Trade Adjustment Assistance for Workers Reversion Primer 2013

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The 2011 amendments to the Trade Adjustment Assistance for Workers program expire on December 31, 2013. If there is no action taken by Congress, the program will revert to a modified version of the 2002 program. This presentation represents a summary of what that reverted program will look like. Congress may pass legislation prior to December 31, 2013, or may even pass legislation after that date with retroactive provisions (as they did in 2011). ETA will issue official guidance to the system based on either an expectation of reversion or Congressional action. This presentation is intended to provide an informal summary to the system and stakeholders. Questions should be directed to the appropriate Regional Office.

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Trade Adjustment Assistance for Workers Reversion Primer 2013

  1. 1. Employment and Training Administration Region 1 (#ETARegion1) December 2013 v2.2.1
  2. 2. United States Department of Labor Mission Statement To foster, promote, and develop the welfare of the wage earners, job seekers, and retirees of the United States; improve working conditions; advance opportunities for profitable employment; and assure work-related benefits and rights. www.dol.gov/100 2
  3. 3. Disclaimer The 2011 amendments to the Trade Adjustment Assistance for Workers program expire on December 31, 2013. If there is no action taken by Congress, the program will revert to a modified version of the 2002 program. This presentation represents a summary of what that reverted program will look like. Congress may pass legislation prior to December 31, 2013, or may even pass legislation after that date with retroactive provisions (as they did in 2011). ETA will issue official guidance to the system based on either an expectation of reversion or Congressional action. This presentation is intended to provide an informal summary to the system and stakeholders. Questions should be directed to the appropriate Regional Office. 3
  4. 4. Materials Overview  2011 Amendments – Reversion  Eligible Worker Groups  Reemployment-Alternative Trade Adjustment Assistance (R-ATAA)  Deadlines, benefits amounts, application process, etc.  Trade Adjustment Assistance (TAA)  Training, waivers, etc.  Trade Readjustment Allowance (TRA)  Deadlines, durations, etc.  Case Management  Job Search & Relocation  Health Coverage Tax Credit  Merit Staffing Requirements  Financial Management & Program Reporting 4
  5. 5. All good things must come to an end. 2011 Amendments Reversion Language 5
  6. 6. 2011 Legislative Language SEC. 233. SUNSET PROVISIONS. APPLICATION OF PRIOR LAW.—Subject to subsection (b), beginning on January 1, 2014, the provisions of chapters 2, 3, 5, and 6 of title II of the Trade Act of 1974 (19 U.S.C. 2271 et seq.), as in effect on February 13, 2011, shall apply, except that in applying and administering such chapters…  On December 31, 2013, the Trade Adjustment Assistance for Workers program will revert to a modified version of the Trade Reform Act of 2002 6
  7. 7. Because who doesn’t love government forms? Petition Process & Worker Group Eligibility 7
  8. 8. Filing Petitions Online at www.doleta.gov/tradeact Fax to: (202) 693-3585 Mail to: U.S. Department of Labor, Office of Trade Adjustment Assistance 200 Constitution Avenue, NW, Room N-5428 Washington, DC 20210 NOTE: Deadline to file for coverage under 2011 provisions is 11:59pm EST, Tuesday, December 31, 2013 8
  9. 9. Who Can File a Petition?      Group of 3 or more workers Company Official Union State Workforce Official American Job Center Network Partner – Rapid Response, Employment Service, Unemployment Insurance, WIA provider, etc. 9
  10. 10. Petition Processing  Upon receipt of petition, investigators contact the company  Gather information on locations, temp workers, remote workers, divisions within company  Company provides information on a confidential basis to the Department  Investigator recommends decision to a Certifying Officer who issues the decision  States ensure the provision of Rapid Response services, if not already provided  Process takes approximately 40 days 10
