Mortgage Banking Update - June 2, 2022
In This Issue:
- CFPB Issues New Circular on Application of ECOA Adverse Action Notice Requirements to Credit Decisions Using Algorithms
- U.S. Treasury Releases 2022 Strategy for Combatting Terrorist and Other Illicit Financing
- New CFPB Interpretive Rule Outlines Broad State CFPA Enforcement Authority
- CFPB Scraps No Action Letter and Compliance Assistance Sandbox Programs and Creates New Office of Competition and Innovation
- DFPI releases Notice Addressing Processing Delays for Debt Collection License Applications
- ALI Members Approve Restatement of the Law, Consumer Contracts
- Georgia Residential Mortgage Act Amended to Address Employing Felons
- Did You Know?
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Under Director Chopra’s leadership, the CFPB has regularly been sounding alarms about the potential for discrimination arising from the use of so-called “black box” credit models that use algorithms or other artificial intelligence (AI) tools. In the second of its recently-launched Consumer Financial Protection Circulars, the CFPB addresses ECOA adverse action notice requirements in connection with credit decisions based on algorithms.
The new Circular (2022-03) is intended to deliver the message that:
- ECOA/Regulation B adverse action notice requirements apply to all credit decisions, regardless of the technology used to make them.
- The fact that a creditor’s technology for evaluating applications is too complicated or opaque for it to understand is not a defense to noncompliance with adverse action notice requirements.
- It is a violation of the ECOA and Regulation B for a creditor to use algorithms or other technology if doing so makes a creditor unable to satisfy the requirement to provide a statement of reasons for adverse action that is “specific” and “indicate[s] the principal reason(s) for the adverse action.”
While the issuance of the new Circular allows the CFPB to issue a news release announcing that it is “act[ing] to protect the public,” the CFPB does not share any new information about the ECOA/Regulation B requirements in the Circular. Most notably absent from the Circular is any guidance that would assist creditors in meeting their compliance obligations. Indeed, in a July 2020 blog post, the CFPB acknowledged the challenges that the use of AI and algorithms creates for providing compliant ECOA adverse action notices.
In its news release about the new Circular, the CFPB renews its December 2021 call for tech workers to act as whistleblowers to report potential discrimination arising from the use of algorithms and other technologies. The CFPB has previously acknowledged the potential consumer benefits of AI and other technologies. We believe the CFPB could benefit both consumers and providers by providing guidance on how industry can best navigate the sometimes challenging compliance issues raised by new technologies.
In the absence of useful guidance from the Bureau, it is imperative that companies seek legal guidance so that they will be in a position to defend their approach to adverse action notices if challenged.
Strategy Includes Professionals Not Yet Covered by BSA
On May 13, 2022, the U.S. Treasury (Treasury) released its 2022 Strategy for Combatting Terrorist and Other Illicit Financing (2022 Strategy). The proposed 2022 Strategy, prepared pursuant to Sections 261 and 262 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), outlines four goals to address the key risks identified by the 2022 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments:
- Increasing transparency and closing legal and regulatory gaps in the U.S. Anti-Money Laundering /Combating the Financing of Terrorism (AML/CFT) framework exploited by bad actors;
- Making the AML/CFT regulatory framework for financial institutions more effective and efficient;
- Enhancing operational effectiveness in combating illicit finance; and
- Utilizing technological innovation to combat illicit finance risks.
The 2022 Strategy is incredibly broad, identifying 16 threats and vulnerabilities to the AML/CFT system as top priorities, and providing 14 separate supporting actions necessary to achieve Treasury’s four goals outlined above. This post summarizes the priorities outlined in the 2022 Strategy, and details the specific supporting action targeting financial intermediaries and gatekeepers not presently covered by the Bank Secrecy Act (BSA), such as investment advisors, lawyers and accountants.
Overview of 2022 Strategy
In its news release, Treasury stated that the 2022 Strategy “will assist financial institutions in assessing the illicit finance risk exposure of their businesses” and guide government agencies and policymakers in countering illicit finance. However, by making nearly every issue under the sun a top priority, the U.S. Treasury runs the risk of making it more difficult for these key players to identify where and how to focus their AML/CFT efforts.
