Regulation Best Interest: Implementing a New Standard of Conduct
As of June 30, 2020, the U.S. Securities and Exchange Commission’s Regulation Best Interest—or Reg BI—is officially in effect. That means brokerage firms now have to comply with a new standard of conduct when working with retail clients.
On this episode we talk to Meredith Cordisco and Jim Wrona of FINRA’s Office of General Counsel about what a post implementation date world looks like for FINRA member firms and what FINRA has been doing to train staff to ensure a consistent approach to examining around and enforcing the new rule across the organization.
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00:01 - 00:22
Kaitlyn Kiernan: As of June 30, 2020, Regulation Best Interest--or Reg BI--is officially in effect. On this episode, we talked to two members of FINRA's Office of General Counsel about what a post implementation date world looks like for FINRA member firms. And we hear what FINRA has been doing to train staff to ensure a consistent approach across the organization.
00:22 – 00:31
00:31 - 00:52
Kaitlyn Kiernan: Welcome to FINRA Unscripted, from Hoboken New Jersey, I'm your host Kaitlin Kiernan. Today we got two new guests joining us from FINRA's Office of General Counsel, Meredith Cordisco and Jim Wrona. Jim and Meredith had been living and breathing Reg BI for more than a year now. And we're happy to have them on the show. Jim and Meredith welcome.
00:52 - 00:54
Meredith Cordisco: Thank you. Good to be here, Kaitlyn.
00:54 - 00:56
Jim Wrona: Yeah, thanks, Kaitlyn, appreciate it.
00:56 - 01:27
Kaitlyn Kiernan: So last year, on episode 45 we, talked to Bob Colby, FINRA's Chief Legal Officer, about the new regulation after it was first introduced. But now the implementation date, June 30th, has come to pass. So, we just wanted to check back in on the new regulation. But before we dig in, I'm sure you guys are more than willing to think about something other than Reg BI at this point, so let's just start talking about what's your background. Meredith why don't you start.
01:28 - 01:50
Meredith Cordisco: Sure. Well I have been in the Office of General Counsel here at FINRA for five years now. Before that I was in the securities group at a big law firm where I worked on broker-dealer matters and also some enforcement matters. And then between the law firm and starting at FINRA I did a brief stint at the Federal Reserve.
01:51 - 01:52
Kaitlyn Kiernan: Jim how about you.
01:52 - 02:03
Jim Wrona: Yeah, so I've been at FINRA for a long time now, always with the Office of General Counsel working on all sorts of interesting issues. And before that I was also at a large law firm.
02:04 - 02:11
Kaitlyn Kiernan: So, to get started on Reg BI, can you just give us a quick overview of the regulation Meredith?
02:12 - 02:15
Meredith Cordisco: Sure. Quick. Well I just thought--
02:15 - 02:17
Kaitlyn Kiernan: I know how many pages is it?
02:17 - 03:49
Meredith Cordisco: It's over a thousand between Reg BI and Form CRS together. So, I'll see if I can distill all of that into a minute elevator speech. But Reg BI is a new standard of care for brokers and dealers and their associated persons when they make securities recommendations to retail customers. And that includes recommendations as to types of accounts. It has four core obligations. So, disclosure, care, conflict of interest and compliance. And it's a really big deal for the industry, particularly the disclosure and the conflicts obligation are new, overarching obligations that the industry hasn't dealt with in that broad sweeping manner. And care also has significant enhancements from the current structure. So, it's a big deal for the BD industry.
Form CRS is a separate regulation that the SEC adopted at the same time they did Reg BI and it requires broker dealers and investment advisors who offer services to retail investors to file with the SEC and to deliver a relationship summary. And this is a really high level two-page document that gives general information about the firm and its services. So, things like fees, standard of conduct. And it's very prescriptive. Certain sections it has to have, certain conversation starters. It's really just meant to be easy to digest for the retail investor.
03:49 - 04:37
Jim Wrona: You know it's interesting, because people will ask us, "well isn't Reg BI really just suitability with some additional requirements?" And if you look at just the care obligations--so one of the four that Meredith mentioned for Reg BI--the care obligation alone is like suitability on steroids. You have to consider cost every time you make a recommendation, reasonably available alternatives, it applies to types of accounts. Those are significant enhancements. And that's only the care obligation. Then you get into disclosure. You get into conflicts of interest and particularly associated person-level conflicts that would have to be mitigated or eliminated. Those are quite different from what the industry has been used to just under the suitability regime.
