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The Cornerstone of FINRA’s Market Surveillance Program: A Historical Commitment to Market Transparency

November 30, 2021

Transparency plays a central role in promoting the fairness and efficiency of U.S. markets, lowering transaction costs, leveling the playing field and enhancing public trust in our markets. And the data market transparency provides serves as the lifeblood of FINRA's surveillance program.

On this episode, we hear the Market Regulation and Transparency Services’ Jon Kroeper, executive vice president of the Quality of Markets Group, and Ola Persson, senior vice president and head of Transparency Services, about FINRA's historical commitment to market transparency and how it has impacted FINRA's regulatory regime.

Resources mentioned in this episode:

Trade Reporting and Compliance Engine (TRACE)

Consolidated Audit Trail (CAT)

Regulatory Notice 20-43

Advancing Market Regulation and Transparency

Episode 13: How the Cloud and Machine Learning Have Transformed FINRA Market Surveillance  

Listen and subscribe to our podcast on Apple Podcasts, Spotify or where ever you listen to your podcasts. Below is a transcript of the episode. Transcripts are generated using a combination of speech recognition software and human editors and may contain errors. Please check the corresponding audio before quoting in print. 


00:00 - 00:31

Kaitlyn Kiernan: Transparency plays a central role in promoting the fairness and efficiency of U.S. markets, lowering transaction costs, leveling the playing field and enhancing public trust in our markets. And the data market transparency provides serves as the lifeblood of FINRA's surveillance program. On this episode, we hear from two executives from FINRA's Market Regulation and Transparency Services Team about FINRA's historical commitment to market transparency and how it has impacted FINRA's regulatory regime.

00:31 – 00:40

Intro Music

00:40 - 01:23

Kaitlyn Kiernan: Welcome to FINRA Unscripted, I'm your host, Kaitlyn Kiernan. I'm excited to welcome two new guests to the show from FINRA's Market Regulation and Transparency Services team. We have Jon Kroeper, executive vice president of the Quality of Markets Group, and Ola Persson, senior vice president and head of Transparency Services. As a bit of a history nerd, I'm excited for today's episode. We're going to be taking a look back at the history of FINRA's commitment to market transparency and how it has impacted our financial markets and the way FINRA regulates them. But before we get into that, Ola and Jon, I wanted to start out by having you introduce yourselves and tell us a little bit about the groups that you run. Ola, maybe we can start with you?

01:24 - 02:51

Ola Persson: I'm happy to. Hello, Kaitlyn. It's great to be here. Thank you for inviting us. So, I'm actually originally from Sweden, but I spent the last 30 years here in the U.S. I did my undergrad at the University of Stockholm, and then I went to graduate school here in New York. So before joining FINRA, I spent 10 years with a company that at the time I was called Reuters, it is now called Refinitiv, all in the various aspects of their fixed income business, data and data structure, analytics and product management. And I joined FINRA in 2004 to work on the TRACE program, which is FINRA's fixed income and reporting transparencies program. After a number of years, I also got involved with equity facilities, and about three years ago I was appointed to head our Transparency Services.

So, the department, we are responsible for operating FINRA's trade reporting and quote facilities for equity and fixed income securities. The technical and operational aspects of that are quite considerable, we take in millions of transactions. We support thousands of users across hundreds of firms. And a couple of our facilities are what's considered critical market infrastructure under the SEC's SCI rules, so there's a significant amount of requirements that come with that. The objective is to minimize market disruptions. Besides the technical aspects and the operational aspects of running these facilities, we also, as the name implies, we're focused on market structure issues in general and transparency in particular. Most staff in the department have quite extensive market experience either on the business side or on the technology side.

02:52 - 02:54

Kaitlyn Kiernan: Thanks, Ola. Jon, how about you?

02:54 - 03:37

Jon Kroeper: Yeah, hi. Thanks, Kaitlyn, and pleasure being here, and thanks for having me. I'm from an even more exotic place than Ola, I'm from Jersey City, New Jersey. I head up the Quality of Markets section, as you said, within Market Regulation. I started my own career at the SEC in their division of market regulation. There, I conducted inspections of SROs. I reviewed rule filings and participated in writing some of the SEC rules in the late 90s, like the order, handling rules and Reg ATS. I went to work for one of the commissioners after that. Then I went to work for a broker-dealer for six years. After that broker-dealer was sold, I went back to the SEC, worked for another commissioner and then the chairman, and then I came to NASD in 2007 and I've been here ever since.

