amount, leading to additional collection attempts and late fees;
  • Charged extra or duplicated amounts that consumers did not authorize;
  • Accepted remotely-created checks (RCCs) in violation of the Telemarketing Sales Rule (TSR); and
  • Required consumers to use recurring electronic funds transfers (EFTs) in violation of the Electronic Fund Transfer Act (EFTA).

Pursuant to Avant’s April 15 settlement with the Commission, it will pay $3.85 million as equitable monetary relief. Under the settlement order, Avant is prohibited from taking unauthorized payments and from collecting payment by means of RCCs. The agreement also addresses Avant’s representations, and Avant is prohibited from misrepresenting: the methods of payment accepted for monthly payments, partial payments, payoffs, or any other purpose; the amount of payment that will be sufficient to pay off, in its entirety, the balance of an account; when payments will be applied or credited; or any material fact regarding payments, fees, or charges.

Dangers of Over-Marketing

The settlement order is an important reminder to start-up fintechs, as well as seasoned institutions pursuing new lines of business, regarding the dangers of over-marketing. A company’s advertising/marketing must not run ahead of the company’s technical capabilities or its regulatory compliance infrastructure. Otherwise, the company risks the allegation that its representations are deceptive.

Importance of Servicing Compliance

The FTC’s complaint and settlement order also highlight the importance of servicing to the overall lifecycle of a consumer loan, and why servicing remains a focus at the FTC and other agencies, including the Consumer Financial Protection Bureau (CFPB). Mistakes during servicing can cost consumers money by leading to late fees and account overdraft or non-sufficient funds charges. Moreover, late payments and delinquencies can affect consumers’ credit reports. Because of this, servicing often results in a high level of consumer inquiries and complaints, which companies must handle efficiently and effectively.

Dissenters Object to Pushing the Envelope

While the commissioners voted 5-0 to approve the settlement, two commissioners filed dissents pertaining to the FTC’s interpretation of the EFTA and TSR. A core element of both dissents is the argument that the FTC should stick safely within the scope of the statutes and regulations it enforces, in effect avoiding the same practice of “pushing the envelope” with regards to enforcement that the CFPB, in public statements by new leadership, has made it policy to avoid.

  • Phillips Dissent: “EFTA does not prohibit the use of RCCs as an alternative to EFTs, and we should not pretend it does.”

Commissioner Noah Joshua Phillips took issue with the settlement order’s treatment of RCCs under the EFTA. The dissent explains that RCCs are not “electronic funds transfers,” under the EFTA. So, by offering RCCs as an alternative payment method to EFT, Commissioner Phillips believes that Avant did not run afoul of the EFTA compulsory use provision, irrespective of Avant’s status as a telemarketer.

RCCs are, of course, prohibited for use by telemarketers under the TSR. The dissent takes issue with using this prohibition as a bridge to an EFTA violation, which Commissioner Phillips believes is a bridge too far. While stating that RCCs may not be “a meaningful alternative to recurring preauthorized EFTs under EFTA,” the dissent notes that “the law treats the two differently.”

  • Wilson Dissent: “Rulemaking rather than mandate broad policy changes through enforcement.”

Commissioner Christine S. Wilson dissented to both the TSR and EFTA violations from the settlement order. Regarding the TSR’s “Novel Payments” (including RCCs) prohibition, Commissioner Wilson took issue with the FTC’s decision to bring TSR charges regarding RCCs—while “recogniz[ing] that the TSR’s prohibition on RCCs is intended to be a bright line rule … .”

Commissioner Wilson also objected to what she views as an importation of the TSR RCC prohibition to the EFTA compulsory use prohibition. She explained that the consent order could lead to “odd results” and “disincentive[s],” such as discouraging lenders and online lending platforms from making or accepting consumer calls during the application process, so as not to fall under the TSR, and thus maintaining the ability to accept payment by RCC.

Commissioner Wilson argued that the correct forum for the FTC to pursue larger restrictions on RCCs would be through rulemaking, rather than enforcement. She also noted the difficulties that a “fragmented law of payments” could create, with multiple agencies taking different views of RCCs and other payment methods.