04:38 - 04:50
Kaitlyn Kiernan: That is a lot for firms to have had to think about and develop a plan around implementation over the past year. So, what does it mean now that the implementation date has come to pass?
04:51 - 05:59
Meredith Cordisco: Well, it means that firms need to be in compliance with Reg BI to the extent that they make recommendations to retail customers. And what that means practically is they should have updated their policies and procedures to account for Reg BI. They should have made system changes to the extent necessary to account for the new standard and all of those things that Jim just mentioned, and they should have trained their reps, even if training is in a virtual setting now that we're all home because of the pandemic.
I would also add that there are open issues still and we know that, and, of course, we're middle of the pandemic. So right now, at least in these initial days post compliance date, we're not expecting perfection, but we, of course, would expect good faith efforts. For Form CRS it means that firms have to have filed it, they have or they should be in the process of delivering that Form CRS to their retail customers, and they should have policies and procedures and systems in place to deliver it going forward when the triggers are met and also to evidence that delivery.
05:59 - 06:19
Kaitlyn Kiernan: You know you mentioned that it doesn't only apply to product recommendations, but also account types. So, Jim, maybe you can tell us when does Reg BI apply? We had one question come in, "does it apply to all transactions or only those involving an order?" Are there any other situations firms should be considering?
06:19 - 06:44
Jim Wrona: Yes. So, for Reg BI any time that you make a recommendation to a retail customer as defined by Reg BI the rule kicks in. So, it doesn't matter whether there is an order that is affected or the results from the recommendation. Reg BI applies when you make a recommendation to a retail customer. So, at that point the obligations are triggers.
06:44 - 06:49
Meredith Cordisco: Surely, you're not saying that it applies even if the customer never executes the order?
06:50 - 06:53
Jim Wrona: No, that's exactly what I'm saying. And don't call me Shirley.
06:53 - 06:58
Meredith Cordisco: Listening audience I apologize. I was forced to ask that question.
06:58 - 07:24
Kaitlyn Kiernan: We've clearly got some Airplane! movie fans here today. FINRA sent an email to firms with an institutional customer-focus informing them that the SEC's definition of "retail customer" differs from FINRA's and that any "natural person," regardless of net worth, is considered a retail customer. Why was this email sent? And can you help define natural person for us?
07:24 - 09:41
Meredith Cordisco: Sure. So, as you note, Reg BI defines retail customer a bit differently than the industry may be used to. So, for example, under the suitability rule some high net worth individuals could be treated as institutions if other conditions apply. But that's no longer the case under Reg BI. So, any natural person--any human--regardless of how much money they have, if a firm is making a recommendation to them, and that recommendation is going to be used primarily for personal, household or family purposes, then Reg BI is going to apply. So, there's no sort of exemption for the super-rich.
The e-mail was sent because we had some growing concern that maybe some firms who would classify themselves as institutional firms may not be aware that Reg BI could apply to them if they actually make recommendations to some high net worth individuals. So, for example, anecdotally, we had heard some firms say "Look, Reg BI doesn't apply to us, we are an institutional shop. It's just not going to apply." So, they'd sort of been disregarding any communications about Reg BI or any information they see in the press about Reg BI because they mistakenly considered it as not applying to them at all.
But the next sentence they say is, "Of course, we have some high net worth individuals, some accredited investors, maybe, that we have as a combination account." You know, maybe they're executives of their institutional clients. And firms need to know that if they make recommendations to such individuals, and those people are using it primarily for personal, household or family purposes, then Reg BI applies to them.
So, in talking with our Small Firm Advisory Committee, we heard that many firms who mostly do institutional business may not be aware of this. And so that email was sent on behalf of our Small Firm Advisory Committee to sort of put the word out. And we've been talking a lot about this, and saying this a lot, but again, if a firm has already concluded mistakenly that Reg BI is not going to apply to them, they may not be listening to or focused on all the right the material that's out there. So that's why we put that out. We're still trying to get the word out.