Treasury noted that its 2022 Strategy reflects significant changes to the AML/CFT landscape since the onset of the Covid-19 pandemic, including: increased digitization of financial services; Covid-19 relief program fraud; a rise in ransomware attacks on municipalities and healthcare systems; and increased corruption highlighted by Russia’s full-scale invasion of Ukraine all informed the 2022 Strategy.
The 2022 Strategy identifies three to four supporting actions necessary to realize each of its goals (above), all aimed at addressing sixteen priority threats and vulnerabilities:
1. Misuse of legal entities
2022 Strategy for Sectors Not Subject to the BSA
One of four supporting actions Treasury pinpoints for achieving Goal 1 (increasing transparency and closing legal and regulatory gaps in the U.S. AML/CFT framework) is: assessing the need for additional action in sectors not covered by the BSA. Specifically, Treasury identifies investment advisers (including of private funds), “gatekeepers to the financial system” (which we’ve previously blogged on here, here, and here), high-value goods dealers, certain payment processors not subject to the BSA, and trusts, as potentially falling through gaps in the regulatory regime. The 2022 Strategy goes on to name lawyers, accountants, and Trust or Company Service Providers (TCSP) as possible gatekeepers who cannot be permitted to “evade scrutiny” for facilitating illicit financing. Yet, the 2022 Strategy’s wide range of possible interventions, from education and guidance to regulatory and enforcement actions, leaves open whether and to what extent these groups will be affected moving forward.
The 2022 Strategy does, however, layout a more tailored proposal for trusts. Despite noting “U.S. trusts are not widely used for money laundering,” Treasury states that legislation enabling the IRS to collect “targeted settlor and beneficiary information . . . for trusts with U.S. bank or investment accounts that do not generate U.S. source income” may promote a number of AML/CFT goals. Such legislation could deter trusts and TCSPs from being used to hide illicit proceeds, facilitate inter-jurisdictional sharing of tax information, and improve access to beneficial ownership information for foreign tax authorities.
Treasury ultimately laid out six 2024 Benchmarks for measuring progress in this arena. These standards collectively call for studying the actual risks of illicit financing activities among these groups not covered by the BSA, assessing the efficacy of the current AML/CFT framework at stopping such activity, and, where necessary, proposing strategies to more effectively mitigate these risks.
The CFPB has issued a new interpretive rule regarding the authority of state attorneys general and state regulators (State Officials) to enforce the Consumer Financial Protection Act (CFPA).
CFPA Section 1042(a) (12 U.S.C. Section 5552) authorizes “the attorney general (or the equivalent thereof) of any State” to bring “a civil action…to enforce the provisions of [the CFPA] or regulations issued under [the CFPA] and to secure remedies under provisions of [the CFPA] or remedies otherwise provided under other law.” It also authorizes “[a] state regulator” to bring “a civil action or other appropriate proceeding to enforce the provisions of [the CFPA] or regulations issued under [the CFPA] with respect to any entity that is State-chartered, incorporated, licensed, or otherwise authorized to do business under State law…and to secure remedies under provisions of [the CFPA] or remedies otherwise provided under other provisions of law with respect to such an entity.” Section 1042(a) includes limits on such authority, including with respect to actions against national banks and federal savings associations, and establishes conditions that a State Official must satisfy to exercise such authority, including notifying the Bureau before filing a CFPA claim and providing a description of the action. It also gives the CFPB a right to intervene in the state’s lawsuit.
In the interpretive rule, the CFPB describes the authority of State Officials under CFPA Section 1042(a) as follows:
- Because CFPA Section 1036(a)(1)(B) makes it unlawful for a “covered person” or “service provider” to “engage in any unfair, deceptive, or abusive act or practice,” State Officials can use Section 1042(a) to bring an enforcement action against a covered person or service provider that engages in unfair, deceptive, or abusive acts or practices.
- Because CFPA Section 1036(a)(1)(A) makes it unlawful for a “covered person” or “service provider” to “offer or provide to any consumer any financial product or service not in conformity with Federal consumer financial law,” State Officials can use Section 1042(a) to bring an enforcement action against a covered person or service provider for a violation of any Federal consumer financial law. In addition to the CFPA, “Federal consumer financial laws” include the 18 “enumerated consumer laws” listed in the CFPA and their implementing regulations, such as the Truth in Lending Act, the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, the Electronic Fund Transfer Act, and the Real Estate Settlement Procedures Act. (This authority is supplemental to any enforcement authority such laws give directly to State Officials or that State Officials have under state law.)