Takeaways

The Commission’s complaint and settlement order provide valuable insight and reminders to the online lending industry and others.

  • Marketing should not outpace technical capability and compliance oversight.
  • Servicing is a critical part of the loan lifecycle, and a source of risk and potentially systemic errors.
  • Companies that engage in telemarketing must adhere to the TSR’s RCC prohibition, and, despite the dissents, regulators may view RCCs as a disfavored form of payment.
  • Companies should provide viable alternatives to repayment by EFT when originating loans.


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If You Build It, Will They Come?

connected cars

What if the automotive industry builds autonomous vehicles and no one wants them?  What if no one trusts them well enough to want to own one or ride in one?  This is precisely what was addressed at the recent World Congress Experience.  The lack of regulations, be they national, state, regional or local is definitely a hindrance to the adoption of a more autonomous future.

Even if regulations get drafted here and there, they may not be consistent from location to location.  This can be as bad as not having regulations at all.  Developing and manufacturing a vehicle that will adhere to regulations in one county while not meeting them in another state is not cost effective.  In fact, it is likely cost prohibitive.

How and when regulations should be drafted is not necessarily an easy question to answer.  Write regulations too early, and they may not address the vehicles that actually end up on the street.  Write regulations too late, and a variety of “standards” may already be in production or in people’s hands.

To help move the industry in a common direction, SAE International has established the Automated Vehicle Safety Consortium.  This Consortium, joined by Ford, GM and Toyota, will:

work to help safely advance the testing, precompetitive development, and deployment of SAE Level 4 and 5 automated vehicles. The AVSC will provide a safety framework around which autonomous technology can responsibly evolve in advance of broad deployment, ultimately helping to inform and accelerate the development of industry standards for autonomous vehicles (AVs) and harmonize with efforts of other consortia and standards bodies.

The consortium will leverage the expertise of current and future members to establish a set of AV safety guiding principles to help inform standards development. The first output from the AVSC will be a roadmap of priorities, applicable to developers, manufacturers, and integrators of automated vehicle technology and focusing on data sharing, vehicle interaction with other road users, and safe testing guidelines.

These are lofty goals and might help lead the industry in the right direction.  It would allow the industry to take a step toward self-regulation or at least toward taking an active role in writing the rules by which the industry would have to play.  Having the industry so involved is certainly a good idea.  Adding other stakeholders may further benefit the industry to get a broad perspective on the issues that it will face.

The Autonomous future seems to inch closer every day.  But we are still a long way from seeing what it will look like.  We are equally far from knowing if people will fully embrace this new technology, especially if they lack the confidence in its safety and efficacy.


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Modernizing Our Grid Infrastructure and Business Models to Meet Increasing Electric Vehicle Demand

electric vehicles

Guest Author: Jim Saber, President & CEO – NextEnergy

If you follow the developing electric mobility industry, you will find articles and announcements on new concept and production vehicles, battery technologies to improve vehicle range, electric vehicle charging networks, mobility services, etc. on a daily basis. It is a race to bring to the market new vehicles and services which appeal to consumers and satisfy regulators and policy makers.

While the electric vehicle (EV) industry is in still in the early stages, it is primed for significant growth in the next five to seven years. Recent articles have predicted that EVs will be cheaper to purchase than internal combustion engine vehicles by 2025. With more EVs expected in the near future, more activity needs to occur in charging and infrastructure to ensure a seamless travel and user experience. Vehicle electrification can also reverse a decade-long trend of flat demand growth for electric utilities. However, the programs and business model development has been slow in this historically conservative industry. A recent Smart Electric Power Alliance report Utilities and Electric Vehicles: Evolving to Unlock Grid Value found that 74% of utilities were in the early stage of EV programs, 23% were in the intermediate stage, and 3% were in late stages; each stage was determined based on level of consumer engagement, as well as availability of incentives and rate programs.

In 2017, 43 state governments and the District of Columbia worked on 227 pieces of legislation that included the regulation of EVs, study or investigation of EVs, incentive programs, charging infrastructure, and new utility rates for EV charging.