09:41 - 11:01
Jim Wrona: And just to add to that, there's not a de minimis exception. So even if it's just one individual that you're accommodating and you're making recommendations to them, all of a sudden you are in the Reg BI/Form CRS world. But we also are trying to be helpful in the run up to Reg BI's compliance date to alert firms that might not have known that it could apply to them. So, there may be cases where it doesn't apply to them, and that's fine. But we just wanted to give firms kind of a heads up, the same way that we sent out an email to firms that have adviser or advisor in their title but are only registered as a broker-dealer.
So, one of the obligations in the Reg BI disclosure requirement is that there is a presumption against using the title adviser or advisor in their name if they're not duly registered as an investment adviser. We have a list of firms that fit into that category that we just sent a reminder communication to and said, look if you're not duly registered or if you're not registered as a municipal securities adviser or commodity trading advisor, just be careful to read closely the Reg BI disclosure obligation and the information release about it. But we just wanted to give firms a heads up.
11:02 - 11:15
Kaitlyn Kiernan: So, you mentioned that many of the institutional-focused firms that received that email were small firms. Just more broadly, how are small firms overall dealing with the implementation of Reg BI?
11:15 - 13:30
Jim Wrona: So, I think everybody, all broker-dealers, have worked really hard to meet their obligations and get ready for the compliance date. And small firms are no exception. Everybody has different challenges. So, some of the larger firms maybe had more different types of services and products offer to take into consideration, but they had bigger teams that were working on these issues. Small firms maybe had not as many customers, not as many different types of services or products available to deal with, but they had a smaller number of people working on it and more limited resources. So, I think everybody faced different types of challenges but there were all challenges.
Meredith mentioned that the releases for the Reg BI and Form CRS were a thousand plus pages and there were two other releases at the same time that were important. And so, we're talking several thousands of pages. So, everybody had to kind of roll up their sleeves and read those releases, read the rules and the additional guidance that the SEC came out with like FAQs and the small entity guides and the risk alerts and really understand what the SEC was looking for. And then once they did that, they would have to prepare their conflicts list--where our conflicts? How are we going to disclose? Or if we have to mitigate or eliminate those conflicts, how are we going to prepare our disclosure documents, the Forms CRS and the disclosures? How are we going to incorporate some of the important new elements into the care obligation? So, there was a lot to be done.
Thankfully people did take it seriously. I think the one thing that I'll say about my time in the securities industry is that everybody is working to a common goal. They do want to work in the best interests of their customers--that's just good business. Now they have the mandate to do that. And so, I think everybody was working towards that anyway, but they had to make sure that they hit all of the marks that were required by both Form CRS and Reg BI. And so, I think the small firms with their more limited resources that made it difficult from that side. But our understanding is that firms worked hard and were ready for that compliance date.
13:31 - 13:48
Kaitlyn Kiernan: The regulation was published only last June, so it was really just a year to prepare, and of course, over the past three months we've mostly been working remotely. Have you heard concerns from firms around how the COVID-19 pandemic has impacted their efforts to prepare?
13:48 - 15:20
Jim Wrona: Yeah nobody expected a pandemic. And so, it has made it more difficult for everybody. Folks are working from home, which makes it more difficult to get your teams together and make sure that everything's being done. Small firms, in particular, had to worry about third-party vendors that they were expecting to assist them. So, it could be that they needed a third-party printer to print up their Form CRS and Reg BI hardcopy disclosures that they were going to have to send out. And so, I think there was some angst about whether those third-party vendors could meet their commitments to our member firms because of staffing issues related to COVID-19.
We are doing this podcast from our homes not because it's more comfortable, but because we can't go into the office. So, I think that the same way for firms that maybe we're planning to have in-person training, all of a sudden at the last minute they had to switch gears to virtual training, which makes it difficult. If you're planning to do that all along, it's one thing, but if you have to switch at the very end right before the compliance date that's a struggle. And firms were able to do that, by and large, and they should pat themselves on the back because I think everybody really stepped up and worked hard to make sure that they were in compliance or used all reasonable efforts to make sure that they were in compliance by that June 30th date.
But yeah, there was a lot going on, and not to mention that I'm sure there were staffing issues at the firms because there were people either suffering from COVID-19 or that had loved ones that were. So, it's really remarkable how well everybody did under the circumstances.
15:21 - 15:36
Kaitlyn Kiernan: So how will firms be examined for compliance with this new regulation since it is an SEC regulation that FINRA is clearly very much involved in helping firms prepare for?