- Although the CFPA (in Sections 1027 and 1029) limits the CFPB’s enforcement authority as to certain categories of covered persons (e.g. motor vehicle dealers, attorneys, persons regulated by a state insurance regulator, persons regulated by the SEC or a state securities commission), those limitations generally do not apply to State Officials exercising their enforcement authority under Section 1042.
- State Officials can bring (or continue) actions under Section 1042 even if the CFPB is pursuing a concurrent action against the same entity.
The issuance of the interpretive rule follows remarks given by Director Chopra in December 2021 to the National Association of State Attorneys General (NAAG) in which he promoted an aggressive approach to enforcement by both the CFPB and state attorneys general. In his remarks, Director Chopra encouraged state AGs to bring actions under the CFPA and indicated that the CFPB planned to clarify “the wide variety of claims that states can bring under the CFPB’s statute.”
While many State Officials were likely already aware of their authority to bring unfair, deceptive, or abusive acts and practices (UDAAP) claims under Section 1042, State Officials have often used Section 1042 to bring UDAAP claims in lawsuits filed jointly with the CFPB. The interpretive rule could encourage greater use of Section 1042 by State Officials to bring UDAAP claims in enforcement actions to which the CFPB is not a party.
Two other aspects of the interpretive rule are potentially even more significant: the CFPB’s message to State Officials that they can use Section 1042 to bring UDAAP claims against entities that the CFPB would not be able to pursue for UDAAP violations (such as auto dealers carved out of the CFPB’s jurisdiction) and to bring claims for violations of Federal consumer financial laws. With regard to the latter, the CFPB appears to be opening the door for State Officials to bring Section 1042 actions for violations of Federal consumer financial laws that they could not enforce directly. For example, neither the Truth in Lending Act nor the Equal Credit Opportunity Act provide for enforcement by State Officials.
We note that the CFPB’s encouragement to State Officials to make greater use of Section 1042 carries some risk for the CFPB. While Section 1042 actions brought by State Officials could result in decisions that are favorable to the CFPB, it is also possible they could result in unfavorable court interpretations of the CFPA.
In addition to not mentioning the requirement for State Officials to notify the Bureau before filing a CFPA claim, the interpretive letter does not mention remedies. State Officials are likely to attempt to use Section 1042 to seek remedies under the CFPA that might not be available to them under state law or under a Federal consumer financial law. In his remarks to the National Association of Attorneys General (NAAG), Director Chopra suggested that a possible way for states “to get more out of the remedies available under the [CFPA]” was to seek civil penalties under the CFPA. As we noted at the time, that suggestion appeared to fly in the face of the plain language of the CFPA, which limits civil monetary penalties to scenarios where “(A) the Bureau gives notice and an opportunity for a hearing to the person accused of the violation; or (B) the appropriate court has ordered such assessment and entered judgment in favor of the Bureau.” Nevertheless, State Officials will likely attempt to invoke CFPA remedies when bringing Section 1042 actions.
The CFPB announced May 24 that as part of a new approach to innovation in consumer finance, it is replacing its Office of Innovation and Operation Catalyst with a new office, the Office of Competition and Innovation, and eliminating it’s No Action Letter (NAL) and Compliance Assistance Sandbox (CAS) programs. In its news release, the CFPB states that “[a]fter a review of these programs, the agency concludes that the initiatives proved to be ineffective and that some firms participating in these programs made public statements indicating that the Bureau had conferred benefits upon them that the Bureau expressly did not.” It also “encourages companies, start-ups, as well as members of the public to file rulemaking petitions to ask for greater clarity on particular rules.” According to the CFPB, this approach “will help level the playing field and foster competition by ensuring any actions the CFPB takes will apply to all companies in the market.”
