Alice was interested in an article she had found whilst waiting for her dental appointment. It was titled: ‘The End of Instability, Opacity and Risk in the Global Financial Market – A Pipedream?’
Reading through the article Alice drifted off into a dreamlike state…
Alice had no real intention of visiting Financial Regulatory Land. It was just that she knew she had money tied up in pensions, ISAs and other investments and wanted to be sure any proposed rules and regulations would make her investments safe.
The article she had read raised a number of things that were concerning Alice. With this in mind she set off to find answers to the many questions that were racing through her head. Where better to find her answers than the Financial Regulator’s tea party. She wasn’t too sure why she would find answers to her questions here but remembered registering for something online.
“Why are you here?” said the MadHatter, who was seated around a large table with the March Hare and the Dormouse.
Puzzled by her surroundings, Alice replied, “I was led to understand that you would be able to reveal all about the initiatives that will be in place to avoid a future meltdown in the Global Financial Market”.
“You’ve certainly come to the right place. Please take a seat and make yourself comfortable. Cup of tea?” said the March Hare.
As she was making herself comfortable the Mad Hatter said, “Where would you like to start?”
“I understand that the problem with the financial system was global in nature and I am interested to hear what the global solution is going to be”, replied Alice.
“Well,” said the Mad Hatter, “Let’s start at the beginning. You see, it all came to pass in 2008 when …”
Alice interrupted, “Stop please! All I read about is the crisis in 2008. In reality it means nothing to us mere mortals. I would just like to hear what global solution will be in place to prevent anything untoward happening in the future”.
“In that case,” said the Mad Hatter, “We should look at the pillars that are being built to make sure nothing of this nature happens again”.
“The first pillar is to do with the unique legal entity identifier that is being introduced globally” said the Mad Hatter clearing a space on the table. “Think of this cup and saucer as the LEI pillar on which other pillars will be built.”
“How does this work?”inquired Alice.
“Let me explain,” said the Mad Hatter. “It was thought, for a long time, that there needed to be a mechanism in place that uniquely identified all Financial Institutions throughout the world.”
“Really?” said Alice.
The Mad Hatter, sensing some sarcasm, continued; “This came to the fore, after er… 2008 and has resulted in the LEI system, which will facilitate aggregation and analysis of trade data across all financial market participants. This system will remove the opacity and uncertainty around risk and exposure in derivative trades by financial counterparties.”
“A truly standardised global system?” inquired Alice.
“Not quite,” said the March Hare, “Due to timescales imposed by the Dodd-Frank Act, for the reporting of swap trades, the US Commodity and Futures Trading Commission were mandated to plough on way before the global LEI was agreed and put in place.”
“Umm!” said Alice “So the unique LEI system is based on the US one?”
“Not really,” said the March Hare. “The globally agreed LEIs have a Local Operating Unit identifier in the first 4 characters and this is numeric and unique. Unfortunately, the US solution is different and the first 4 characters are alphabetic, therefore all historically created LEIs on the US LOU will not follow the globally agreed implementation ofISO 17442. It’s not clear if the US LEIs will be brought into line as they are deeply imbedded in financial systems and trade repositories. At the moment we have a system of pre-LOUs in place. I know, don’t ask.”
“Sounds unnecessarily complicated,” interjected Alice.
“But think of it like football. The US plays the same game as the rest of the world but they call it soccer!” said the Mad Hatter.
“But if one regulator implements something before a global standard is put in place wasn’t there always a risk involved?” enquired Alice.
“Well quite,” said the March Hare.
“It’s a marathon, Alice,” said the Mad Hatter impatiently. “Some runners set off at a sprint and others catch up later.”
“That’s OK,” said Alice. “But wouldn’t it have made more sense if everyone left the starting blocks at the same time? I guess that as long as they all pass the same finishing line it might be OK.”
“This has been thought about and we now have a globally agreed governance structure in place under the Financial Stability Board that will oversee the global LEI system. Hopefully, all these little issues will be ironed out by the regulatory oversight committee managing the global legal entity identifier foundation who will be guiding the central operating unit who will be working with the local operating units around the globe. Until then we will have a system of pre-LOUs,” said the March Hare.
“But isn’t the running of the LEI system based on a federated approach?” said Alice. “Surely this could lead to duplication and quality issues when all the data comes together and what will happen when something like a merger or takeover occurs?” Alice was recalling the fact that she had read an article about this very recently.
