Financial Services and Markets Appendices to the Minutes of Evidence



  My submissions relate primarily to the establishment of the Financial Services Ombudsman Scheme and those other provisions which have an indirect impact on its operation. The attached paper is an abridged version of my submissions to the Treasury on its consultation on the Bill. I would strongly urge the committee to read my full paper as it contains my own redraft of the relevant provisions of the Bill.

  I start by saying that the success or failure of the legislation and financial services reform will be measured by the failure or success of the complaints regime—the resolution of complaints is the face of the legislation to the consumer. The Government will have at its disposal the considerable experience and enthusiasm of the staff of the existing schemes. I feel strongly that the Financial Ombudsman Scheme should achieve its objective of being a speedy and cost effective alternative to the courts. I do not believe that that has been achieved in the draft legislation. My response attempts to deal with those problems I believe exist.

  My evidence deals with:

  The provisions other than those relating to the Financial Services Ombudsman—section 10 (Exemption of representatives), sections 14 to 16 (Enforceability of Agreements), section 19 (Financial Promotion), and sections 74 (Endorsement of Codes) and 80 (Action for damages).

  The Provisions relating to the creation of the Financial Services Ombudsman, in particular:

    (1)  The general provisions describing the scheme (section 151);

    (2)  The jurisdiction of the scheme (both compulsory and voluntary) (sections 152-154);

    (3)  Determination of complaints (sections 155 and 156);

    (4)  Costs (section 157);

    (5)  Power to require information (sections 158 and 159);

    (6)  Funding/fees (section 160);

    (7)  Schedule 8.

  I am aware that the Government has already proposed changes to:

    (a)  the way the scheme's jurisdiction is to be expressed;

    (b)  costs; and

    (c)  appeals on points of law.

Although I have not seen any draft of the proposed changes, based on information available, I do not believe that the issue of jurisdiction has been satisfactorily resolved. I believe that if a consumer conducts business with a regulated person (be that person a bank, building society or financial adviser) he/she should not have to be concerned about issues of jurisdiction or membership of the scheme before they conduct that business or before their complaint can be considered. In my view the legislation could present regulated firms with many technical objections to complaints being considered.

  1. Unless otherwise stated, all section and paragraph references are to the sections and paragraphs in the FSM Bill. The Financial Services Ombudsman will be cited as the FSOmbudsman hereafter.

  Part A



  2. Section 10 appears to be the equivalent to section 44 of the Financial Services Act 1986, although in much simpler terms.

  3. It has been argued by senior counsel before a hearing with the Principal PIA Ombudsman that section 44 of the Financial Act has the effect of excluding the doctrine of ostensible authority. That if there is no acceptance in writing for the conduct complained of, the complainants cannot go further and rely on the common law—they are limited by the agreement made under the statutory scheme. That must be wrong. To say otherwise would lead to some extraordinary results. For example, an authorised person could orally hold a third party out as having authority to conduct regulated business (which was in fact outside the terms of the written agreement), but would then be protected by the statutory scheme if a claim was subsequently made in relation to that unauthorised business.

  4. It would be useful, in that it would avoid any further dispute, if section 10 specifically stated that the liability of the principal (authorised person) may still arise by reason of any common law principle giving rise to a liability on the part of a principle for the activities of his agent.


(a) Extent of the provisions in sections 14 and 15

  5. Under section 14, an agreement made in the course of carrying on a regulated activity (excluding deposit taking) in contravention of the general prohibition is unenforceable by the provider against the purchaser.

  6. Under section 15, an agreement made by an authorised person (not in contravention of the general prohibition) in consequence of something said or done by a third party in contravention of the general prohibition is unenforceable against the purchaser (this would not include an appointed representative who has gone beyond his authorisation under section 10 because there would be no breach of the general prohibition—it appears that it would only include an unauthorised intermediary).

  7. Under section 34 (1) no authorised person may carry on a regulated activity in the United Kingdom, or purport to do so, unless the Authority has granted him permission to carry on that activity or unless a provision in the FSM Bill gives him such permission. This section does not provide a specific remedy if an authorised person goes beyond his authorisation—it certainly is not clear that an investor could avoid the agreement (although there may clearly be a claim for breach of statutory duty). It would not come within section 14 and 15 because there is authorisation and thus no contravention of the "general prohibition".