03:38 - 03:42

Kaitlyn Kiernan: And what about the Quality of Markets Group? What do they do?

03:42 - 05:39

Jon Kroeper: We're responsible for conducting automated surveillance and investigations that come out of our surveillance reviews. They go to potential violations of trading related rules in equities and fixed income securities. So, you might ask, you know, what is surveillance? At its simplest form, we run computer programs against the market data that we take in to detect specific rule compliance issues or to find other behaviors of interest.

So, on the equity side, we perform this role not only for FINRA, but also for all of the other equities exchanges, and there are 16 of them right now, through what we call regulatory services agreements. On the fixed income side, our surveillance covers all the fixed income products that are reported to TRACE, which Ola will talk about in a little while I'm sure, and we also cover municipal securities that are reported to the MSRB.

So, no matter what the product is, we performed four basic types of surveillance reviews. The first is regulatory reporting reviews and those covering things like trade reporting, as our surveillance is only as good as the data that we take in. We do market conduct rule reviews as another category. That covers things like short sales and quotation requirements. Those are intended to make sure that market participants comply with all the rules of the road. We cover customer protection as well. Are customer orders being handled properly or obtaining best execution? We have programs to detect that. And also, the final category is market manipulation. So, we look at things like marking the close, wash sales, front running and a myriad of other scenarios.

So, we have about 100 surveillance reviews that we conduct, and many of these have multiple scenarios under them. And we have a lot of partners within FINRA to help us do our work. We work with technology to develop our surveillance patterns; we work with enforcement in those situations where our matters may turn into formal actions. We coordinate closely with the exam teams at FINRA to ensure that all the bases are covered and we're not duplicating efforts. And we work with Ola and his team to make sure that if there are any potential changes to the transparency programs, we are able to evaluate what impact that has on the surveillance program.

05:41 - 05:56

Kaitlyn Kiernan: Well, thank you for that. Well, Ola just to kind of kick things off, FINRA has a whole group called Transparency Services, which I think in itself is very telling. But can you help us understand the history of FINRA's efforts to increase market transparency?

05:57 - 07:30

Ola Persson: Sure. Maybe starting with why is transparency important, why are we focused on it? As you know, FINRA is dedicated to protecting investors, safeguarding market integrity in a way that facilitates vibrant capital markets. And transparency is really a key component of that. Information on market activity, whether it be volume, price levels, et cetera, is really critical for market participants in their investment decisions and trading decisions, judging the quality of their execution, risk analysis and a whole host of other areas.

The equity markets have a long tradition of transparency, and more recently, relatively speaking, we also introduced transparency to parts of the fixed income markets. And the effects of that have been very positive and the academics that have had a chance to study during the rollout and its reduced bid-ask spreads, which is generally associated with more liquid markets, it's reduced trade execution costs for investors. It's leveled the playing field and allowed smaller regional dealers to compete effectively. And it's also improved the precision in the valuation of these securities.

So, transparency generally has had a very positive impact on the market. Taking a step back, though, from a regulatory perspective, just collecting this data is very beneficial. There are facts on how the market operates, how the instruments trade, levels of market participation, et cetera, that we can observe, and we can use that in formulating policy proposals. The third benefit is in Jon's area, that collecting this information enables the surveillance and oversight, which really is the cornerstone in FINRA's mission to ensure investor protection and market integrity.

07:31 - 07:44

Kaitlyn Kiernan: You have mentioned that center operates facilities for different markets. Can you talk a little bit about the breadth of that coverage and how it has evolved over time? You mentioned equities, it's has a longer history than bonds.

07:45 - 11:33

Ola Persson: Generally speaking, at FINRA we focus on transactions that are executed over-the-counter or off-exchange. It really breaks down into three distinct markets where we operate different facilities. The first one is actually listed equities, which is also known as the NMS market. A significant portion of transactions in listed equity securities actually takes place off the exchange, over the counter. And we have facilities for member firms to report those transactions.