15:36 - 18:43
Jim Wrona: Yeah, so listen, we're gonna go in with the microscope and so every little detail better be absolutely perfect. No listen, that was a joke. So, if you're listening to this and your heart stop it was just a joke.
Look, the SEC put out risk alerts for both Reg BI and Form CRS. So, it really kind of mapped out the SEC's approach and the types of information and documents that they would be reviewing in anticipation of examinations. And one of the things that they emphasized is that they're looking for a good faith effort to comply with Reg BI and Form CRS. And we put out a statement the next day that said that we were going to take the exact same approach, that we're looking for good faith efforts to comply with Reg BI and Form CRS.
So, what does that mean? It means that we're going to go in and probably look primarily at the compliance obligation on the Reg BI side. So that's things like your policies and procedures and training. You know there may be certain instances where we've done risk analysis and maybe a firm has had difficulties complying with some sales practice obligations, and so we'll take a look at some of the care obligations as well, or maybe they've had an interesting way of dealing with compensation, and so maybe we'll look at conflicts a little bit more closely. But by and large, we're going to be looking at the compliance obligations of policies procedures and training, and we're not looking at it to say, "did a firm do everything the way that we would have done it," or "did they do everything perfectly." We're looking to see do they understand the obligations, and do they make a good faith effort to implement the changes that needed to be made and incorporate those in their policies procedures and training.
The one thing that I'll say is that a firm that does have difficulty meeting their obligations under the old standards, if we go in and we see that they're continuing to have a sales practice related issues--if we go in and see that someone is churning an account--we're not going to give the firm a pass just because this is a Reg BI good faith effort type examination. If there's customer harm involved, if it's something that would've been a violation under the previous standards, we're going to take a close look at that.
But by and large, in terms of the compliance with these new obligations we're looking for good faith efforts and that's kind of the initial rounds of examinations. And then as we, and the SEC and firms gain experience with both Reg BI and Form CRS then we'll start doing deeper drives to make sure that all of the different obligations are being met. And we'll probably have a better sense then of what works and what doesn't work, and firms are going to take the same approach. So, they've done their best to make sure that they're in compliance. They've done their best to make sure that they're acting in the customer's best interests, but they may find with some experience that certain ways of dealing with obligations isn't as effective as they had anticipated. And so, they'll make changes, they'll tweak their policies and procedures or approaches to issues. So, it'll be somewhat evolving over the course of the next year or two.
18:44 - 18:52
Kaitlyn Kiernan: So, you mentioned the first round of examinations. When will firms start seeing Reg BI included in exams?
18:52 - 19:17
Jim Wrona: Yeah, so it's already started. So, there were probably some open examinations pre- compliance date that were still open or hadn't closed. And examiners might have asked some questions about Reg BI and Form CRS as part of the closing out of the exams. New examinations are being scheduled all the time. And certainly, at this point, they'll be looking at Reg BI and Form CRS.
19:17 - 19:33
Kaitlyn Kiernan: So, Jim, you started with the joke about being under a microscope, but it is true that we've gotten a lot of questions from firms worried that there's going to be a gotcha approach to this whole examination process. Can you say anything else to reassure listeners?
19:33 - 22:07
Jim Wrona: Yeah. Listen, these are really really important obligations and we want firms to take them seriously, but we also understand how much of a change this has been for many firms and how much work they put into it and that they're trying to do the right thing. And speaking with the SEC, they're of the same mindset. They want to make sure that you've put the work in that you've tried very hard to understand the obligations and the changes that you as a firm need to make. But we do understand that this was a big ask.
And so that implementation period was approximately a year. And it sounds like a long time, but when you think about everything that had to be done within that year it's really not that long at all. From our side, we have trained our examination staff. We've trained our enforcement staff not only on understanding the obligations from a substantive standpoint, but also understanding the approach that we want to take.
So, this good faith effort is something that we've talked to all of our examiners, all of our, enforcement attorneys. And there's been a lot of training. I mean, Meredith and I have been a part of that training. We've helped to prepare everybody. And we had preparedness reviews leading up to the compliance day just to get a sense of where the industry was--these weren't examinations, these were just really conversations to see where the pain points were for firms and how firms were progressing and getting ready for the compliance day. And so, we went through a training session with examiners at that point, and then we had an online course that included questions that the examiners enforcement attorneys had to answer. And then we did virtual, live training with the examiners and the enforcement attorneys. And then we had separate Q&A sessions.