  11. 11. Primary Affected Workers – Reversion 2014  Increased imports (all must be true)  Criterion 1: Significant number/proportion of workers totally or partially separated or threatened with separation  Criterion 2A: – Sales and/or production has decreased absolutely – Imports like or directly competitive with goods produced by workers’ firm have increased – Increased imports contributed “importantly” to actual/threatened separation 11
  12. 12. Shift In Production – Reversion 2014  Shift in production (both must be true)  Criterion 1: Significant number/proportion of workers totally or partially separated or threatened with separation  Criterion 2B: – There has been a shift of production by workers’ firm of like or directly competitive articles to certain foreign countries. 12
  13. 13. List of Specific Nations – Shift In Production  Free Trade Agreements (http://www.trade.gov/fta/) – Australia, Bahrain, Chile, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua, Canada, Mexico, Israel, Jordan, Morocco, Oman, Peru, Singapore  Andean Trade Preference Act (http://www.ustr.gov/tradetopics/trade-development/preference-programs/andean-trade-preference-actatpa) – Bolivia, Colombia, Ecuador – Peru (Now a free-trade nation.) NOTE: The list of nations with free trade agreements is subject to change. List as of October 31, 2013. 13
  14. 14. List of Specific Nations – Shift In Production  Caribbean Basin Economic Recovery Act (http://www.ustr.gov/trade-topics/trade-development/preferenceprograms/caribbean-basin-initiative-cbi) – Antigua and Barbuda, Aruba, The Bahamas, Barbados, Belize, Dominica, Granada, Guya na, Haiti, Jamaica, Montserrat, Panama, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Trinidad and Tobago, Virgin Islands (British) – List as of June 10, 2013 14
  15. 15. List of Specific Nations – Shift In Production  African Growth and Opportunity Act (http://trade.gov/agoa/eligibility/index.asp) – Angola, Benin, Botswana, Burkina Faso, Burundi, Cameroon, Cape Verde, Chad, Cote d’Ivoire, Comoros, Republic of Congo, Djibouti, Ethiopia, Gabonese, The Gambia, Ghana, Guinea, Kenya, Lesotho, Liberia, Mala wi, Mauritania, Mauritius, Mozambique, Namibia, Niger, Nigeria, Rwanda, Sao Tome and Principe, Senegal, Seychelles, Sierra Leone, South Africa, Swaziland, Tanzania, Togo, Uganda, Zambia NOTE: The list of eligible nations under AGOA is subject to change. Please check the trade.gov site for the most recent changes. 15
  16. 16. Worker Group Eligibility – Reversion 2014  Upstream (Secondary) 1. Firm that produces and supplies component parts directly to another firm 2. Component parts must be directly incorporated into articles that were the basis of certification for primary workers – Primary workers must be certified – Separations (or threat) at secondary firm – In addition, one of the following must be true: • Component parts accounted for at least 20% of upstream producer’s production or sales • Loss of business contributed importantly to workers’ actual or threatened separation 16
  17. 17. Worker Group Eligibility – Reversion 2014  Downstream (Secondary) 1.Firm that performs additional, value-added production processes directly for a firm for articles that were basis of certification 2.Downstream production can include final assembly or finishing – Must meet the following criteria: • Separations (or threat) at secondary firm • Loss of business with primary firm must have contributed importantly to separations at secondary firm • Applies only to primary certifications based on increased imports from or shift in production to Canada or Mexico 17
  18. 18. Worker Group Eligibility Matrix Program Version Manufacturing Services Public Sector Shift in Production / Secondary Certs 2002 YES NO NO Limited Countries 2009 YES YES YES Any Country 2011 YES YES NO Any Country Reversion 2014 YES NO NO Limited Countries 18
  19. 19. Petition Series I. TA-W-69,999 and below Amendment / Version TAARA (2002 Amendments) Guidance II. TA-W-70,000 - TA-W-79,999 TGAAA (2009 Amendments) TEGL 22-08 and Change 1; Omnibus Trade Act; and 20 CFR parts 617 and 618, and 29 CFR part 90. III. TA-W-80,000 - TA-W-80,999 TAARA (2002 Amendments) –orTAAEA (2011 Amendments) These workers are subject to either (I) or (IV), per TEGL 10-11. IV. TA-W-81,000 - TA-W-84,999 TAAEA (2011 Amendments) TEGL 10-11, and Changes 1, and 2; and 20 CFR parts 617 and 618 and 29 CFR part 90. V. TA-W-85,000 and above Reversion 2014 (2002 Amendments with TAAEA sunset provisions) TEGL 11-02 and Changes, 1, 2, and 3; TEGL 2-03, and Change 1; and TEGL 10-11, and its Changes 1 and 2 where it applies 2011 policies retained per the 2011 sunset provisions; the operating instructions; and 20 CFR parts 617 and 618, and 29 CFR part 90, 11/26/2013 TEGL 11-02 and Changes 1, 2, and 3; TEGL 2-03, and Change 1; 20 CFR parts 617 and 618, and 29 CFR part 90. 19