“We won’t know until the fully working system is in place and this is some way off,” the March Hare replied.
The Mad Hatter announced, “All will be working perfectly once there is a central repository in place. Did you know that over 300,000 legal entities have registered across the world so far? There are also sites emerging to show consolidated LEIs. For example,the following p-lei.org, c-lei.org and g-lei.com allow anyone to download a consolidated list of LEIs. Let me ask the Dormouse to explain.”
The Dormouse had gone to sleep.
“So, all the data is in the same format” Alice thought out loud.
“Not quite,” said the March Hare. “Unfortunately there isn’t an agreed standard schema. This means that the data has to be mapped to some extent although the contents remain the same. There are exceptions, one being that where the full country name is used by the LOUit is converted to the two character ISO 3166 code.Another one is to do with the conventions for the LEI status, which have not yet been agreed and therefore some transformation must take place.”
“Also,” said Alice. “Isn’t it true that FATCA, amongst others, require legal entities to register using completely different numbering systems? Like the global intermediary identification number?As I understand it one of the issues before was not being able to readily identify all the legal entities of Lehman Brothers that were involved in trading, what turned out to be suspect investments. And hence what the company’s total exposure was. Will the LEI record hold the unique identifier of the business hierarchy or at least the LEI of the business entity? I feel this is important.”
“Dormouse, Dormouse!” shouted the Mad Hatter in some despair, but there was no response.
“Is it true that the LEI itself doesn’t readily identify the legal entity and therefore the name supplied to the LOU is very important?” queried Alice, sensing a problem or two.
“Yes,” said the March Hare. “But the names will be in the local language, including character based ones. This may make it hard to confirm the correct LEI for the counterparty.”
“DORMOUSE!” implored the Mad Hatter but the Dormouse appeared to be in a world of his own.
Given the lack of a response, Alice asked,“But how does the LEI help?”
“It is one part of the global regulatory jigsaw puzzle and this brings us to the next pillar which is to do with the reporting of derivative trades to a trade repository,” said the Mad Hatter placing another cup and saucer on the first causing the construction to appear less than solid.
“And the unique trade identifier?” added the March Hare.
“That makes sense,” said Alice.
“It should,” said the March Hare. “But there are some complications with it. The globally agreed proposal is for a UTI based on a 10 character prefix and using characters 7-10 of the LEI followed by a uniquely generated transaction identifier. You see the CFTC in the US jumped the gun again by creating the USI.”
“The USI?” said Alice.
“The USI is the unique swap identifier and it is mandatory for all financial institutions registered with the CFTC and trading in swap derivatives,” continued the March Hare. “Furthermore, the 10 character USI bears no resemblance to the globally proposed UTI.”
“Oh,” said Alice. “This sounds very confusing. How will this be resolved?”
“Simple. If the counterparty usesthe USI format, even if not reporting a particular trade to the CFTC, then they should use a USI. Otherwise they should use the UTI as clarified above,” explained the March Hare. “Furthermore, the EU countries have their own trade repositories. But whereas in the US only the seller is required to post the trade, in the EU both parties have to report the same trade. In addition, there is no global agreement on the type of trade to be reported.”
“Oh, a federated system again!” shouted Alice in frustration. “But could this lead to a high level of mismatches when the data is consolidated? Not to mention the quality issues.”
“This is true” said the March Hare “some evidence suggests a very low matching rate to date. The hope is that this will improve”.
“And will there be a central repository of all derivative trades carried out around the globe?” enquired Alice.
“This is probably not going to happen in the short term, if ever, as each jurisdiction will want to maintain its own vested interests. Sharing data wouldn’t be seen as a positive thing and there may be local data protection laws to consider,” said the March Hare.
“Vested interests?” exclaimed Alice“but what does that mean?”
“It means,” said the March Hare. “That the regulators will use organisations in their own jurisdiction to facilitate the regulations being enacted, whether for LEIs, trade repositories or central clearing. Hence, any solution will be federated, even in the EU. It also means they can look out for the financial institutions in their jurisdictions. If you like, all for one and that one’s me!”
“Again, a federated system to deal with a global problem,” exclaimed Alice. “But how will we know the total global exposure of each financial institution if each trade repository only holds trades made in its own jurisdiction?”