There are also markets that don't trade on an exchange at all and all that we have facilities for as well. The first one is unlisted equities, by definition, all over-the-counter, and the fixed income markets, as I mentioned, are all over the counter markets. So, if you look at it, the historical context is the equity markets have been transparent for quite a while, obviously Nasdaq goes back many decades at this point. And equity markets have history dating back from the time prior to NASD and Nasdaq separated.

Specifically, in the NMS space, the listed equities we created want is called Trade Reporting Facilities, TRFs, and that allows reporting and dissemination of over-the-counter transactions in listed equities. These facilities are really partnerships between FINRA and the exchange. We have three of them today. We have two of them with Nasdaq and one with NYSE. And then we have our own facility called the Alternative Display Facility. But on any given day, over 40 percent of volume in listed equities are executed off exchange and goes through one of these facilities. It's also of note the data from that comes out of these facilities for transparency purposes is distributed together with the exchange data in what's called the Securities Information Processor. That data reaches a very large audience. We have over 250,000 professional users. I think it's over six million non-professional uses at this point, so it gets a very wide distribution.

The other area is unlisted equities. There was a refreshment of the rules set in the mid-90s, and then when NASD and Nasdaq separated, FINRA maintained these facilities. So, we brought with us a facility called ORF, the Over-the-Counter Reporting Facility. And also, a facility for quotations, and that's something known as the OTC Bulletin Board. The bulletin board was actually closed earlier this month, but we've operated it otherwise since then. The unlisted market is actually relatively big, some 18,000 instruments, everything from small domestic companies to ADR and foreign securities. We see around 600,000 trades in any given day reported to ORF. The data coming out of ORF is also distributed and co-mingled when the listed data in the SIP, so it also gets a very wide distribution.

The other critical function we perform in unlisted equities, we're responsible for declaring corporate actions or name changes, stock splits, dividends, et cetera, and that in the market, the corporate action is not considered effective until we've declared it, so it's a very critical function so these securities can trade. And fixed income is relatively new in historical context, but nonetheless, a couple of decades ago, FINRA launched TRACE in 2002. Initially it was covering corporate bonds. Since then, we've expanded to agencies, debentures, asset and mortgage-backed securities and most recently to Treasuries.

TRACE was created for all the reasons I mentioned up front, it was to level the playing field among market participants. It was to provide regulators with information to enable surveillance and oversight and it was to increase the knowledge of the market and create the foundation for developing policy. TRACE increased gradually. We've added these asset classes and every time we added more asset class, we've been also gradually phasing in transparency. There's been a number of benefits to that, it gives us a chance to study the impact of transparency as we roll it out. And the other one is to allow market participants a chance to get used to the new environment, new levels of transparency and how that may affect them business.

11:34 - 11:41

Kaitlyn Kiernan: And it seems like the requirements for these different products and asset classes, they vary. Why is that?

11:42 - 12:32

Ola Persson: There are many forms of transparency. I think generally we think of transaction-level information being disseminated to market participants and that is the case for a vast majority of the markets. But we also published a significant amount of aggregated information on all markets. The OTC activity in listed equities and in unlisted equities and in some fixed income. A good example of that are the aggregated volume reports for Treasuries that we publish. We work very close to the Department of Treasury to develop those and they've been positively received in the market. But we do also recognize that there are distinct differences between markets and products and maybe in particular in fixed income. There are some very unique aspects of certain products, in particular in the securitized space, how they're structured, issued, traded. So, we take a nuanced approach to the analysis when we evaluate what kind of potential transparency may be appropriate for a specific product.

12:32 - 12:36

Kaitlyn Kiernan: So, transparency, while important, is not one size fits all.

12:36 - 12:38

Ola Persson: It's not one size fits all, correct.

12:38 - 12:47

Kaitlyn Kiernan: And Jon, how did the introduction of these facilities that Ola has been talking about impact FINRA from a regulatory point of view?

12:47 - 14:19

Jon Kroeper: Yeah. So, you know, data is the lifeblood of the surveillance program that we operate. The more data that we have available to us, the more we can do with it to improve our oversight of the markets. Otherwise, you know, we can only evaluate behavior on a firm-by-firm basis through exams or some other means unless we went out to all the firms asked for their information, put it all together, it may be in different formats, and then tried to run reviews on top of that, which would be very inefficient and would be burdensome on us. And the market participants would be practical to perform on any sort of regular basis or any kind of scale at all.