  20. 20. Appealing Petition Denials – All Programs 1. Request administrative reconsideration of the determination; 2. Seek judicial review of the determination; and/or, 3. Seek reemployment services from other programs through the American Job Center Network (ie: WIA, NEG, ES) 20
  21. 21. What’s old is new. Alternative Trade Adjustment Assistance – Filing and Benefits 21
  22. 22. ATAA and the Petition Process – Reversion 2014  Revised petition forms will include a box for petitioners to check to indicate that the worker group wishes to be considered for ATAA group eligibility 22
  23. 23. ATAA Group Certification – Reversion 2014  Criterion 1: A significant number of adversely affected workers in the petitioning workers’ firm are 50 years of age or older (the lesser of 5% or 50 workers);  Criterion 2: The adversely affected workers in the petitioning workers’ firm possess job skills that are not easily transferable to other employment; and  Criterion 3: The competitive conditions within the affected workers’ industry are adverse. 23
  24. 24. ATAA Eligibility – Reversion 2014  From a worker group that has been declared ATAA eligible  Reemployed within 26 weeks of most recent qualifying separation - not certification  At least 50 years of age at the point of reemployment  Verified through appropriate documentation, such as a birth certificate or driver’s license  TEGL 10-11, Change 2 not applicable to ATAA  Employed full-time as defined by state law  Should be verified with job offer letter or pay stub  Earns no more than $50,000 a year at new employment 24
  25. 25. ATAA Individual Eligibility – Reversion 2014  Does not return to employment from which the worker was separated (recall)  The application for ATAA must be filed within two years of the first day of qualifying reemployment  The worker must indicate that a “choice” has been made and that the worker understands that he/she cannot subsequently switch to the TAA program once they begin receiving the ATAA supplement – Receipt of the initial ATAA payment represents the individual’s decision with respect to choosing ATAA and voids the participant’s rights to retraining, allowances and TRA. – Correspondingly, once a worker has enrolled in training, he/she forfeits his/her right to ATAA participation. 25
  26. 26. ATAA Benefits – Reversion 2014  50 percent of the difference between:  The wages received by the worker from reemployment; and  The wages received by the worker at the time of separation.  Up to $10,000 26
  27. 27. ATAA / RTAA Matrix Trade Program Full Time Employment Part Time Employment Training + RTAA Maximum Amount 2002 – ATAA YES NO NO $10,000 2009 – RTAA YES YES YES $12,000 2011 – RTAA YES YES YES $10,000 Reversion 2014 YES NO NO $10,000 27
  28. 28. It’s not just training, it’s an adventure. Trade Adjustment Assistance (Training) 28
  29. 29. Training Under Reversion 2014  Only full-time training can be approved  Part-time training cannot be approved  Distance learning allowable  Prerequisite and Remedial courses allowable  Maximum of 130 weeks of training 29
  30. 30. Training-Related Costs – All Programs  Allowable – All tuition & fees; – Books, uniforms, supplies, equipment – Transportation costs (mileage, mass transit, parking) – Laptops and software (including tablets) may be purchased if they are required for all students by the institution for the approved training program – Health insurance premium costs, if all students are required to carry health insurance and they are not otherwise covered – Initial professional licensing fees and licensing exam fees  Not Allowable (under TAA funds) – Child care, Auto repair, etc. • Allowable under WIA, NEG and other partner programs 30
  31. 31. Training Matrix Program Maximum Weeks of Approved Training Part-Time Training Allowable Breaks in Training (Days) for TRA Remedial Training / Prerequisite Courses Online Training 2002 130 NO 30 YES YES 2009 156 YES 30 YES YES 2011 130 YES 30 YES YES Reversion 2014 130 NO 30 YES YES 31
  32. 32. Deadlines, waivers and duration, oh my! Trade Readjustment Allowance 32