In describing the work of the new office, the CFPB states that it “will focus on how to create market conditions where consumers have choices, the best products win, and large incumbents cannot stifle competition by exploiting their network effects or market power.” More specifically, through the new office (which will be housed in the CFPB’s Division of Research, Markets, and Regulation), the CFPB will:
- Explore ways to reduce barriers to consumers in switching accounts and providers;
- Look at market-structure problems that create obstacles to innovation (which could include a focus on the payment networks market or the credit reporting system, both of which the CFPB describes as “essential to our financial system but have only a few dominant players”);
- Look at how bigger players can gain advantage over smaller players (such as big tech companies which, according to the CFPB, “are also seeking new ways to join consumer finance markets and may threaten fair competition”);
- Through its Section 1033 rulemaking on consumer access to their financial data, address concerns that innovators may not be getting their products or services to market because they do not have access to digital data stored by the big banks; and
- Convene events at which entrepreneurs, small business owners, and technology professionals “will be able to collaborate, explore obstacles, and share frustrations with government regulators” and share the results of such events publicly.
Since the CFPB’s announcement does not address the status of previously issued NALs or approvals previously issued through its CAS program, we assume those NALs and approvals have not been withdrawn. It is curious that the CFPB calls the prior programs “ineffective” after having touted the success of the underwriting model that was the subject of a NAL issued to UpStart. In a blog post, the CFPB reported that results shared by UpStart showed that Upstart’s model using alternative data and machine learning approved 27 percent more applications than a traditional lending model and yielded 16 percent lower average APRs. According to the CFPB, the expansion of credit access reflected in the results occurred “across all tested race, ethnicity, and sex segments” and “significantly expand[ed]” access in “many consumer segments,” such as “near prime” consumers, applicants under 25 years of age, and consumers with incomes under $50,000.
We presume that the CFPB’s preference for rulemaking petitions is meant to encourage companies to use the new process for submitting such petitions that the CFPB announced in February 2022. In the CFPB’s history, only one rulemaking petition has been granted. That petition was filed by the Bank Policy Institute and the American Bankers Association seeking rulemaking by the CFPB to codify the “Interagency Statement Clarifying the Role of Supervisory Guidance” issued in September 2018. In response to the petition, to codify the Interagency Statement, the CFPB issued a proposed rule on the role of supervisory guidance which was finalized in January 2021. As that rulemaking evidences, rulemaking is typically a slow-moving process.
In an announcement to its subscribers sent electronically on May 23, 2022, the California Department of Financial Protection and Innovation (DFPI) notified applicants – and prospective applicants – for a license under California’s Debt Collection Licensing Act (the Act) that changes mandated by the Federal Bureau of Investigation (FBI) to state agency protocols for requesting federal background checks have caused “unforeseen” and unavoidable processing delays.
By way of background, the Act became effective September 25, 2020, with a licensing component that became operative on January 1, 2022.
The Act requires any person engaging in the business of debt collection in California to be licensed annually by the DFPI.
The DFPI previously announced that it would permit applicants who submitted a completed application before the operative date to continue engaging in licensable activity while their applications were processed, even if the DFPI had not approved or denied such applications. Correspondingly, applicants who did not submit an application by December 31, 2021, would have to wait until their applications were approved in order to engage in licensable activity.
The Act requires a person applying for a license to, among other things, submit to a criminal background check by the Department of Justice. In relevant part, the Act expressly provides that
[w]hen received, the Department of Justice shall transmit fingerprint images and related information received pursuant to this section to the Federal Bureau of Investigation for the purpose of obtaining a federal criminal history records check. The Department of Justice shall review the information returned from the Federal Bureau of Investigation and compile and disseminate a response to the commissioner. (Cal. Fin. Code 100008(b).)
According to the announcement, the FBI notified the DFPI that “changes are needed to state agency protocols for requesting federal background checks.” The announcement did not elaborate on the nature or scope of those changes, nor did it provide a timeline for resolution of the delays in processing Debt Collection License applications.
Importantly, the DFPI specified in its announcement that it will take a no-action position for applicants that submitted their applications after December 31, 2021, permitting such persons to continue engaging in otherwise licensable activity without a license. However, the DFPI recommended that, for purposes of complying with provisions of the Act that require displaying a license number when contacting or communicating with debtors, license applicants “may indicate ‘license number pending’ or similar verbiage until a license is issued.”
The DFPI encouraged prospective licensees to continue submitting applications through NMLS, and advised that it will reach out to applicants with instructions for the submission of fingerprints for background checks when the process becomes available.