In Q3 2018 alone, a total of 276 grid modernization actions were taken, representing a 50% increase over Q3 2017.

Clearly, states and utilities are working to accelerate their programs. Leader states can help lagging states and their associated utilities by determining the best way to spend their time and money, but models of success have been, and are being developed so replication at scale can happen now.

As states and utilities are increasing their activity to support the growth of EVs, a few areas of future focus are:

  1. Future ownership and operation of the charging stations. States are developing programs and positions on utility ownership and operation of EV charging stations. Utilities are most familiar with the local electrical grid and have the expertise to operate the stations in a manner which increase stability and efficiency of the systems which can be an advantage. Utility ownership and operation may also limit retail competition and negatively impact EV owners in the future.
  2. The sale of electricity via EV charging stations. Since the EV charging station is not a generator (similar to a solar panel), many states are piloting the ability for the station operator to sell the electricity that goes to the charge the vehicle. This can lead to increased revenue for the operator and if taxed properly, a source of funding for the state to replace fuel taxes. Some have concerns over the potential for significant fluctuation in pricing.
  3. Experimental rates for DC fast charging systems which minimize demand charges. Owners of DC fast charging stations are typically billed on a utility’s general service tariff with a three-part rate, including per-kWh energy charges, a demand charge, and a fixed charge. The fast charging nature of these stations results in high demand charges on owners’ bills, which can be a deterrent to developing this infrastructure. To overcome this obstacle and encourage the build-out of DC fast chargers, several utilities are proposing demand charge alternatives for the owners of fast charging stations.

As states and utilities go from early to late stages of the policies and programs to support electric vehicles, the opportunities for business to invest and participate in new added-value services will become clearer, and the value of electrified mobility will be more easily realized by consumers.


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Updates in FTC and California’s Continuing Enforcement of Continuity Programs

Thought that the FTC and California planned to cool off on enforcing trial and subscription programs? Think again. The FTC and California continue to bring these actions with alarming regularity.

For those of you who haven’t been tracking these issues, last year California’s Automatic Renewal Law was amended to tighten the restrictions on continuity programs. The amendments increased restrictions on companies providing trial or discounted introductory programs, and required companies to provide an “exclusively online” cancellation mechanism for consumers who originally accepted the service agreement online.

In addition, both the FTC and the California Autorenewal Task Force (a team of district attorneys who enforce the statute) have brought multiple challenges against companies offering continuity programs. We wrote a few weeks ago about the FTC’s settlement with Urthbox, which included charges challenging how that company’s free trial and subscription offerings were disclosed.

The Urthbox settlement followed California’s autorenewal task force’s settlement with j2 Global. That settlement was unsurprising in most respects (it imposed $1.2 million in monetary redress, required the company to provide “clear and conspicuous” disclosures, obtain affirmative consent from consumers before charging the consumer, provide post-purchase confirmation, and afford consumers an easy cancellation mechanism). However, the order bears noting because it expanded the definition of “consumer,” which the California statute defines as “any individual who seeks or acquires, by purchase or lease, any goods, services, money, or credit for personal, family, or household purposes.” The order expanded the statute’s reach to any “individual consumer with a California billing zip code,” thereby reaching individuals outside the traditional definition of consumer.

The j2 Global case came on the heels of the FTC announcing its case against F9 Advertising, alleging violations of the federal Restore Online Shoppers’ Confidence Act, which governs online negative option and continuity programs. These settlements are not alone, as California has brought cases against DropBox, AdoreMe, multiple dating websites, and others, demonstrating that the California task force and FTC aren’t showing any signs of slowing their enforcement of these laws.

With the landscape surrounding trial and continuity programs shifting rapidly, advertisers would be wise to double-check that their programs comply with the most up-to-date laws and regulators’ expectations. And advertisers shouldn’t bank on falling outside the reach of these laws. Otherwise, they run the risk of falling onto regulators’ radar.