There's been a lot of effort put into making sure that everybody understands the substance of Reg BI and Form CRS. But as part of that training, we've also talked about our approach. And I think that that's really important. We're a large organization and there's a lot of different firms, a lot of different geographic locations. There are different business models, different customer bases, different product lines and everything else, but we want as an organization a consistent approach. And so, we thought that that was really important. One of the other things we've done is to make sure that as issues arise through examinations that there is a central group that are kind of the experts at FINRA on Reg BI and on Form CRS, so those issues will get to that group, so that group will ensure that there is consistency among the organization and among the different examinations.
22:08 - 22:44
Meredith Cordisco: Yeah, and that will be a cross-functional group. So, it'll have members of OGC, obviously--Jim and I will be on that, and members from our Member Supervision, so our examination staff, members from our enforcement staff and others. So we'll really see different perspectives and we'll talk through issues and, when needed, to the extent that any interpretive questions arise, we will take those back to the SEC staff to get clarity to ensure consistency not only within FINRA, but also to ensure consistency across regulators, so that we know that we and the SEC are taking a consistent approach with examination and enforcement on Reg BI and Form CRS.
22:44 - 23:07
Jim Wrona: And let me give a shout out to the SEC staff, because they've been really good partners. We meet with them very frequently and they've been very helpful. At the end of the day, these are their obligations and as Meredith said, when an interpretive issue arises, they're the ones that are going to have to resolve those interpretive issues. But they've been very open with us as we kind of work through some of the rough spots.
23:07 - 23:22
Kaitlyn Kiernan: It's good to hear. So, Meredith, we had another question come in, and it was how does FINRA intend to test firms that allow supplemental oral disclosures for Reg BI purposes. Do you have anything you can say about that?
23:22 - 24:54
Meredith Cordisco: Sure. Well the disclosure obligation is one of these four core obligations, and it requires written disclosures before or at the time of the recommendation. And there are a lot of particular things that are required in those disclosures, many of which will be standardized. But it does allow for supplemental oral disclosure when such disclosures are necessary. If you have to disclose material facts that is not disclosed in those standardized disclosures, if there there's a particular conflict associated with the recommendations not been disclosed or a particular conflict related to that associated person who's making that particular recommendation.
And the SEC has said that firms should document the fact that they're making that supplemental oral disclosure and the fact that it took place. But you don't necessarily have to disclose the substance of those discussions. But they've also said as a best practice that firms probably want to or probably should follow any of those oral disclosures with timely written disclosures summarizing what was conveyed orally.
So, this is just another area when we're talking about good faith approach and we're talking about focus on compliance. Firms should be amending their policies and procedures or should have amended their policies and procedures to account for this. And when supplemental oral disclosures are permitted and indeed required, reps should know how they're going to do that.
24:55 - 25:03
Kaitlyn Kiernan: One other question I had is at the top of the discussion, Meredith, you mentioned there are still some open issues. Can you tell us what those are?
25:04 - 25:04
Jim Wrona: Yeah, list them out, Meredith!
25:06 - 25:07
Meredith Cordisco: How much time you got?
25:10 - 25:11
Jim Wrona: There's a lot.
25:11 - 26:55
Meredith Cordisco: There are a lot of issues that haven't been addressed with particularity because many aspects of this regulation on Reg BI are really principles based and will depend upon the facts and circumstances. That makes a lot of people very uncomfortable, and with good reason, perhaps. There's not always absolute clarity on all of the requirements. And so, we have heard from the industry, we've done a lot outreach.
Certain questions--to the extent that they're interpreted--we take them back to the SEC. So I'll give you an example of one area where we have heard a lot of questions and I know that this has been raised with the SEC, too, is to whether family offices, for instance, are included in the definition of retail customers such that a recommendation to a family office falls within Reg BI. And that's something that the SEC is considering, but they haven't put out guidance on that stating one way or another. So that's just one area.