As expected, the American Law Institute (ALI) approved the Restatement of the Law, Consumer Contracts yesterday at ALI’s 2022 Annual Meeting in Washington, DC. The Restatement sets forth a series of rules that are intended to represent the current black letter law for contracts between businesses and consumers and culminates an 11-year project by ALI on the subject.
Discussion of the Restatement kicked off day two of ALI’s meeting, with a briefing on significant changes to the tentative draft from the 2019 Annual Meeting and then comments from ALI members in attendance on the topics covered in the Restatement. Following discussion, the draft was approved with minor technical changes that will be made to the official text for publication.
More discussion regarding the Restatement can be found here as well as in this week’s Consumer Finance Monitor Podcast episode with Ballard Spahr’s Alan Kaplinsky (who is on the ALI Board of Advisers to the new Restatement) and special guest Steven Weise from the ALI Council.
Governor Brian Kemp signed SB 470 into law on May 2, 2022 (the Effective Date), amending the provisions of the Georgia Residential Mortgage Act, O.C.G.A. §§ 7-1-1000 et seq., that prohibited a Georgia mortgage lender or mortgage broker from employing any person with a felony conviction. The enactment of SB 470 is a major step towards resolving a long-time issue within the mortgage industry by significantly reducing the burden for Georgia mortgage lenders and mortgage brokers to monitor their employees’ felony convictions on an ongoing basis and avoid a license application denial or license revocation.
Prior to the Effective Date, O.C.G.A. § 7-1-1004(h) expressly prohibited a Georgia mortgage lender or mortgage broker from employing any person that had a prior felony conviction. This provision stated, in relevant part:
The department shall not issue or may revoke a license or registration if it finds that the mortgage loan originator, mortgage broker, or mortgage lender applicant or licensee, or any person who is a director, officer, partner, agent, employee, or ultimate equitable owner of 10 percent or more of the mortgage broker or mortgage lender applicant, registrant, or licensee or any individual who directs the affairs or establishes policy for the mortgage broker or mortgage lender applicant, registrant, or licensee, has been convicted of a felony in any jurisdiction or of a crime which, if committed within this state, would constitute a felony under the laws of this state (emphasis added).
The terms “agent” and “employee” were not defined in O.C.G.A. § 7-1-1000; however, the Georgia Department of Banking and Finance (the Department) interpreted these terms to include anyone employed by the licensee/registrant, irrespective of whether they engaged in Georgia residential mortgage business on behalf of the licensee/registrant or otherwise maintained contact with Georgia borrowers (i.e., custodial staff, mailroom employees, office services, etc.). As anyone in the industry will note, O.C.G.A. § 7-1-1004(h) had a significant impact on a Georgia Mortgage Lender Licensee/Registrant’s ability to do business. O.C.G.A. § 7-1-1004(h) not only burdened licensees/registrants with actively monitoring felony convictions for all employees on an ongoing basis, but it also subjected to licensees/registrants to severe penalties if they inadvertently employed someone with a prior felony conviction. The Department had the authority to deny a license or revoke a license for a Georgia mortgage lender or mortgage broker for such an error, which are reportable events that require the licensee/registrant to update its answers to its Disclosure Questions and provide a corresponding Disclosure Explanation to resolve. As a result, the provision had a widespread impact on licensees/registrants that extended well beyond the borders of the State of Georgia.
Moreover, Georgia’s historical prohibition on employing individuals with prior felony convictions has been “out of step” with the same requirements under the federal Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act). Under the SAFE Act, only a mortgage loan originator (MLO) is required to submit to a criminal background check, and the MLO would only be considered ineligible for licensure if s/he is found to have been convicted of a felony involving dishonesty, breach of trust, or money laundering against the employee or organizations controlled by the employee, or agreements to enter into a pretrial diversion or similar program in connection with the prosecution for such offenses within seven years of the criminal background check. The Department’s historical interpretation of O.C.G.A. § 7-1-1004(h) raised the bar for Georgia mortgage companies, requiring all employees to submit for criminal background checks and penalizing the mortgage company if any employee has been convicted of any action that would be considered a felony under the laws of Georgia at any time in his/her life.