So, things like TRACE give us transaction reports for all or almost all market participants in one standardized format. We can run our reviews on all the market activity at once and compare the behavior across firms, and we can then identify firms that are the outliers in performance or engaging in possibly problematic behaviors. So, it's really, truly the bedrock of our surveillance program, the data that we receive from all these different facilities. And just underscore the point that one size does not fit all, there is different character to each of the markets that we regulate and the context and the data that we bring in differ for each one, so we do adapt our programs accordingly. There are other things that we've used the data for as well. It's not only for surveillance, but also in formulating our regulatory policy and also to support whatever rulemaking we need to conduct, and also forms the basis of the academic research on the marketplace.

14:20 - 14:31

Kaitlyn Kiernan: And one element of the surveillance program, an important source, is OATS, the Order Audit Trail system. Can you tell me a little bit about that, why it was established and the purpose it served?

14:31 - 15:41

Jon Kroeper: Yeah, absolutely. The roots of OATS went back to the order handling rules that the SEC issued back in the late 90s in response to the market maker collusion that occurred in the over-the-counter market. So as a result, the SEC wanted NASD, at the time, to be able to surveil the markets to make sure that customer orders were handled appropriately. So what OATS is I would say is a way of collecting the lifecycle of information of an order from when it's initiated to one it's executed or cancelled.

So, what happens is there are many steps in the handling of an order. It comes into a firm, get sent to a desk in the firm and may go out to another broker-dealer for handling, may go to market maker for execution, may get routed to an exchange. And all these steps, the firms are required to report to OATS, that step in the lifecycle, and they were required to report it in a way that could be linked together so that at FINRA we could collect all that information together in what we call a lifecycle and see, from cradle to grave, what happened with that order, and connect that to the transactional information that we had through the FINRA facilities or information that we receive from the exchanges.

15:42 - 15:49

Kaitlyn Kiernan: And how did that introduction really change the marketplace and how FINRA regulated it?

15:49 - 17:00

Jon Kroeper: Yeah, there are at least two ways it did that. So, as I alluded to, OATS enables us to run surveillance in areas where customer orders that improve the quote weren't included in the market makers quote. So better prices were available and OATS there to be able to ensure that the market makers were including those orders in their quotes. Also, initially, customer orders were traded ahead of, so that if a broker-dealer held a customer order, then traded for its own account without OATS, there was no way of knowing whether that order was in hand at the time.

So those were the initial purposes, but we've expanded well beyond that and incorporated it into pretty much all of our surveillance program and actually OATS was the foundation of what we call our cross-market equity surveillance program. And there we took the OATS information, combined it with the trade reports on the FINRA side and combine it with the exchange orderbook information to create a virtual view of the entirety of the U.S. equities markets, and then ran all of our surveillance programs against that. So, we were able to recreate the market and be able to get a comprehensive, full picture of what was going on. And it really took our program to the next level.

17:01 - 17:09

Kaitlyn Kiernan: That sounds like it had a huge impact that what was missing and how did that limit the way FINRA oversaw markets?

17:09 - 17:52

Jon Kroeper: So, there were a few things missing in OATS. So, it only covered equities, didn't cover options, and those markets are very interrelated with one another. So, you're missing a big piece of the picture if you don't have the options information. The information related to the identity of customers, you only knew that it was a customer order, you didn't know who the customer was. There were limitations on the amount of information about market maker orders. You know, there were gaps in that lifecycle that I talked about, and it only included information from FINRA member broker-dealers, it didn't include those other broker-dealers who aren't FINRA members, which were many of the HFT firms and other proprietary trading firms of that ilk and accounted for a large part of the marketplace.

17:53 - 18:01

Kaitlyn Kiernan: So recently, OATS had its very last trade reported on August 31, 2021. Why was that?

18:02 - 19:25

Jon Kroeper: Well, you can trace the beginning of the end for OATS all the way back to May 6, 2010, which, as a history buff, you would know was the day of the Flash Crash. And on that day, the Dow dropped a thousand points in a matter of minutes, only to rebound quickly. And there are a number of blue-chip stocks that went almost to zero in that timeframe. Everybody wanted to know the answers—Congress, investors, the SEC, but what was lacking was a comprehensive audit trail to enable that kind of an analysis to take place.