  8. It is my view that the right of the investor/customer in sections 14 and 15 to avoid the agreement and claim compensation should be extended to those sales where the authorised person has gone beyond his authorisation (most importantly this would include an appointed representative who has gone beyond the terms of his section 10 agreement).

(b) Compensation under section 16

  9. Where an agreement is unenforceable by reason of section 14 or section 15, compensation is due for any loss suffered by the purchaser. Under section 16 the compensation recoverable will be that sum agreed by the parties or the amount determined by the court. The court also has a power to allow the agreement to be enforced or allow any money paid or transferred under the agreement to be retained.

  10. In my view, the powers of the court set out in section 16 should also be available to the FSOmbudsman. The investor should not be put to the expense of going to court where his investment agreement was procured by an unauthorised person (or, if my submission above is accepted, by an authorised person who goes beyond his authorisation).

  11. As the power of the FSOmbudsman set out in sections 151 to 160 to consider complaints only relates to authorised persons (or persons who have voluntary agreed to participate in the scheme), amendments are necessary. Rather than amending the FSOmbudsman provisions, which would be a difficult task and unnecessarily complicate the FSOmbudsman scheme provisions, the matter could be resolved by specifically giving the Ombudsman jurisdiction within section 16—e.g., "Notwithstanding sections 151 to 160 and Schedule 8 of this Act the Ombudsman established under those provisions may exercise the powers of the court set out in this section."


  12. Under section 19(1) and (2), if a person enters as a customer into a relevant agreement (or exercises any rights conferred by an investment) as a direct or indirect result of an unlawful communication it is unenforceable against him. That person is also entitled to compensation. Again, the amount of compensation is that sum agreed between the parties of the amount determined by the court (section 19(7)). As with section 16, the FSOmbudsman should specifically be included here as having the same jurisdiction as the court.


  13. Section 74 of the FSM Bill provides for the endorsement of codes (or particular provisions of a code) by the Authority where it is satisfied that the provision made by the code could have been made by the Authority in its general rules (general rules are defined in section 70(1) as being rules necessary or expedient for the purpose of protecting the interests of persons who, inter alia, use the services provided by an authorised person). Breach of an endorsed code may only lead to intervention or discipline (section 74(3)).

  14. Under section 80 of the Bill (which appears to be the equivalent of section 62 of the Financial Services Act) a private person (who is not yet defined) is given a cause of action where there has been a contravention of "a rule" (which I assume includes the general rules). Thus even though the Authority could have made the endorsed code as part of its own rules (thereby giving an investor the cause of action under section 80 for its breach) when those same provisions only form part of an endorsed code there is not a cause of action for breach of that endorsed code.

  15. It is my view that where there has been endorsement of a code (or part of a code) under section 74 the investor/customer should be given the same rights where there has been a breach of those endorsed provisions in the same way as those applicable to a breach of a rule by reason of section 80.

  Part B



The Scheme

Section 151

  16. Section 151(1) refers to resolving "disputes involving authorised persons". There are two points here. First the remainder of the provisions refer to "complaint" and for consistency and correctness, the word "complaints" should replace "disputes" in section 151(1).

  17. Secondly, an "authorised person" has the meaning given in section 20(3) (see section 219), namely "a person who is authorised for the purposes of this Act". As I read the provisions, it is clear that the scheme is not limited to resolving "disputes involving authorised persons". The voluntary jurisdiction is an example of this. It is my view that "involving authorised persons" should be replaced by "involving persons subject to the jurisdiction of the scheme" which would include those with both compulsory and voluntary membership.

  18. I also believe that some fundamental concepts and definitions should be explained in section 151, thereby setting the scene for the remaining provisions. It is apparent that apart from section 151 (4) there is little cross-referencing between sections 151 to 160 and schedule 8, yet both must work together. This could be improved within this section by inserting some relevant cross-references to the definitions contained in schedule 8, for example, "scheme rules" and "Ombudsman", which are referred to throughout the sections in Part XIV.

  19. I also believe that this initial section should explain that the Ombudsman's role is not only to make decisions and awards, but to also act as a conciliator (it is this issue which sets it apart from adversarial litigation). The Ombudsman's duty must be to "facilitate the satisfaction of complaints" whether by agreement or by making an award. It should also be explained that the Ombudsman shall, in carrying out his functions, decide his own procedure to be adopted in considering complaints (subject, of course, to the legal obligations on him to act fairly and comply with the Human Rights legislation).


