Transcript for HODLCast Ep. 114 with Amber Scott discussing Global stablecoin Regulation



Sasha:

Hello everyone! Welcome to the HODLCast. Today is May 1st, and we have a very special guest, Amber Scott, the CEO of Outlier Canada, and a good friend. Amber, thank you so much for taking the time out today. How you doing?


Amber:

Pretty good! All things considered. I can't complain.


Sasha:

Excellent! So our agenda today is to go through the G20 recent guidance or recommendations that they made on the stable coins. And I know last year we talked about the FATF guidance and you're always my go-to when new regulations come out. I love talking things through with you ‘coz you always have a really good insight to it. So thank you again. First off, how has the quarantine impacted Outlier Solutions. And maybe, you could tell us a little bit just of your background and what Outlier is, and what you do there.


Amber:

Sure! So we do consulting work, we work in anti-money laundering, counter terrorist financing, privacy, regulatory compliance. Most of the clients that we work with are essential services; banks, credit unions, money services businesses. But that said, I wouldn't say that we've been completely without impact because we also do things like compliance program developments and audits. And if you're worried about the basic core running of your business, it's okay not to be focused on audit right now. We have a few audits that are paused and that's okay. We're working through it with our clients. We're answering those questions. We're figuring out what's happening with our regulators and where there's some leniency and where there's not.


Sasha:

Excellent! I've been actually more busy through the quarantine than I've ever been in the history of working at this firm. At first I was nervous that things were going to slow down too much. And then now, it's feeling a little bit like the opposite. It's that hard to get time ‘coz everyone's at home. But I think it shows the crypto community already set up to work at home and not be so dependent on the government and everything like that.


Amber:

Absolutely! I think it's going to be hard post quarantine to the idea of going back to everyone being in a physical location from nine to five every day. I read something that said that the average commute from a Canada perspective was something like 35 minutes each way each day. You get an hour of time back every day. Who doesn't want that? At least some of the time in that way that it will free people up to work from home more often and work from wherever as it were.


Sasha:

And force the companies to get that kind of infrastructure set up so that now that everyone's had the opportunity to work from home, they can point to that as being maybe more efficient. And I think it gives people a better life not to have to be in that rat race, fighting traffic every morning, be there right at a certain time and have to clock in. It gives people a lot more autonomy to work at their own speed from the comfort of their home or wherever.


Amber:

Absolutely! I know that I'm way more productive when I'm not counting my hours.


Sasha:

Yup! For me it goes back and forth a little bit. Sometimes I feel like lately, I need to get a change of scene to get a fresh take on things. Anyway, what do you make of what's going on in the stable coin industry right now? We saw the Chinese government is saying that they're getting ready to issue their own currency as a stable coin. And there's been some news articles saying that they've got subway, sandwiches, and I think it was Starbucks and a few other companies ready to also interact with this China stable coins.


Amber:

It could be exciting. I guess. I mean it’s good if they can roll it out as a project and see how it works, and everyone else will watch and learn from it. There's definitely a different foundation in China than there is in a lot of places just in terms of WeChat and the digitization of payments, the digitization of services, the ability to do those things within app that exists already. And so, there's part of that we're having a native digital currency that builds on that. Just seems like a very natural extension.


Sasha:

Agreed! And so these G20 members that just met to go over stable coin regulation. Who are the G20? Can you give us a little background on who they are and what they do?


Amber:

So in terms of the G20, you're talking about a group of countries that work together in terms of setting policy, in terms of setting tone. As the name implies, it's a group of 20 countries. Although the things that they're saying aren't necessarily binding, so when they get these types of recommendations. I think I might be jumping ahead to your next question. But these types of recommendations aren't binding, so nothing that we're going to be talking about today is a law or regulation that's been passed. They do tend to be things that set the tone globally. I think they're pretty good Harbinger's in terms of what we should expect and what we should be thinking about. And they definitely are for anyone that's in the world of developing these technologies worth paying attention to.


Sasha:

Absolutely! And what is the goal of these recommendations? What are they trying to promote?