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Manufacturing MarketTrends | April 2019, Issue 1

Cargo

Welcome to Foley’s new Manufacturing MarketTrends newsletter. In each edition, we will highlight key trends to watch out for in 2019, making it a year of change for manufacturers.

Know Your Supply Chain

If a company fails to know its supply chain, it can find itself getting burned in many ways, including responsibility for upstream use of forced labor or downstream sales to an export-restricted company. One of the most common ways that a company may find itself in trouble is by failing to ensure that the obligations it is undertaking in its agreements with customers are backed up by the rights it is receiving in its agreements with suppliers.

As a simplified example, if a company is warranting to its customer that products do X, Y and Z, then the company should ensure that the suppliers of its products are warranting that they do X, Y and Z. Further, if a company’s sole and exclusive remedy for a defective product from its supplier is replacement of the product or a refund of the purchase price, then the company should ensure that its agreements with customers correspondingly limit the company’s responsibility.

Even if the company’s supply chain contracts are perfectly symmetrical, if the company cannot collect from its supplier (due to the supplier’s insolvency or otherwise), then the symmetrical contracts do little good. Thus, a company must also (i) know with whom it is entering into business, (ii) ensure its supplier’s creditworthiness, and (iii) require its supplier to maintain sufficient insurance to cover the supplier’s obligations under its agreement with the company.

Section 232 and 301 Tariffs

Many manufacturing companies were heartened by the announcement that the next tranche of section 301 tariffs on Chinese imports will be delayed following further progress in the negotiations between the U.S. and China. The existing section 232 and 301 tariffs still have had a major impact on manufacturers’ profit margins. Many companies cannot meet the requirements to obtain an exclusion. The 10 percent and 25 percent tariffs have seriously impacted manufacturers across a number of industries, including many that entered into long-term agreements for the sale of goods without any right to seek adjustments or price increases following the imposition of these tariffs.

How are these additional costs and risks flowing through the supply chain where there are fixed-price, long-term supply agreements? There have been a series of consequences that have reverberated through the supply chain. In the unlikely event that the contract contains a price adjustment clause or indexing or even a “good faith” obligation to renegotiate pricing, suppliers are exercising these clauses. Where contracts do not contemplate price adjustments (most do not), suppliers may be forced to make unilateral demands for price increases under a number of theories, such as claims of force majeure or commercial impracticability. Some suppliers have threatened to stop shipping products unless the buyer will increase prices or take over responsibility for importing the goods at issue as the importer of record. If the product is critical enough to the buyer’s supply chain and cannot be obtained from an alternate source, the buyer may have no choice but to acquiesce in the relief requested by the supplier, even if it falls outside of the parties’ contract and technically is a breach of the seller’s obligation to supply goods at a fixed price.

Whether on the sell side or the buy side, it is important that the manufacturer track all additional costs incurred as a result of the tariffs, any related demands or any cost relief. There may be an opportunity at the end of the parties’ agreement to recover some of these costs or, at least, negotiate more favorable terms for any future business.

OFAC Highlights the Importance of Supply Chain Due Diligence

Regulators at the Office of Foreign Assets Control (OFAC) have sent a near seven-figure message that companies need “full-spectrum” supply chain due diligence by assessing a $996,080 penalty on a California cosmetics company, e.l.f. Cosmetics (ELF), for purchasing false eyelash kits from suppliers in China that had sourced from North Korea, in alleged violation of the North Korea Sanctions Regulations, according to OFAC.

This enforcement action highlights the risks for companies that do not conduct full-spectrum supply chain due diligence when sourcing products from overseas, particularly in a region in which North Korea, as well as other comprehensively sanctioned countries, are known to export goods. OFAC encourages companies to develop, implement, and maintain a risk-based approach to sanctions compliance and to implement processes and procedures to identify and mitigate areas of risks. Such steps could include, but are not limited to, implementing supply chain audits with country-of-origin verification, conducting mandatory OFAC sanctions training for suppliers, and routinely performing audits of suppliers.