We had OATS, we had OTC trade reports, but at that time we only had Nasdaq information. We didn't have information for the other exchanges because we hadn't entered into an agreement with them yet. So, we had slightly less than half the market activity. So, everyone wanted the answers, but there was no comprehensive audit trail available. So that started the decade long journey that we've been on for the SEC to propose the creation of the CAT, for the rule to get approved, for the SROs to get together and develop a plan for building the CAT, to get that plan approved by the SEC, for the SROs to actually have CAT built and for the industry members and the SROs to report to CAT. So, at this point, we're working through the final implementation stages to CAT. There's one phase in December and another next July and then CAT should be complete.

19:26 - 19:33

Kaitlyn Kiernan: And so how would you compare OATS and CAT? It sounds like CAT is the next level and progression of OATS?

19:33 - 20:51

Jon Kroeper: Absolutely. So, CAT addresses all the limitations of OATS that I talked about earlier. CAT includes both equities and options, gives you information about the identity of the parties responsible for the market activity, so it will tell you ultimately who the customer who entered the order was, and you're able to relate that information across different customer accounts, so you know if someone is working through two different brokerage accounts to try and engage in some manipulation or try to do something else. CAT includes market maker activity, which wasn't in OATS. It provides better linkages in the life of orders. Those linkages are tighter. There aren't gaps in those linkages.

And CAT includes activity from all broker dealers, just not FINRA remembers. So, the promise of CAT is that it's going to provide us with the ability to be more precise with our surveillance, it will reduce what we call false positives, and those surveillance outputs will be more efficient. Hopefully, we'll be able to resolve many more alerts without having to go out to broker dealers to get information. And it's like going from broadcast TV, if you remember that, to HDTV or 4K. It's a much clearer picture of activity on the marketplace. And then the ability to do cross products surveillance between equities and options on a systematic basis is a game changer for all of this as well, given, as I said before, the relationship between those two products.

20:51 - 21:03

Kaitlyn Kiernan: So that sounds like a very exciting future with CAT, but OATS had a very important role in us getting to this point. So, if you were to write an epitaph for OATS, what would it be?

21:04 - 21:18

Jon Kroeper: Yeah, a lot of the industry complained about OATS throughout its life cycle and OATS was complicated, but it provided a lot of value. So, it'd be something like, "You were unappreciated by many, but you're greatly valued by those who knew better."

21:18 - 21:32

Kaitlyn Kiernan: I love it. That's perfect. Now, Ola, can you tell me a little bit more about some of the recent efforts to enhance our ability to oversee the market? And tell me more about TRACE for Treasuries and what's happening there?

21:32 - 23:12

Ola Persson: TRACE for Treasuries, we initiated the trade reporting for FINRA members in Treasuries back in 2017. The impetus for that was a little bit similar to what Jon just described for CAT. There was a bit of an unexplained burst of volatility in Treasuries a number of years ago, and I think regulators would prefer to have more data to look at and understand why those events may occur. So FINRA members have been reporting since 2017.

We've been working very closely with the Department of Treasury and the Fed during this time, both to make sure to work through the data and explain the data. And also, we worked with them to start releasing aggregated level information in the market. We publish weekly aggregate volume reports on our website, which have been very well received.

One key development that occurred very recently is that the Fed adopted rules for commercial banks that meet certain thresholds to report their transactions to TRACE in what's known as exempt securities and, for the purpose of today, exempt securities are really Treasury's agencies, debentures and agency mortgage-backed securities. And this is a very big step in the right direction. This will take effect in September of next year, and it will provide a complete picture of market activity in these securities, since extended securities can be traded obviously by FINRA members, but also by commercial banks.

So, this is a big step to get the complete picture. We also worked with the members of the Interagency Working Group in enhancing certain aspects of the TRACE data. We did put out a regulatory notice seeking comment. We're working through that now and see how we can prioritize them, but that is a joint effort with them trying to collect information on this market that is relevant to evaluate the activity.

23:13 - 23:22

Kaitlyn Kiernan: And so, you mentioned big new changes to increase the scope of TRACE for Treasuries, but are there any other current limitations that might be addressed in the future?