  20. As the draft explanatory notes record (on page 58), there are a number of Ombudsman and arbitration schemes operating in the financial services sector. It is intended that the new provisions will replace those existing schemes. Some of those schemes operate on a voluntary membership basis and some on a compulsory membership basis. Those schemes are respected for the work they undertake.

  21. I am aware that the Government intend to make changes to the jurisdiction provisions contained within the draft bill. I have not seen those changes. The explanation provided in the March 1999 Progress Report suggests that the scheme's jurisdiction will be built around the compulsory jurisdiction direction given by the FSA. In my view the jurisdiction should be set out in the legislation and not left to the discretion of the FSA. Consumers need to know what their rights are to complain in the event of fault. My full response to the Treasury's consultations sets out the format I believe the legislation should take. My evidence in this paper will concentrate on the compulsory and voluntary jurisdiction provisions on the assumption that those will remain substantially unaltered by the Government's proposed changes.

  22. Section 152—In relation to this section my specific comments are:

  22.1 In subsection 152(2) the conditions of eligibility are that the complainant is eligible under the scheme rules and that the respondent was authorised. Those conditions read along with section 152(1) provide no scope for excluding the complaint on any of the grounds set out in the scheme rules—as there is no reference to the need to have regard to complaint eligibility under the scheme rules. Subsection 152(2) should also have a requirement that "the complaint is eligible under the scheme rules."

  22.2 Subsection 152(2)(b) requires that the respondent was "at the time to which the complaint relates . . . " This would be much improved and easier to apply if it read "at the time of the events giving rise to the complaint."

  22.3 In subsection 152(5) it states that a complainant is eligible if he falls within a class of person specified in rules made by the Authority. The Authority's procedural rules (in paragraph 14 of schedule 8) do not provide for complainant eligibility rules (e.g., size of companies or partnerships). In any event, complainant eligibility requirements would be more appropriately contained within the scheme rules.

  22.4 As a consequence of the amendment to subsection 152(5), subsection 152(6) should now read "The scheme rules may make provision for persons other than individuals to be eligible."

  23. The legislation should also make absolutely clear that it is for the Ombudsman (in my view the Chief Ombudsman), in the first instance, to decide whether or not a complaint falls within his jurisdiction and both the respondent and the complainant must co-operate with the Ombudsman in reaching a jurisdictional decision. My full response to the Treasury's consultation contains a new section dealing with co-operation with the Ombudsman at both jurisdiction and investigation stage, and the consequences of failing to do so.


  24. If the necessary amendments are made to section 152 so that all complaints dealt with by the schemes which the FSOmbudsman is to replace are covered by section 152 (as I would suggests), then the voluntary jurisdiction need say no more than it will cover complaints not falling with the compulsory jurisdiction.

  25. In relation to the voluntary jurisdiction, under section 154(3) a voluntary jurisdiction direction may be given where:

  25.1 It relates to an activity to which a compulsory direction does not apply because the respondent was not an authorised person at the time to which the complaints relates (section 154(3)(a)).

  25.2 It relates to an activity which "could be" made the subject of a compulsory jurisdiction direction but which has not been (section 154(3)(b)); or

  25.3 It relates to an activity which is not a regulated activity (i.e., it does not fall within the Treasury Order made under section 11), could not be made the subject of a compulsory jurisdiction direction (i.e., because it is an activity outside the terms of Schedule 2) but could be made a regulated activity under section 11 (i.e., it is an activity which relates to an investment or is an activity carried on in relation in property of any kind: section 11(1)(a)(b)).

  26. This seems overly complicated. Surely it need say no more than a voluntary jurisdiction direction may cover any type of complaint or respondent which does not fall within the compulsory jurisdiction.

  27. Under subsection 154(2)(b) and (8) it appears that it is not necessary for participation at the time of events giving rise to the complaints—only that the respondent qualified to participate and agreed to participate when the complaint was made to the scheme. I would have thought that the intention was that the respondent had agreed to participate at the time of the events giving rise to the complaint.