”The federated approach has already been agreed upon and accepted by the G20 nations,” said the Mad Hatter. “There’s really no prospect of going back.”
“Even at the expense of global financial stability and transparency?” worried Alice out loud.
“You need to look at the regulatory reform as work in progress. If something is not working then it can be corrected or at the very least obfuscated,” said the Mad Hatter.
“And what about dark pools?” said Alice. “One of the main tenets of the regulations was for transparency. I understand that dark pools defeat the very purpose of a transparent market. Will dark pools be subject to the same regulations?”
“Oh, Alice, you read far too much for your own benefit,” said the Mad Hatter. “Rest assured that that the G20 governments and their regulators have employed the finest minds in financein order that the world at large has no need to worry – about anything.”
“Butwill those minds be looking after any vested interests?” said Alice.
“Umm,” said the March Hare. “This is more than likely.”
“There’s more to come. You really need to look at the whole regulatory pie,” said the Mad Hatter as Alice fidgeted in her chair looking as if she was about to leave. “You must stay.”
“But so far the pie looks undercooked to me,” replied Alice. “This is all very confusing and we only seem to have scratched the surface,” said Alice looking concerned. “I really must be going.”
“We haven’t talked about the third pillar – central clearing. Not to mention collateral management, MiFID, AIFMD, FATCA, GATCA, Basel III, Solvency II, UPI, HFT, SEFs and much, much more,” said the Mad Hatter.
“What’s central clearing?” asked Alice watching the Mad Hatter place the third cup and saucer gingerly on top of the other two.
“Let me explain about central clearing,” said the Mad Hatter, wanting toappear knowledgeable. “You see,all standardised OTC derivative contracts will be processed through central clearing parties. These parties will be responsible for settling the trade on behalf of both the seller and buyer sides. This should bring stability to the financial markets in the future as these contracts will no longer be bi-lateral.”
“Is there a risk with this approach?” wondered Alice out loud.
“The biggest concern is that the relatively small number of central clearing counterparties will become too big to fail. You may remember some banks were deemed as such during the crisis and were bailed out by governments around the globe,” said the Match Hare.
“Nonsense,” said the Mad Hatter. “This has all been thought through in detail. And, don’t forget all these trades have to be reported to the appropriate trade repository as well”.
Alice was eager to push forward with something she had read. “I was reading an article that said the financial crisis was caused by unscrupulous traders selling collateralised debt obligations and mortgage backed securities. These products bundled together mortgages designated as sub-prime because the people taking them on would likely default if there was any turmoil in the housing market. The housing market crash in the US brought the lot down like a house of cards. I don’t pretend to understand this at all but it also said that the buyers of these securities had poorly performing or non-existent risk assessment functions and this all happened within a regulatory-lite framework,” said Alice, keen to understand as much as possible before she left.
“I wanted to know if these types of transactions are covered by central clearing?” continued Alice. “And will not cause another crisis.”
“Oh no!” said the March Hare. “These transactions are referred to as structured products. They are not in scope of any of the regulatory reforms taking place.”
“So,” said Alice. “It could all happen again even though millions of dollars have already been spent and millions more yet to be spent by financial institutions.”
By now the cups and saucers were beginning to look like the leaning tower of regulation and Alice felt that one small tremor was all it needed to come crashing down. The March Hare had already sought sanctuary under the table. Even the Dormouse was stirring, sensing that all was not well.
The Mad Hatter noticed the wobbling structure and was urgently trying to interject and said, “You mustn’t believe all you read Alice, this is all very complicated and that is why the regulators want to get it right.”
All this time it had been quite plain to Alice that the regulators knew nothing about designing and implementing a global solution for a global issue. As for all their obfuscation, well Alice didn’t care.
“Sorry,” said Alice. “But I have to return to the real world”.
Before the Mad Hatter had a chance to speak Alice disappeared, she seemed to be in a hurry.
“Wake up, Alice, wake up,” said the nurse gently shaking her. “The dentist is ready for you now.”
Startled, Alice awoke from her dream only to realise that she hadn’t returned to the real world. She had been in it all the time. Furthermore, she now understood that getting meaningful information from the financial regulatory bodies would be harder than pulling teeth.