23:24 - 23:53

Ola Persson: Chairman Gensler spoke about this at the conference. High frequency trading firms are active in Treasury securities and particularly in on-the-runs. They trade through the IDBs, mostly related to the dealer broker platforms, and dealer brokers can identify the firms in the data, but it's not consistent across the platform. And Chairman Gensler yesterday spoke about potentially registering high frequency trading firms, which would then give them a reporting obligation in this context, which would be a great deal of help.

23:53 - 23:58

Kaitlyn Kiernan: And Jon, I'm sure you're excited to just have more pieces to the puzzle.

23:58 - 24:16

Jon Kroeper: Absolutely. As always said, the market is dominated by firms that are high frequency trading type firms and to have more granular information about the executions that occur in those markets would definitely give us more pieces of the puzzle, and it makes for better surveillance and oversight overall.

24:17 - 24:23

Kaitlyn Kiernan: At the end of the day, how does the data here inform FINRA's policy making decisions?

24:24 - 25:06

Ola Persson: Generally speaking, Jon can jump in, the data is the foundation because you can empirically observe what's taking place in the market. You can see how transactions are executed; you can see dealer behaviors. There is a series of measures you can take a look at, and you can pinpoint if something appears to be problematic. You can dive into it, but then also then does the data support or observation so to speak? So, it's a great tool to use as a foundation for pinpointing where we may want to focus or if issues are brought up with us, we can go and validate it based on the data. The other side of that coin is obviously hugely beneficial if you do make policy changes. You now have a way of measuring the impact of those policy changes. So, both those two pieces are critical.

25:07 - 25:38

Jon Kroeper: Yeah, and I'd also make clear that increasing transparency is something we see as improving things for investors in our ability to oversee markets. But in terms of evaluating policy changes, we're always very cognizant of the impact those changes might have on market participants who are required to report as they may need to make changes to their systems in order to do so or make changes to their workflow. So, there's always a cost-benefit analysis that we go through. We still see comments from the public on all such proposals, and they're generally subject to review by the SEC as well.

25:39 - 25:50

Kaitlyn Kiernan: And given that it is a burden for firms to implement new policies and procedures, just to wrap things up, at the end of the day, why does it matter? Why are we doing this and why is transparency so important?

25:51 - 26:55

Ola Persson: Back to the beginning, there are significant benefits of transparency to market participants, to the regulatory program, to our general knowledge about how markets operate and why. So, we always work to ensure that the programs that we have really reflect the market the way it operates. We also spend a lot of time developing the programs as the markets continue to evolve. And the unlisted market is a great example.

We actually closed down the Bulletin Board because businesses migrated onto commercial platforms that allowed for more electronic interactions. But we also look at the market conventions and how they develop and how that's reflected in the data. So, for example, in the fixed income space, we've seen significant growth in portfolio trading. So, we got a recommendation looking at changes there, we put out a regulatory notice seeking comment. We spoke to a number of participants.

So, we're looking to evolve the program as the markets evolve. So, there are significant benefits to transparency to market participants, savings to investors, but also to the integrity of the market through our ability to surveil behaviors in the market.

26:56 - 27:14

Jon Kroeper: That absolutely goes back to FINRA's mission, so that data enables us to better protect investors, to run our surveillance and conduct our exam programs and give investors the information they need to make wise investment decisions. And it also enables us to promote market integrity through the reviews that we conduct.

27:15 - 28:17

Kaitlyn Kiernan: Maybe all businesses should spend more time not just celebrating new initiatives, but when old programs and initiatives come to an end because the company has realized they have reached the end of their useful life. Ola and Jon, thank you so much for joining me to walk through the history of FINRA's commitment to transparency and how it impacts the market regulation program.

Listeners, you'll have to stay tuned for future episode that delves a little bit more into some exciting new technology that is being applied to the market surveillance patterns that Jon mentioned earlier. So, if you don't already, be sure to subscribe to FINRA Unscripted wherever you listen to podcasts, so you can be notified when that comes out. If you have any ideas for future episodes or thoughts to share on today's episode, you can email us at [email protected].

Today's episode was produced by me, Kaitlyn Kiernan, edited and coordinated by Stephanie Van den Burg and engineered by John Williams. That's it for today's episode. Until next time.

28:17 – 28:22

Outro Music

28:22 - 28:49

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28:49 – 28:55

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