Georgia legislators introduced SB 470 to course correct for this long-standing issue. It was met with overwhelming support in the Georgia House of Representatives (142 to 1) and Senate (47 to 1). In short, SB 470 permits Georgia mortgage lenders and mortgage brokers to employ convicted felons if such employees are not involved in certain mortgage loan-related activities. As of the Effective Date, O.C.G.A. §7-1-1004(h) provides:
The department shall not issue or may revoke a license or registration if it finds that the mortgage loan originator, mortgage broker, or mortgage lender applicant or licensee, or any person who is a director, officer, partner,
agent, covered employee, or ultimate equitable owner of 10 percent or more of the mortgage broker or mortgage lender applicant, registrant, or licensee or any individual who directs the affairs or establishes policy for the mortgage broker or mortgage lender applicant, registrant, or licensee, has been convicted of a felony in any jurisdiction or of a crime which, if committed within this state, would constitute a felony under the laws of this state (emphasis added).
O.C.G.A. § 7-1-1000 also includes the following definition for a “covered employee,” limiting the scope of employees to which this provision applies:
“Covered employee” means any employee of a mortgage lender or mortgage broker who is involved in residential mortgage loan related activities for property located in Georgia and includes, but is not limited to, a mortgage loan originator, processor, or underwriter, or other employee who has access to residential mortgage loan origination, processing, or underwriting information.”
Also of note, O.C.G.A. § 7-1-1004(i) provides for an alternative definition of “covered employees,” defining such persons as “employees who work in this state and also have the authority to enter, delete, or verify any information on any mortgage loan application form or document.” It is not clear from the amended laws which definition governs and, to the extent that two definitions of the term exist, when each such definition applies.
Although this is a significant step forward in reducing the regulatory burden on Georgia mortgage lenders and mortgage brokers, this is not a perfect solution to the problem. Further legislative changes need to be made to clarify the types of employees that constitute “covered employees” and bring the Georgia Residential Mortgage Act completely in alignment with requirements under the federal SAFE Act. Amended O.C.G.A. § 7-1-1004(h) generally limits the scope of the provisions applicability to those involved in mortgage-related activities and, ostensibly, the scope to those employees located in Georgia that have the authority to enter, delete, or verify any information on mortgage loan applications and documents; however, the amended laws can also be read to prohibit Georgia mortgage lenders and mortgage brokers from employing individuals with felony convictions if they have “access to residential mortgage origination, processing, or underwriting information.” It remains to be seen how far the Department will extend the scope of this provision’s applicability. For example, if a mailroom employee of a Georgia Mortgage Lender Licensee/Registrant could open up a package from a Georgia borrower that contains a residential mortgage loan application, then the Department could require the licensee/registrant to ensure that the mailroom employee does not have a prior felony conviction or else be subject to revocation of its license. What is more, amended O.C.G.A. § 7-1-1004(h) and the new definitions of “covered employee” in O.C.G.A. §§ 7-1-1000 and 7-1-1004(i) do not limit the types of felony convictions or the timeframe during which a felony conviction occurred in any meaningful way. Georgia mortgage lenders and mortgage brokers remain liable for employing any “covered employee” that has a prior conviction that would constitute a felony under Georgia law at any point in his/her life.
The practical impact of the amended laws should not be minimized. As of the Effective Date, Georgia mortgage lenders and mortgage brokers can rest a bit easier knowing that they will not be subject to the Department’s scrutiny if employees with prior felony convictions – arguably, only those that are located outside of Georgia – do not engage in the activities of a “covered employee” for Georgia loans and do not have access to information relating to Georgia loans. Nevertheless, we await further guidance or rulemaking from the Department that clarifies what constitutes a “covered employee” and limits the scope of felony convictions covered under the law.
Wyoming Collection Agency Board Certificates of Exemption Process Terminated
The Wyoming Collection Agency Board (Board) has terminated its Certificate of Exemption process, through which entities were permitted to determine whether or not they were required to obtain licensure by answering a series of questions.
The Board determined that it lacked statutory authority to issue certificates of exemption and that such certificates had no legal relevance.
On March 16, 2022, the Board clarified that it will not recognize previously issued certificates of exemption.
A copy of the Collection Agency Board notice is available here.
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