Amber:

I'm not speaking obviously as an official representative of the financial stability border or of the G20. One of the things that hit me really hard when I was looking over the recommendations is that, when I look at them, they're not really talking about anything that's new, so to speak. So stable coins are new in the sense that it's not something that they've contemplated. I'm really deeply previously in terms of how it fits, but when we're talking about things like payment systems in a much more vanilla way and the interoperability of payment systems and the governance of painted systems between countries. What that looks like, those aren't really new things. Financial stability isn't really a new thing. We have central banks that have been setting monetary policy and I'm sure some would argue, acting as a system of control for a long time. Certainly as far back as I can remember. And so these are really looking at bringing some of the aspects of, and not even necessarily all stable coins, but some stable coins under that purview and looking at how should they be regulated, how should they be governed. One of the things that I think is really key about this piece is that they're not talking about every stable coin. And they're the specifically get into something that they refer to as global stable coins. They abbreviate throughout as being GCS and they talk about those as having really specific characteristics. This was fascinating to me. And one of the things that it reminded me of is one of the first talks that I ever gave on crypto or Bitcoin that was at an investment type conference. And a dude talked my ear off for five minutes nonstop afterwards in a way that I didn't understand. And he came up in his posture was very, will you have an MBA? So you're going to understand me? And he talked to you that very tight lips, arms crossed, kind of angry white dude. But I was genuinely confused by, so I think I had a smile on my face the whole time. It was fun. But he was like, I don't know why you think that the world is going to give damns about this cryptocurrency and it's got such a small market cabinet and it's so tiny. And even though Bitcoin has some value today, it's very little value. And compared to the market cap of Microsoft or all of these things, no one should give damns about this and was essentially saying, why do you care about something so small? It's so small, you shouldn't be presenting about this. It's tiny and insignificant. What this paper is really looking at is the potential for not all stable coins, but some stable coins that have certain characteristics to not be small. In fact, to be very big, so big that they have the potential to destabilize economy. And that's the gravitas of what they're talking about in this paper. That permeates all of it. They're talking about things that have the potential to be systemically important. They're talking about things that have the potential to disrupt and not necessarily in the way that we talk about it in tech because I think that's often seen as a positive, but to destabilize economies. And that's something that, is seen as being problematic. I think that there's a lot of this, that was written very much more about Libra then tether, which is not a slight to tether. But I definitely felt a lot of empathy with the pen holders when I read it. Because I will say just as a human, Heather doesn't really make me uncomfortable. Libra does a little bit.


Sasha:

Yeah, that's true. And since Libra came out, tether started it. And then in 2018 we started to see more come online and not really any regulatory guidance about it. Not more of the attitude that had of these are too small to worry too much about. But then, as soon as Facebook came online, we saw the US rushed to put a paper out saying they might be securities like they EU and UK. Just in the last year we've seen regulation come some discussion around them from almost every country, I think or every major one. But the EU is counting them as e-money and trying to regulate them under the payment system. Italy said their financial products and regulated them. Switzerland said the same thing. You need a license, their financial products and you need a FINRA license. Malta, they actually have said they're not considering them as financial products, and Singapore said they made a distinction. If it's pegged to US dollars, then it's e-money service. But if it's pegged to a payment token, it'll go under their payment services act. So I think you really hit the nail on the head there. It's got the potential to make a disruption to the economic landscape right now. So I guess that's why they're all looking at it.


Amber:

Does the US dollar distinction that Singapore made make sense to you? Sorry, I'm not supposed to be asking the host questions, but I find that really interesting.


Sasha:

They made the distinction. I should have researched it more because one of them, when it's US dollar pegged, it's got this e-money issue in services and digital token payment services. So then they're the ones that are going to be regulated. But if it's pegged to say a Singapore currency or a gold, then it wouldn't be regulated. So I guess it might be something where the US even requires that things that are interacting with it have so much KYC on it that it was just easier for them. They knew that if people are going to operate with a US related currency, it's better just to keep them all regulated so they can send the info back to the US if it asks for it.


Amber:

That's a fair point. I had a bit of a different take on that one. And when I was reading, one of the things that I thought was interesting as a Canadian, is that I thought, for a Canadian dollar denominated stable coins, there's probably not a lot of immediate impact from this. And I was thinking about that when they talk about the characteristics of something that could be a global stable coin or a global stable coin related arrangement. And I don't think in that particular arena that the US dollar can really be understated. So having things that are pegged to the US dollar having things that are backed by the US dollar because globally speaking, that's what people want in terms of reserve. I mean, effectively the US dollar for so much of the world is a global reserve currency.