And this is another area where I think the good faith approach really kicks in. And that's because, frankly, we know firms have had to make judgment calls on some of these areas that aren't crystal clear. And so as long as they have made those judgment calls--reasonable judgment calls--and they have a rational basis for those and have documented that, when we go into examine, to the extent that the SEC later comes out with clarifying guidance that contradicts their judgment calls, that's something that we're going to take into account that, yes they considered it. Yes, they had a reasonable decision and they didn't have perfect clarity in this issue, and they've addressed it in this way, and going forward they're going to shift what they've done to come into now the new guidance on that point. So, we are cognizant that not every aspect of it is crystal clear.
26:55 - 27:07
Jim Wrona: The only thing that I'll add to that is that we wouldn't want to see if the SEC does come out with contrary guidance that the firm is making efforts to make the changes to be compliant, understanding that that might take a little bit of time.
27:07 - 27:17
Kaitlyn Kiernan: As firms are working through and have this new regulation implemented. How is FINRA continuing to work to support firms?
27:18 - 29:37
Jim Wrona: You started this podcast out by saying that we've been living and breathing Reg BI and Form CRS now for more than a year, and that's true. And part of the reason for that is not only that we wanted to get a firm understanding of the requirements and what the firms were doing to meet their obligations, but also because we were trying to be helpful to broker-dealers that were confronted with these new significant obligations.
And so, what we've done is, first, we set up a dedicated web page for Reg BI and Form CRS. It's a one stop shop. It collects all the information that we've put out publicly, all of the information that the SEC has put out publicly, although there was so much information, I think we now just have a direct link to the SEC's dedicated webpage. They didn't originally have one, but they do now. And so, you can go to our dedicated Reg BI/Form CRS web page at the FINRA site and everything that's been published by the SEC or FINRA is available there. That's one thing.
We've also tried to outreach with our committees, with all of the different broker-dealers that have raised issues to us, to get a better understanding of the pain points for them, the interpretive issues that they would like additional information on, and we've relayed that information to the SEC staff. We have put on conferences and had both in-person conferences before the pandemic and post-pandemic virtual panels on Reg BI and Form CRS that usually involve SEC staff that have been working on Reg BI and Form CRS. We will continue to do that.
We will continue to post on our dedicated web page any information that the SEC or FINRA issues related to these topics. We will continue to provide other resources. We had a firm checklist early on that firms could use to understand the differences between the obligations pre-compliance date and the obligations post Reg BI and Form CRS compliance. So, we've really worked hard to try to get an understanding of how we can assist the broker-dealers and have worked very closely with them and with the SEC staff, and we'll continue to do that.
29:38 - 29:40
Meredith Cordisco: And we're doing this podcast!
29:40 - 29:41
Jim Wrona: Yeah, and we're doing this podcast!
29:41 - 29:51
Kaitlyn Kiernan: And we will put this podcast on that Reg BI as well. So final question. If firms have additional questions where can they go with those?
29:51 - 29:52
Jim Wrona: Call Meredith!
29:52 - 30:17
Meredith Cordisco: So, we're always here, but if have questions, particularly interpretive questions, they can go directly to the SEC and the SEC has set up a dedicated mailbox for questions about Reg BI and Form CRS, and that is [email protected] And it will be directed to the appropriate staff at the SEC who handle Reg BI and Form CRS.
30:17 - 30:39
Jim Wrona: Yeah, and I have to say that some firms are reluctant to send questions directly into the SEC, and so sometimes they go through an association. But other times they're comfortable coming to us at FINRA, and we'll convey the information to the SEC staff and we're happy to continue being that conduit.
30:39 - 30:57
Kaitlyn Kiernan: Well, thanks, Meredith and Jim, for joining us. Listeners, if you don't already, make sure you subscribe to FINRA Unscripted on Apple Podcast, Spotify or wherever you listen to podcasts. If you have any ideas for future episodes you can email us at [email protected] Until next time.
30:57 - 30:58
Jim Wrona: Wait--can I tell a dad joke?
30:59 - 31:00
Kaitlyn Kiernan: Yeah, go for it.
31:00 - 31:04
Jim Wrona: All right so did you hear about the guy that invented Altoids?
31:04 - 31:05
Kaitlyn Kiernan: No.
31:05 - 31:07
Jim Wrona: He discovered a mint.
31:08 - 31:13
Meredith Cordisco: Wow, you made me ask you the Shirley question and this? It is too much.
31:13 - 31:16
Kaitlyn Kiernan: Well with that, we'll actually sign off.
31:16 – 31:21
31:21 - 31:49
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31:49 – 31:55
Music Fades Out