The Departments of Treasury, State, and Homeland Security also have highlighted North Korean “deceptive practices” that put U.S. supply chains at risk of legal violations. A special advisory titled “Risks for Businesses with Supply Chain Links to North Korea” states that North Korea often sends workers abroad to earn hard currency to send back to the North Korean government. U.S. firms that purchase goods made by these workers risk significant fines and having their imports seized at the border.

As the U.S. government concludes in its advisory, “[b]usinesses should closely examine their entire supply chain(s) for North Korean laborers and goods, services, or technology, and adopt appropriate due diligence best practices.” With OFAC also maintaining strict sanctions regimes against other countries and regions, governments, and specially designated persons, any firm that relies on an international supply chain needs to incorporate the types of supply chain best practices highlighted by the advisory and by OFAC in the ELF settlement.

Market Intelligence

Additive Manufacturing. Additive manufacturing, the process of building three-dimensional structures by adding layers of material through digital design, is no longer just wishful thinking; the number of enterprise-class three-dimensional printer manufacturers has tripled to 180 since 2016. Of manufacturers surveyed, 56.9 percent reported that they either already had, or planned to deploy within the next 36 months, some form of three-dimensional printing technology.

Additive manufacturing is no longer limited to building with plastics. For example, researchers at A*Star Singapore Institute of Manufacturing Technology have shown that additive manufacturing techniques can make a stronger version of a high-entropy alloy, cobalt-chromium-iron-nickel-manganese, allowing lower-cost manufacture of metal parts that have greater resistance to fracturing under harsh conditions.

And the reach of additive manufacturing is quite long. Boeing announced it has used additive manufacturing techniques to build control antennae for its AMOS 17 satellite. Bugatti uses selective laser melting, a form of additive manufacturing, to help create lightweight, strong parts for the Chiron sports car. In a trial taking place in the United Kingdom, additive manufacturing is being used to manufacture a titanium port for delivering microcatheters to target a region of the brain with a naturally-occurring protein that researchers think may reverse Parkinson’s Disease.

Cybersecurity. Remaining competitive and advancing requires manufacturers to rapidly implement new technologies, though they may be slow to recognize the associated cybersecurity risks. With complex systems, devices utilizing the IoT, and increasing connectivity to the Internet and third parties, manufacturers are creating new opportunities for cyberattack.

Manufacturing is as target rich as every other industry. Manufacturers maintain intellectual property, product and manufacturing designs and specifications, employee and customer data, financial information, and a host of other valuable assets. With ransomware, manufacturers may be even more at risk given that they are considered less cybersecure – which can make them prime bait for phishing an employee, gaining access to the network or dropping ransomware seeking a large payout. Often attacks start in one system and leapfrog across the network to compromise high-value targets in another system. Numerous manufacturers have had their production operations shut down, causing a massive ripple effect throughout their supply chain due to ransomware such as Notpetya, Samsam, and WannaCry.

Manufacturers need to become more cybersecure, which may require solutions such as multifactor authentication, log analysis, password rules, training, and access controls. Manufacturers should consider retiring programs and equipment that are considered end–of-life and no longer supported, leaving them exposed to known vulnerabilities. They should focus on event detection, which is more effective than seeking “absolute protection,” including secure log aggregation and security information, event management, and continuous security monitoring. Finally, manufacturers should improve their incident response capabilities, including pre-engaging with incident response and forensic providers to help support investigations.

An effective cyber strategy may require changing operational protocols. Many traditional in-house IT departments have an “if it ain’t broke, don’t fix it” mentality, leaving in place unpatched or unsupported systems that are highly vulnerable to attackers. Even if a manufacturer patches “all” vulnerabilities and secures “all” borders, the hackers are already on to the next vulnerability. Thus, the never-ending game of whack-a-mole. Vigilance is key!

Manufacturing: The Road Ahead

For an interactive session on managing your business’s cyber risk in the age of IoT, make plans to join Foley in Milwaukee on May 9th for our next Midwest Cyber Security Alliance meeting. For event details, contact Foley’s Midwest Cyber Security Alliance co-founder, Jennifer Rathburn.

Foley Resources

We invite you to subscribe to Foley’s Manufacturing Industry Advisor blog, which examines the latest news, developments, and trends in the manufacturing industry.