As a Canadian, I can travel freely to Cuba and have, apologies to any U S Watchers who might take offense to that. But one of the things that I find really interesting is that US persons haven't been able to travel freely to Cuba in a very long time. But there is a flowing US dollar economy. You can buy something with physical US dollars paper money that's not going to be refused. And that's really fascinating. I think the US dollar is probably the most widely accepted currency around the world where wherever you are, you may be able to buy something with a US dollar. When I leave the immediate border regions of Canada. So I mean if I drive across the border into Michigan, I might be able to buy something with my brightly colored money in Michigan.

Once I'm more than half an hour, an hour away from the border, forget it, and if I get on an airplane and I go somewhere, could I buy something with a Canadian dollar? No, not as long as it's local currency and a currency exchange. I'm pretty much out of luck, but the experience for Americans is very different. And I think that that's a really long winded way of getting to the importance of that piece. Because what people really want is usable, functional money. So they want to be able to pay for things and they want that money to be able to store its value. And if my currency is rapidly deflating and losing its value, I'm dealing with prices are skyrocketing, what my money can buy is just less and less and less each day.

And I can get my hands on something else that's going to be a better store of value. Of course I would do that. You would do that. Anyone would do that. That's just we've all got to eat. That's the rational thing to do. And I think that's the crux of the thing where US dollars are really going to matter versus any other currency. Because historically they have held their value in a different way. They have been seen as a global reserve currency and we have seen people be able to make payments, and US dollar denominated payments across any number of different markets. Whether it be electronic payments or payments locally on the ground with paper money. And that's a really important thing. I think when you combine that with the idea that in some places, people think that Facebook and the internet are the same thing.

If Facebook then has the power to issue US dollars. There's a lot of implications that happen around that. So if I wasn't in Canada, and I was somewhere with rapidly deflating money, but I did have the ability to get something that was us dollar denominated, it said that it was going to hold its value from this tech company. What I do it probably, would there be a bunch of risks in that that I didn't understand? Probably. Would there be actual US dollar reserves backing that up somewhere? Maybe. And then would that…. if it's useful as widespread enough, if it was in the hands of enough people, if it was on every mobile device…. who's using my country’s local currency.


Sasha:

Yeah. Good question. ‘coz like everything that you buy, but I worry that it takes away the.. and I know it doesn't, but it kind of competes a little bit with Bitcoin because I was hoping Bitcoin would become like the money of the future and we would be off the government money. But these are all still keeping the government money very much in play and the old system in play. But I think logically we're not moving from where we are now to just everyone using Bitcoin. We're nowhere near that. So this is kind of a step in the way, on the way to getting digital assets, but it's missing a lot of the core tenements that are positive of a Bitcoin. And it could put us into a really….. There's just a lot of privacy concerns for every single transaction globally to be recorded by one place.


Amber:

There are a ton of privacy concerns around that. And there should be. I think that one of the most important things that I think need to happen as part of this process as part of the digitization process. And for what it's worth, I think that these things will exist in parallel with Bitcoin. I think that if what you're looking for is self-sovereign hard money and you're really bought into that idea, you're not getting off the bandwagon because, you know what I mean, a country or a company or more likely those two things in conjunction, have issued a stable coin. And nor do I think that the stable coins that they're talking about in this context really when you read it and you start looking at the parameters, you're talking about permission ledgers, you're talking about systems that have access.

You're not talking about completely open systems. You're talking about a lot of imposed structure and that actually makes sense to me when you start to talk about things like reserves. I don't know that a form of Bitcoin where everything is completely permission-less and open and decentralized and somehow also there's a volt with cash in it. Makes sense. Right? So I think that these are different things that they have maybe even slightly different use cases with a lot of overlap. But I think that really when I read this, what I see is really less about the technology that is stable coins, and more about the modernization of the central banking system. And if you renamed it the modernization of the central system, that would be equally accurate for this paper.


Sasha:

Yeah. And what were of the recommendations? What was your overall take of it, of the regulatory attitude towards stable coins? And then what were your favorite? Or I guess favorite might not be the right word, but what regulations did you think they got it right or their approaches, coming from an intelligent angle, like what the information that they're asking for and then are there any recommendations that didn't make sense to you?