  28. It is not clear whether section 154(3)(a) and (b) are separate factors or cumulative. The lack of the word "and" suggests that they are separate. If that is right, for clarity, the addition of the words "which would otherwise apply" should be added to section 154(3)(a) so that it reads "to which a compulsory direction, which would otherwise apply, does not apply because the respondent was not an authorised person . . . ."

  29. Additional matters not contained within section 154 are:

  29.1 There should be provisions for the giving of notice before a respondent can withdraw from the voluntary jurisdiction and the consequences of cessation.

  29.2 There should be provisions for the scheme operator to terminate participation in the voluntary jurisdiction and the consequences of cessation.

  29.3 The scheme operator should be obliged to keep a register of those persons who have agreed to participate in the voluntary jurisdiction.


Compulsory Jurisdiction


  30. Sections 155 and 156 deal with provisions which the Ombudsman must observe when reaching his determination and making his award. The whole of those sections apply to complaints within the compulsory jurisdiction without regard to the type of complaint or the nature of the respondent.


  31. Section 155 should be prefaced with a section which explains that if a complaint is not settled or withdrawn during the conciliation process, the Ombudsman may, after the completion of the investigation of the complaint and considering the submission made, make a determination.

  32. The Ombudsman is obliged to make a statement where he has determined a complaint. The statement must give reasons and be signed—there is no provision requiring the Ombudsman to state the nature of the award. Although this may appear obvious, I believe that specific reference to this requirement should be made.

  33. This section should also deal with all other relevant substantive issues. In particular, specific reference should be made to the principle that:

  33.1.1 The Ombudsman shall not be bound by any legal rule of evidence.

  33.1.2 The Ombudsman shall not be bound by any previous decision made by him or by any other Ombudsman or by any predecessor in any such office.


  34. Under section 156(1) and (2), in relation to complaints which fall within the compulsory jurisdiction, where the complaint is determined in favour of the complainant, the determination may include a money award or a direction to take steps. There should be a third option—which is a combination of a money award and a direction to take steps.

  35. Subsection 156(2)(a) refers to "such amount as the Ombudsman considers fair compensation for loss or damage (of a kind falling within subsection (3)) suffered by the complainant . . . " In my view "fair compensation" does not denote sufficient objectivity—assessing loss in a legal sense does not involve fairness. Furthermore, there is no reference to compensation for anything other than loss or damage (e.g., distress or inconvenience).

  36. I believe that subsection 156(2)(a) should read: "the determination may include (a) an award of compensation against the respondent for loss or damage or distress or inconvenience (of a kind falling within subsection (3)) suffered by the complainant . . . "

  37. Subsection 156(3) is divided into:

    (a)  losses for breach of contract; and

    (b)  loss or damage of any other specified kind.

I do not see the logic behind this division. Many complaints could be based on two or more causes of action—breach of contract and negligence for example. In relation to regulatory complaints, the most common cause of action will be breach of statutory duty as provided for in section 80 of the FSM Bill. In addition to determining the complaint, will it be necessary to decide the cause of action on which the decision is made so that the award can be calculated? This again seems overly complicated.

  38. In my view the split should be between:

    (a)  compensation for any loss or damage for which the court has a power to award damages (irrespective of the nature of the cause of action); and

    (b)  compensation for any distress or inconvenience or any loss or damage suffered by the complainant not within (a) for which it is fair and reasonable to award compensation.

In this way there is greater correlation between the compensation provisions and the provisions to which the Ombudsman must have regard when reaching his determination—section 155(2).

  39. In subsection (5) "if he [the Ombudsman] considers fair compensation requires payment of a larger amount . . . " a recommendation may be made. In my view "fair compensation" is too vague and subjective. It should read "if he" [the Ombudsman] considers that proper compensation requires payment of a larger amount . . . " a recommendation may be made. This is a more objective test.

  40. For clarity subsection 156(6) should read "The monetary limit is such amount as may be specified by the Authority under subsection (4)".

  41. Subsection 156(7) should read "Different monetary limits may be specified . . . "


  42. Paragraph 17 obviously brings the money award within Order 25, Rule 12(1) of the County Court Rules (applicable in relation to England and Wales). Under the legislation, before a money award can be enforced it must be "registered in accordance with scheme rules . . . ". However, there is no provision in paragraph 15 which requires the scheme operator to create or keep a register of awards. Will the complainant have to produce an extract from the register when applying to the county court or some other declaration from the scheme operator or Ombudsman. This appears to be an unusual requirement. The procedure in Order 25, Rule 12(1) merely requires the production of the original or a copy of the award. I would suggest that the requirement to register the award be removed.