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Brexit … Exit or No Exit?

Brexit

Almost three years after the UK’s 2016 referendum to exit the EU (“Brexit”), there is no UK agreement on the substantive terms of exit or its timing.  It is clear, however, that Brexit is causing devastating economic loss and unemployment, particularly in UK’s motor vehicle industry.

The exit plan agreed to by UK/EU leaders has been repeatedly rejected by Parliament.  That plan has now been split into two parts – a withdrawal agreement (the legally binding terms of exit – how much the UK must pay to leave and a two-year transition providing for status quo on trade, travel/treatment of UK/EU citizens) as well as a political declaration (the future relationship with the EU).  Deadlines have come and gone.  Even the UK Prime Minister’s promise to resign if the plan were approved hasn’t moved the ball closer to the goal. As the latest deadline approached, the EU granted the UK an option to leave at any time before October 31 if the withdrawal plan were approved, thus avoiding a “hard exit” that would otherwise occur.  While the EU clearly prefers an agreed-upon exit, EU patience is running out.

This spectacle reminds one of Jean-Paul Sartre’s play “No Exit” in which three bickering characters find themselves punished in the afterlife by being locked in a room together for eternity.  Stay tuned!

Negative economic consequences of Brexit for the UK are everywhere apparent – reduced competitiveness, escalating unemployment, brain drain and capital flight.  The UK motor vehicle industry – employing 856,000 people and accounting for more than 5% of total UK GDP – is particularly hard hit.  In 2018, investment dropped 46.5% from 2017 and vehicle production fell to its lowest level in 5 years. Multinational manufacturers are voting with their feet.  Some companies are either idling/shuttering UK production or realigning their supply and distribution infrastructures outside the UK.  The UK’s credibility as a safe and secure place for business has been badly damaged by the economic and political wreckage that the Brexit crisis has created.


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Grooming Standards: No Longer So “Hair-Larious”

After seeing several players’ hair covering their jersey numbers during a performance of the Star Spangled Banner, former New York Yankees’ owner, George Steinbrenner, instructed the players to cut their hair. It was then, in 1973, that the New York Yankees’ grooming policy was born.  The official team policy states that, “all players, coaches, and male executives are forbidden to display any facial hair other than mustaches (except for religious reasons), and scalp hair may not be grown below the collar.” Over the years, many have commented about the policy and some have openly rebelled.

In 1991, Don Mattingly (current Miami Marlins’ Manager), defied the policy and refused to cut his hair. In response, he was removed from the team’s starting lineup and was fined repeatedly until he trimmed his hair.   As with employers with similar policies, Steinbrenner wanted the Yankees to adopt “a corporate attitude.”

New York City, however, has recently warned businesses that bans on hairstyles commonly worn by African-Americans may violate anti-discrimination laws.  On February 18, 2019, the New York City Commission on Human Rights said, in part, that employers may face liability under New York City’s Human Rights Laws if their policies subject African-American employees to disparate treatment – such as the banning of “cornrows, dreadlocks, Afros, or fades.”  Under the guidelines, the Commission can impose a penalty of up to $250,000 on those who harass, demote, or fire individuals because of their hair.

New York City is leading the charge. Not many other local governments (if any) have considered similar ordinances. But this warning serves as reminder that overbroad appearance and grooming policies can lead to discrimination concerns in the workplace. Ways to curb potential concerns include drafting concise, easy-to-understand policies, carving out exceptions based on protected categories (such as for religious reasons like the Yankees’ policy did), and, of course, making sure that the policies are enforced consistently.

Something tells me that if The Boss were still around, he would likely pay a $250,000 fine per player to make sure that his Yankees look clean-cut … but how many other employers would do the same?

Register Here for our 2nd Annual Tampa Labor & Employment Law Seminar from 8am-4pm on Friday May 10, 2019 at the Tampa Bay History Museum.

Register Here for our 29th Annual Miami Labor & Employment Law Seminar from 8am-4:15pm on Friday, May 17, 2019 at the Hard Rock Stadium.

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