Amber:

So I think overall they're looking at it and saying, if you think about it as the modernization of the central banking system, it makes sense if you look at it as the regulate relation of technology that already exists, it's free and open. It's terrifying. So those are two different perspectives that I think are important to keep in mind. But I think in terms of talking about collaboration, there was a lot in this piece in terms of talking about collaboration and standardization across different regimes. I was really fascinated by discussions of cross border payments and being able to make cross border payments faster or cheaper or more efficient. That was one of the pieces that struck me in a strange way in that we couldn't have done that decades ago.

We have some awesome new tech. There's awesome new tech. Not denying that, super excited about it. But electronic databases that could talk to each other across oceans existed like decades ago. And we could have used those in different ways that were permissioned, not unlike what we're talking about now. And those payments could already have been more transparent. They could have been faster, they could have been more efficient, they could have been less expensive. And we chose not to do that. But necessity is the mother of invention. And I think that what's happening here is that suddenly there's something that could be competition. Suddenly there's a threat of something that could be equally useful, that's not controlled, that could destabilize the system. And that's problematic. And so this is looking at it and saying, how, how do you maintain that control?

How does the central banking system face the existential threat and modernize itself? And develop in a way that's going to make sense. As like a regulatory geek, I am pretty jazzed about anything that talks about collaboration and standardization across different regions. Do we lack that? We lack that in every facet of regulation everywhere you lack in between States. We lack of between provinces we lack at between countries. Wouldn't it be nice to just be able to deploy something and say, Hey this is going to work in all of the jurisdictions with which we're cooperating.


Sasha:

That would need so much time and effort in everything. ‘coz right now it's just anything to do with money transmission is such a… The hardest part is to get launched and be compliant in all these different jurisdictions and it's that people are able to launch worldwide, over the internet, but then they can't because they've got to make sure that they're licensed in every state and country and sometimes province. I don't know if the provinces require any variation on the licensing, but…


Amber:

One and two on its way. Yeah. Eventually there may be more.


Sasha:

It just seems that, what you said is if we could have one standard that we knew we could check all that we're doing everything to…. I think we already maybe have that standard in America because it regulates more than any other country as far as I know in terms of with the FinCEN and what's required and collected. I think if you can follow a robust AML policy here, you're pretty much covered for most other places other than actually applying for the license. But your processes would satisfy what most places need. Although I haven't dug in ever…. I haven't dug in that far to what the other countries actually need.


Amber:

This is I think a good thing and if this could work well in this arena, it's something that I think we might be able to see in other policy arenas, which is really cool. The place where I would have liked to see more, but didn't, is in the tremendous potential that I think some of these things have for anti-corruption, for anti-collusion, for transparency. I think they did a really good job talking about retail transparency. So the end user really needs to understand what they're buying. If it's collateralized, the rights that they have, the rights they don't have, because maybe in a bankruptcy they're last in line. So I think they did a really good job in talking about that retail level of transparency. But I think as specially when we start to talk about things, like these distributed ledgers, like these block chains, why not make it public?

How about we could literally never have another library scandal because every armchair analyst always is watching. I think that would be fantastic. Yeah. I believe in the individual rights to privacy, but I also think that there are things that we could be doing to promote at a government, and institution and governance level transparency and those things are… they're not in conflict with each other when we're looking at the design of these systems. So I think there's some pretty fantastic things that we could do from an anti-corruption and anti collusion level, and we could really build that into the DNA of these types of systems. There are definitely parties that would be part of those systems that don't want that to happen, but I'd like to see it happen anyway.


Sasha:

And imagine if every country or company had their own stable coin, how easy it would be to audit their financials. If you could really see track and see publicly where everything was spent. I think companies would not like that


Amber:

But I think that would be fantastic when we talk about how much outstanding currency or how much outstanding value there is in any system. Absolutely. If that was completely transparent, if that was completely audit-able, there would be value in that. I think even from a securities token perspective, that's one of the biggest value propositions that I see. You know where every share is. How many have been issued and where they are, at least in terms of the wallet they're connected to at every given point in time. That's amazing.