Voluntary Jurisdiction

  43. There are no provisions at all detailing how complainants within the voluntary jurisdiction will be determined. I assume that this is a matter which will be considered when issuing a voluntary jurisdiction direction. Nevertheless, I do believe that even at this stage, before the making of a voluntary jurisdiction direction and the specifics as to the basis on which awards will be made, that certain provisions should be set out in the legislation. The most important being the right to enforce an award or the right to take injunctive proceedings in respect of an award made by an Ombudsman under the voluntary jurisdiction. Those rights require legislative force.

  44. In respect of the enforcement of a money award, Order 25, Rule 12(1) of the County Court Rules requires an "enactment" to provide for an award to be enforceable in the county court. It would not, in my view, be sufficient for such provision to be contained within the voluntary jurisdiction direction.


  45. I am aware that positive changes to the costs provisions have been proposed by the Government. I will say no more on this issue.


  46. Section 158 provides the Ombudsman with a power to request information or documentation. As with section 157 (costs), it is not clear whether this applies to section 152 complaints, the voluntary jurisdiction or both.

  47. In relation to section 158(3) it should be made clear that the Ombudsman decision is final. It would not be unusual to get into debates as to what information is necessary for the fair determination of the complaint.

  48. Subsection 158(4) says that "the person to whom [the document] is produced may" take copies, etc. Under section 158(1) it is the Ombudsman making the request for the information. It would be much clearer if "the person to whom [the document] is produced may" was changed to "the Ombudsman may" (even though in practice it may be one of his staff receiving the information). A similar amendment should be made to "the person requiring its production" in subsection 158(5) as we know this is also the Ombudsman.

  49. Subsection 158(6) states that no person may be required to produce or disclose a privileged document. Who decides this where there is a dispute as to whether a document is privileged?

  50. I have expressed a view below that the scheme rules should make provision for information to be provided in confidence. I believe that there should be a cross-reference to such a provision in section 158 with the caution that it is for the Ombudsman to decide to what extent regard is had to information provided in confidence.

  51. Section 159 provides that if a person (known as the defaulter) fails to comply with a request for information, an Ombudsman may certify that fact in writing to the court and the court may enquire into the case. If the court is satisfied that the defaulter failed to provide the information without reasonable excuse, it may punish the defaulter as if he had been guilty of contempt of court. I have considerable misgivings that this provision should relate to the complainant. The fear of being unable to provide information may of itself be a considerable deterrent to some complainants wishing to make a complaint. In my view there should be three options set out in section 159:

  51.1 Where the defaulter is the complainant, the Ombudsman should have a discretion to terminate his investigation.

  51.2 Where the defaulter is the respondent or the complainant, the Ombudsman should have a discretion to continue his investigation without references to the information requested.

  51.3 Where the defaulter is the respondent, the Ombudsman should have a discretion to report the matter to the court as set out in section 159.


  52. Section 160 provides for the Authority to make rules requiring the payment to it, or to the scheme operator, by authorised persons of specified amounts or amounts calculated in a specified way. This provision must be read along with paragraph 16 of Schedule 8, which explains that the Scheme rules may require a respondent to pay to the scheme operator such fees as may be specified in the rules.

  53. Subject to my belief that the jurisdiction under section 152 should not be limited by the requirement that respondents under that jurisdiction should be authorised persons (and therefore payment in section 160 should not also be so restricted), as far as section 160 and paragraph 16 of Schedule 8 are currently worded I have no objection.

  54. There are no fee charging provisions in relation to the voluntary jurisdiction. It may be that these provisions will be included within the voluntary jurisdiction direction. Nevertheless, in order to put the beyond question the scheme's powers to make charges for voluntary participation, I believe that similar provisions to section 160 and paragraph 16 of Schedule 8 should be included in the legislation.



Establishment by the Authority of the Scheme Operator

  55. Paragraph 2(1) should surely refer to "the functions conferred on the scheme operator by or under this Act". It currently refers to "by or under this Part". However, the functions of the scheme are much wider than those set out in Part II of Schedule 8—they are more particularly defined in Sections 151 to 160.