It was clear that this whole business of bringing stability, transparency and a risk-free global financial system was not going to be a tea party!
She promised herself that, at the earliest opportunity, she would liquidate all her assets and place them under her mattress. She knew it made sense.
Corporate treasuries under pressure need multi-banking trade finance technology
By Andrew Raymond, CEO, Bolero International
The pressures on corporate treasuries in global trade have continued to mount since an HSBC survey last December found many felt ill-equipped to meet the demands placed on them.
Since then the pandemic has caused massive disruption and has overturned many carefully-laid plans. The same pressures identified in the survey remain, but have intensified. Treasurers still face ever-more complex flows of information from multiple systems while relying substantially on manual processes. At the same time they are expected to drive change and provide strategic insight.
It was no surprise then that two-thirds of treasurers in the survey were planning changes to the technology they used as part of transformation programmes to increase efficiency and bring greater visibility to treasury operations.
Reliance on manual methods and paper documents makes little sense and is unsafe
As we move through the pandemic, pressure on cashflow and working capital remain potent factors. Many treasurers working for enterprises engaged in global trade know that continuing to use manual methods to manage credit lines, and important trade finance instruments such as letters of credit (LCs) or guarantees is hard to justify in an age of digitisation and multi-banking trade finance solutions.
Not least because of the constant problem of fraud and forgery in relation to paper documents, which has led some banks to withdraw from involvement in commodity trade finance. The allegations of prolonged major fraud against the oil trader Hin Leong in Singapore are a case in point, sending tremors through the trade finance world. Court documents reportedly allege the fraudulent use of 58 import letters of credit that were not supported by any underlying transaction. Forged bank statements, bills of lading, sales contracts and invoices are also allegedly involved in very substantial fraud designed to cover losses and give a false impression of liquidity.
The case has not just exposed the susceptibility of paper trade documentation to forgery – it has also prompted some well-known European long-term commodity finance banks to withdraw or review their activities in this field. None of this makes everyday operations any easier for corporate treasuries still using paper in trade finance.
Reducing fraud through digitisation of trade finance
With fraud such a substantial problem, treasurers need to think hard about digitisation and how it reduces the risks. Paper documents can be forged when out of sight while being couriered around the globe. Once a document is digitised, however, fraud or forgery become extremely difficult because of encryption and audit trails. The electronic document remains completely visible at all time, but only to those engaged in the transaction and only the legitimate holder can amend it.
Increasing the efficiency of each trade transaction through digitisation
Digitisation substantially reduces the chances of fraud, but it also transforms how treasuries manage credit lines, letters of credit and guarantees, vastly increasing the speed and efficiency of transactions. It also maintains relationships with preferred banks.
In a digitised workflow, automation takes care of the data-uploading for LCs, while transfer between parties is at the click of a mouse across secure digital networks. LCs are notoriously complex instruments requiring close attention to detail and strict compliance with the rules governing their use. Compliance-checking can also be automated to reduce the administrative burden on treasuries and increase accuracy.
These advantages are important because the use of paper under LCs can imperil a transaction at many potential break-points. Documents must be presented physically, often to a prescribed location. Yet being time-limited, LCs (and bank guarantees) often expire before they are used, or their presentation periods are found to have been exceeded. Prevention of these problems requires constant supervision and many hours of work. When lines expire, new and potentially more expensive credit must be negotiated, while failure to present on time threatens transactions, leads to substantial extra costs, delays in releasing cargo and poor relationships between counterparties.
Consolidating credit lines and trade finance on a single, easy-to-use platform
The most effective form of digitisation for corporate treasuries is through a multi-bank trade finance platform which will slash the time involved in supervising credit lines, LCs and guarantees. An exporter may have thousands of LCs and guarantees with dozens of different banks. Optimising their use still requires laborious logging in and out of banking portals. Finding a single LC or guarantee relating to a transaction can be very difficult.
If treasuries implement multi-banking trade finance solutions, they will eliminate the need to toggle between different bank portals. They gain quick and easy access to all their banks, along with far greater visibility and control of all their credit lines and individual LCs. From a single platform they can manage and edit all their trade finance documentation and electronic presentations, as well as open account transactions and electronic bills of lading. All tracking and reporting is accomplished with a few mouse-clicks, while communications with banks remain secure. This is a major advantage when remote working is on the increase in so many areas of the globe.