Sasha:

And even things like payroll, if the company was using some kind of digital token, that could be streamlined a lot. Even every hour that you earned can immediately be paid rather than waiting two weeks batching checks. And at a larger scale from a government perspective there, it certainly can be at any time that's wasted. Sending money around wires and things like that is all able to be streamlined here. It's at the same time, I remember talking with Isabella Kaminski about the Facebook one a while ago and she pointed out, if we start paying people in Libra currency for instance, there could be some kind of, we could get into a draconian situation where if someone has lowered their credit score for whatever reason, they might get locked out of their Uber car that they're trying to get into and earn money or banks or whoever you owe money to might have easier access to your wallet, like especially the government taxes and for child support or anything like that, which in some cases maybe fine. But it's certainly a shift from today when everyone has the choice whether to send a transaction to any credit or not.


Amber:

Yeah. The intent here in terms of the product that they're talking about, I mean, it is not something that's intended to be open and border-less and resistant. And I think that's a really important distinction. Um, in particular when we talk about value and use cases for things like Bitcoin. It's very different what they're talking about here in terms of these collaborations would not be censorship resistant. Any more than the money that's auspiciously held in my bank account is censorship resistant now. As I was going through those, one of the funny questions that I was trying to think through in my head when I was thinking about different models for stable coins. So when you look at collateralized and not collateralized, what's the scarier option? Defy. So decentralized finance with all of its lovely buggy smart contracts or a fractional reserve banking token.

Sasha:

Fractional reserve. A stable coin. I mean, I'm sure that's what it'll end up being like we saw with tether already. It's too tempting to…. you don't want to keep all that money tied up when you can figure out a way to use the money that's backing it. I doubt governments would sit on all their cash that now they're going to find a way to double the supply of the world's money if they get, big stable coins going cause they'll have more and more in that re hypothecation situation.


Amber:

What are the things that I always hope comes from this or it comes from any of these discussions? Is that more stable as access to banking? I think in a situation like tether, it's so hard to know what is actually happening, because how do you audit something when there's not a stable banking relationship or there's continuous movement by necessity, which is to say that I don't think anyone at tethers sat down and said, you know what? We should change banks a couple of times this year. That sounds like a great plan. That's what every business wants to do. I think that that was something that they dealt with by necessity and that caused a lot of confusion and a lot of difficulty in terms of auditing and tracking. And so I think when you have in these types of recommendations, the idea set out that these things should be transparent and it should be auditable and there should be suitable reserves. And there should be suitable custodians for those reserves. You have to have traditional financial institutions that are stepping up into those custodian roles. Recognizing the importance of those roles, playing those roles. And this is really inherent in the DNA of these recommendations is that that will happen. I hope that happens for our little nerd money and our nerd money companies as well as for the central bank facilities.


Sasha:

Yeah, for sure. If you could create the regulations for a stable coin, how would you set it up?


Amber:

I think that's a terrifying question. Because I don't think our current system is all bad. I live very comfortably. I like my comfortable life very much. I don't know that I think that it needs to be completely destabilized. And so I think that's a hard question. I also know that I don't want to be beholden to any particular company. And I think that there is a real danger, particularly in emerging markets of a particular a company becoming more powerful than the government. I'm not really worried about that from the Canadian perspective. Although we grow up with the spectrum of our neighbor, the United States and we assume you'll take care of us if we mess up too bad. Right? And we're kind of like that kid brother who always has the security blanket. But I don't know that I would feel that way if I was somewhere else in the world. That said, I really want everyone to have access to solid money. And so I don't think there's an easy answer in terms of how to regulate, I think the answer is very carefully. And I think the answer is that we accept that there's going to be some things that happen that are not comfortable.


Sasha:

Agreed. I was expecting to read these recommendations, usually when the government puts out some kind of recommendations on things you can pick apart, like they didn't understand a certain aspect of the technology or something like this. But these were actually…. I thought they were pretty reasonable and some of them were even things I hadn't thought of that, that aren't very important things to be cognizant of with stable coins. So, all the balancing mechanisms that they talked about a lot too, I think they were encouraged to…. stable coins are encouraged to make their stabilization mechanism open source. So that I really liked the name when they said that.


Amber:

Yeah, I thought that was good. And they've clearly done a lot of research, so they talk about the creation and destruction of coins and how that's counterbalanced with reserves. They talk about audits and transparency. They even talked about the suitability and fitness of the companies themselves. So the idea of it, you probably shouldn't have a fraudster running these companies. Which I agree with wholeheartedly. I wish we had the same laws that applied to government, but this may be a little too political.