Annual Report

  56. Paragraph 8 requires that at least once a year the scheme operator makes a report to the Authority on the discharge of its functions. By reason of paragraph 3(5) the function of the scheme operator in producing that report may be exercised only by the Board.

  57. I have no particular objection to a report being produced to the Authority by the board. However, one of the strengths of the existing schemes is the report produced by the Ombudsmen of the Scheme. The reports currently produced by the existing schemes explain the approach to case investigation, give guidance on issues of importance and detail the work of the scheme. In this way the report is useful to both respondents and complainants. It would be a great loss to lose the production of such a report.

  58. In the case of the PIA Ombudsman scheme, its annual report contains a report from the council (seen to be the equivalent to the FSOmbudsman's schemes board) and the Ombudsmen.

  59. I would strongly suggest that the same format be followed. There should be an obligation on both the Ombudsmen and the board to produce a report (although the reality would be that they would be contained within the same document).


  60. Paragraph 9 states that the scheme operator may publish guidance. As this guidance is most likely to relate to the way the scheme investigates complaints (both generally and in relation to specific types of complaints) the Chief Ombudsman should be responsible for providing advice to the scheme operator with regard to this guidance.

Exemption from Liability in Damages

  61. Paragraph 11 provides a protection for claims for damages. I would question why this is limited only to the compulsory jurisdiction. I would like to see this protection being given across the whole of the Ombudsman's jurisdictions.


  62. Under paragraph 12, for the purpose of the law relating to defamation, proceedings in relation to a complaint which is the subject of the compulsory jurisdiction are treated as if they were proceedings before a court. Again, I would question why this is limited only to the compulsory jurisdiction. I would like to see this protection being given across the whole of the Ombudsman's jurisdictions.


Authority's procedural rules

  63. The discretion given to the Authority in paragraph 14 to make procedural rules contains provisions which will impact on issues of the Ombudsman scheme's jurisdiction to consider complaints, namely sub-paragraphs 14(1), 14(2), 14(3). All of those provisions would be more usefully contained within the Scheme Operators Rules (paragraph 15). In this way, the Authority's rules will not form a jurisdictional document thereby simplifying the resolution of jurisdiction disputes.

  64. The Authority's rules should be limited to the provisions of paragraph 14(4) which require the respondent to establish appropriate procedures for the resolution of complaints which may be referred to the scheme (I do not see the need for the reference in (b) to "arise out of an activity to which the Authority's powers under Part VIII do not apply").

  65. The Authority's rules will only apply to authorised persons. However, there will be those respondents who have agreed to participate in the scheme's jurisdiction on a voluntary basis. It must be right that they are also obliged to have internal complaints procedures in place for the resolution of complaints. The legislation should apply the Authority's rules in this regard to those respondents who have agreed to participate in the scheme.

Scheme Operators Rules

  66. Sub-paragraph 15(2) sets out some of the issues which may form part of the scheme rules. I have only two comments:

  66.1 Sub-paragraph 15(2)(c) provides that the scheme rules may include a provision for persons other than the complainant and the respondent who appear to have an interest in the determination to be made parties to the complaint. This is a provision which, as far as I am aware, is new to Ombudsman scheme procedures. I would firstly question whether such a provision is necessary as the Ombudsman is dealing only with the complaint and may only make an award against the respondent (he may request information from a third party—who could provide it on a voluntary basis). Secondly, I would question whether such a provision in the scheme rules would be binding on any person whom the Ombudsman wished to make a party to the complaint—I do not see that the scheme rules would have the legislative power to permit the Ombudsman to join third parties.

  66.2 Sub-paragraph 15(2)(d)—should also include reference to the provision of information that may be provided in confidence.


  67. Save for the fact that I believe that provisions regarding fees and the enforcement of awards made under the voluntary jurisdiction should be included within Part IV of schedule 8 (in similar terms to paragraph 16 and 17 of schedule 8), and that the discrepancies between the provisions of the voluntary and compulsory jurisdiction in relation to the exemption of liability in damages and privilege should be removed, I have nothing to add in respect of these provisions.


  68. It is my opinion that the draft provisions relating to the Ombudsman Scheme are unnecessarily complicated. Simplification can be achieved by making greater use of the legislation and scheme rules under which the existing schemes operate. I believe that the legislation attempts to reinvent a wheel that has been successfully working for some time.

22 March 1999

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