As the world changes, but the pressures intensify, there is an urgent need for treasuries to grasp greater efficiency and visibility in their management and optimisation of credit lines and trade finance. It makes the adoption of multi-banking trade finance solutions an obvious first move.
How can financial services companies deliver great customer service and retain customer loyalty?
By Chris Angus, Senior Director, 8×8
The reality many banks are facing now is that given Amazon Prime can deliver goods to our doors in less than 24 hours, even during a pandemic, consumers expect the banks they use to keep up with their needs.
People want to be able to access their bank accounts, services and speak to an expert within a matter of minutes, whether it’s via an app on their device, web-chat or over the phone – their expectations are high. Adding to this, the World Health Organisation has advised consumers to use cards instead of banknotes during the Covid-19 pandemic – changing the way consumers pay for products.
With the recent health crisis forcing contact centres to shift to home working, collaboration can be more challenging, especially without the appropriate IT systems and applications in place. A delay in communication or unavailable information can, over time, cause reputational damage.
According to Deloitte, the bank of 2023 will look very different from today, making it clear that financial institutions should consider how they prepare for the future.
- Review your business communications strategy – both inside and out.
A crucial part of this preparation needs to be on reviewing business communications – both internally and externally – ensuring that employees can seamlessly collaborate and connect regardless of their location.
And technology is key to this movement, not only between teams, but also with customers. With the right communication tools in place, employees can gain better insight and deliver services that meet customer expectations. This results in not only satisfied customers, but also happier, and more motivated employees. All of which goes towards truly building a solid foundation for business recovery and continuity.
For many businesses right now, the future feels uncertain, so it’s important to consider the flexibility of solutions before deployment. Cloud computing, for example, allows businesses to stay nimble, scaling up and down their requirements to reflect the needs of the business and their customers.
- Implement an ‘Operate from anywhere’ strategy
The first half of 2020 was defined by the need for agility, an adjustment in how we operate our day-to-day lives and how we communicate both professionally and personally. The remainder of 2020 and beyond will focus on the application of technology to define how we reinvent working and connecting with each other, our customers, partners, and beyond.
To deliver great customer service, while ensuring employees are happy, productive and most of all safe, businesses need to be able to operate from anywhere. Yet, for many with contact centre requirements, this is not an easy transition. Enabling contact centre agents to work flexibly and from remote locations is now a critical component of business operations that must be top of mind for the entire C-suite.
Agents need to have the right tools to ensure they can continue to provide the same level of customer service, from any location. For an operate-from-anywhere strategy to be effective, organisations should consider how they can combine voice, team chat and video meetings on a single technology platform.
The use of multiple apps for multiple purposes can have the opposite effect than intended. Unifying communication channels enables collaboration and productivity while minimizing complexity. It also means a more streamlined and efficient experience for both employees and customers aiding great customer service.
- Meeting expectations is key
Not only have recent events affected contact centres operations, but the traditional, in-person branch experience has also been significantly impacted. Bank branches can now only accommodate a small percentage of customers. These restrictions have accelerated the impetus for businesses to meet their customers’ needs online, but also, the expectations of customers have also evolved rapidly. Virtual instant communication between businesses and consumers is now becoming a basic customer need. For financial services, this means considering digital-first applications, such as chatbots or instant messaging, where possible.
Businesses now also need to be where their customers are and offer them an omnichannel experience. Via the cloud, businesses can continue to serve customer needs through multiple channels such as voice, video, email, SMS and more.
While meeting expectations needs to be a priority – it’s not enough. Financial services institutions need to ensure they meet those expectations at speed, being the new battleground for competition. When it comes to finances, consumers expect their problems to be dealt with at speed and to the highest standards.
In summary, taking a technology-first approach which enables both employees and consumers to operate and access their data and communication tools from anywhere is the defacto business priority. Helping the financial services industry empower employees to better serve customer expectations with speed and accuracy – and ultimately delivering great customer service.
How payments can help streamline operations and boost customer satisfaction in the vending industry
By Darren Anderson, Business Development Manager, Self Service, Ingenico Enterprise Retail
The COVID-19 pandemic has had an astounding impact on the payments industry, causing cash usage to plummet as contactless and card-not-present volumes soared. Of course, this phenomenon was not unforeseen by payments professionals, who had predicted such a movement away from cash, but not at the speed the virus guidelines facilitated. In fact, due in part to the hygiene perks of contactless payment methods increasing its adoption, 50% of customers think that cash will disappear completely at some point in the future.