Sasha:

There was one too where it said, I think it was recommendation number nine that authorities should ensure that the global stable coin arrangement provide legal clarity, the users on the nature and enforceability of any redemption rights and the process of redemption. Where applicable. That one I was a little bit, so right now as far as I'm aware, globally, users are not regulated for using any kind of digital currency. But this is saying and authority puts some kind of…. if there's some rule on the user, then that really needs to be clearly articulated, which of course, it would be, but I hope there's not any plan rules coming to the users that aren't existing today where say one jurisdiction says you can't use the stable point. We don't want you using it, whatever it is, Libra, or country's stable. I guess we've already seen Trump said we can't use the Petro back point.


Amber:

Do a lot of people want to? I'm sorry, that's a really stupid question, but I don't like… I'm not feeling like that one had a ton of potential that's just being tamped down on..


Sasha:

Yeah. But I guess, some countries have said not like China's setters banning, certain digital currencies and we just haven't seen that over. And in probably most of these G20 countries, there's not any repercussions on the users other than maybe if they don't pay their tax liabilities. But it kind of made me think there might be some rules on the users with this, which we'll see what, you know, nothing's there yet. It's just something to keep an eye on.


Amber:

I saw, I mean, I had kind of read that one more as consumer protection. And I think about that even in the Bitcoin world. I remember a company here in Toronto, there was sort of an exchange or brokerage type company. They were around for a very short period of time. Because they got a letter from one of our regulators because they advertised pretty widely for risk-free Bitcoin investments. They were selling Bitcoin so you could go to them and you could buy Bitcoin from them and they weren't trying to rip you off in the sense that they would give you Bitcoin, but where they misrepresenting risk.

Sasha:

Yeah, maybe, and their exchange was so safe because they were in charge of it that it was risk-free, but then it's interpreted like, Hey, Bitcoin's a risk free asset.


Amber:

No, we think the price is definitely going up, so we should be able to say that it's risk-free. I know I was morbidly curious, so I like went and found them and just chatted with them. I was like, yeah, okay. I do think from a consumer protection perspective that things like that are important. It's important to know what you're getting. If I think that I'm getting a thing that I can redeem for a us dollar somewhere, but I can only redeem it for an ice cream cone at that ice cream parlor two blocks away and it's worth, it's elsewhere. I don't really have a dollar. And that's a pretty important distinction. I can remember being a kid. Did you have farebox anywhere where like if you went to a country fair?

So it's like this coupon basically that you can use with the vendors within the fair. So it's like you know, drink tickets or meal tickets or whatever. But I remember being scandalized because I was really excited because I was like, okay, so I can give them my $10 and they're going to give me 12 Fairbanks. It's totally makes sense because now I can spend $12 within this environment. But then at the end of the day, I was like, Oh, I have three of these left, so I should return them and they'll give me dollars. And they were like, Nope, you can buy a thing. But you can get no dollars back for those. Once you trade your dollars for farebox.

That's it. Like you can get whatever you can get for farebox. And I was scandalized in part because, you know, in my brain I was like, I beat this is, you know, but yeah, I was really upset that, okay, so now it's the end of the day and I have to try to find something that maybe I want that I can buy for $3 or just accept this loss. And I think those are the types of things. It's funny and kind of cute when I tell the story about how my 10 year old brain processed that inequity, but if we're talking about something like my life savings that just went into farebox, and I didn't know that it was farebox, and I thought that it was dollars and everything about it seemed to promote the idea that it was dollars. That's problematic. Yeah. And I mean, the reason that you have this paper and I think they get really clear on that is that they're looking at it because there's a potential for this to be very widely used, you know, as widely used as we might use a credit card or a debit card today. And that's a pretty big deal.


Sasha:

Yeah, absolutely. I know you've got a call in four minutes, so we'll maybe wrap up here. Thank you so much. Any final thoughts on it and where can people find you?


Amber:

Please don't panic. No one's banned stable coin if that's the headline you're reading. Breathe out. Fake news. Keep building cool stuff.


Sasha:

And your twitter?


Amber:

Oh, my Twitter is at outlier Canada. Or you can find me at outliercanada.com.


Sasha:

Perfect. All right. And thank you again and we'll talk again soon.

Amber:

Thanks so much for having me.

Sasha:

Thanks Amber. Have a good one.


Amber:

You too.

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