The unattended market was ahead of the pandemic in terms of contactless alternative payment method (APM) adoption, and it continues to upgrade its offerings to suit a wider range of industries. Nevertheless, the pain point for vending operators is that they’re often not sure exactly how these technologies work, or how to implement them. And with payments offerings constantly evolving, it’s becoming harder for vending operators to know which solution would be the best fit for their business.
As such, one easy way for vending operators to ease this load is to partner with a knowledgeable payments advisor who can not only provide the best solutions for their business, but guide them through the process and any need-to-knows. It’s also important to investigate the payments trends across the vending market, what the future might bring and what vending operators need to know about newer payments technology and the value it can bring to their unattended retail business operations.
Vending through the pandemic
Coronavirus has impacted the unattended market in various ways. In some cases, vending machine use has decreased as a result of lower footfall and closed premises. However, the nature of vending being self-service, for many it’s just been a case of upgrading systems to meet new guidelines and hygiene recommendations to start boosting their usage again. As cash usage decreased over the course of the pandemic, cards and APMs stepped in to provide a host of benefits, and as customers use and enjoy these seamless technologies, they are fast becoming the preference.
These developments have provided the opportunity for vending operators to embrace newer technologies which, although ultimately positive, can prove daunting if such retailers are not accustomed to working closely with payments. Fortunately, the vending market is in a great position to take advantage of new contactless technologies, being already low on human interaction and having 24/7 capabilities.
What’s more, the market can not only cater to consumers’ evolving needs, but it can also provide the flexibility and reliability that consumers are relying on as the world around them is changing. Many new technologies can also improve the general operations and management of vending, offering features such as easier on-the-go stock management and maintenance notification technology.
Keeping the consumer in mind
Consumers today want to enjoy the latest innovations and best-in-class customer experiences. These shoppers believe that self-service is a time-saver, and they also view cashless and contactless as faster and more seamless ways to pay – a fact which is reflected in the recent consumer demand for a wider variety of APMs. Customers now expect even more options to pay for their goods and services, from QR codes, to in-app payments and more.
Alongside the cashless trend, data-security and customer experience are two other factors driving the vending market evolution. With constantly evolving fraud developments in the online world, good security is more pertinent than ever, and has to be a central consideration to vending operators – as well as ensuring a seamless customer experience.
From a customer usage standpoint, mobile payments are becomingly increasing popular, as driven by the Gen Z market. According to our research, 63% of Gen Zers have said they would pay more for a mobile experience.
Trust and a good experience are also considerable factors across all customer groups, with 95% of customers claiming their loyalties lie with a company they trust, and 86% willing to pay more for a positive experience.
To appeal to ever-hungry consumers, vending operators need to provide the options they want. In the unattended market, this is relatively simple – not only do they provide a convenient and reliable method of payment for customers, but they also avoid face-to-face interaction. They can also supply a range of different products and accept a variety of payment methods to appeal to all customers, no matter their preference.
Using payments to drive revenue
Driving revenue is a two-pronged approach – you need to appeal to customers to keep them coming, and streamline operations to reduce overheads. In order to meet both parties’ expectations, it’s important to respond well to new vending challenges, taking note of the solutions that enable merchants to provide their customers with the payment methods they prefer.
Payments are complicated, so there’s no need to worry if you’re not hugely familiar with the offering out there, or unsure where to start – that’s where a payment service provider (PSP) can assist. With the expertise that a PSP brings, along with the technological solutions they offer, vending operators can improve customer journeys in all unattended environments.
Such technological solutions are flexible and can cater to specific business needs, while providing easy, quick, and secure payment methods that protect both the business and the customer’s personal data. They can also improve operational efficiency, increasing business performance with features such as real-time reporting and smart transaction management, to provide a best-in-class customer experience.
With smart devices, a secure gateway and advanced acquiring capabilities, PSPs can help vending operators design a flexible vending solution tailored to their individual and specific needs. To find out more about unattended retail and how your company can benefit from Ingenico’s unique expert knowledge, get in contact with Ingenico Enterprise Retail today at www.ingenico.com/smartselfvending.
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