  33. 33. Enrollment Deadlines Under Reversion 2014  8/16 week deadline for enrollment in training or waiver from training – – – – – 8 weeks from the date of the petition certification; OR 16 weeks from the worker’s most recent total separation from adversely affected employment 45-day “extenuating circumstance” extension is possible No good cause exceptions (Federal or state) allowed Equitable tolling is permissible (TEGL 08-11)  TRA eligibility: – – – From TEGL 11-02, Change 3, the above does not apply to be eligible for Basic TRA, if the determination is made before the training deadlines. A worker may receive Basic TRA prior to the 8/16 if all other eligibility has been met in the Section 231(a) of the Act. Once the enrollment deadline (8/16) is reached, the training requirement must be met: enrolled in training or receipt of a waiver. 33
  34. 34. “Enrolled in Training” – All Programs  20 CFR 617.11(a)(2)(vii)(D) – “Enrolled in training” means that the worker’s application for training has been approved by the CSA and that the training institution has furnished written notice to the CSA that the worker has been accepted into the approved program which is to begin within 30 days of such approval.  Once “enrolled in training,” a participant is no longer subject to the EB work test or work search requirements under UI laws 34
  35. 35. TRA Deadline Related Provisions Enrollment Deadline Provisions 2002 2009 2011 Reversion 2014 45-day Extenuating Circumstances Extension YES YES YES YES State Good Cause Provisions Allowable NO YES NO NO Federal Good Cause Provisions Allowable NO NO YES NO Military Service Deadline Extension Available NO YES YES NO 210-day Bona Fide Application for Training Rule YES NO NO YES Equitable Tolling Allowable YES YES YES YES Allowable Grounds for Extension of 104 Week Eligibility Period for Basic TRA 2002 2009 2011 Reversion 2014 Judicial or Administrative Review Extension NO YES YES NO Justifiable Cause to Extend the Period NO YES YES NO Military Service Deadline Extension NO YES YES NO
  36. 36. Waivers Under Reversion 2014 Sunset provision limits the available waiver types to: Health, Enrollment Unavailable and Training Not Available  Health – The worker is unable to participate in training due to the health of the worker, except that this basis for a waiver does not exempt a worker from the availability for work, active search for work, or refusal to accept work requirements under Federal or State unemployment compensation laws.  Enrollment Unavailable – The first available enrollment date for the worker’s approved training is within 60 days after the date of the training determination, or, if later, there are extenuating circumstances for the delay in enrollment, as determined under guidance issued by the Secretary.  Training Not Available – Training approved by the Secretary is not reasonably available to the worker from either governmental agencies or private sources (which may include area vocational schools as defined in section 3 of the Carl D. Perkins Vocational and Technical Education Act of 1998 (20 USC 2302) and employers), no suitable training for the worker is available at reasonable cost, or no training funds are available. 36
  37. 37. First Payable Week (TRA) • Under Reversion 2014, the first week of TRA eligibility is the week that begins more than 60 days after the date on which the petition that resulted in such certification was filed. • This is the same as 2002 but a change from 2009 and 2011 37
  38. 38. Weeks of TRA – Eligible Weeks for Payment  Under the Reverted Program, the maximum payable weeks of TRA set at 130 – Basic TRA = 52 weeks – Additional TRA = 65 weeks (13 grace weeks) – Completion TRA = 13 weeks (7 grace weeks) 38
  39. 39. Completion TRA – Reversion 2014  13 weeks of Completion TRA, payable over a 20 week period, for a participant that: – Is actively participating in training expected to lead to an industry-recognized credential – Has substantially met the performance benchmarks established as part of the training approved for the worker; – Is expected to continue to make progress toward the completion of the training; and – Will complete the training during that period of eligibility. 39
  40. 40. Additional TRA Matrix Program Total Weeks Payable Payable TRA Within Election (Weeks) Earnings Disregard Remedial / Prerequisite TRA (Weeks) Completion TRA (Weeks) 2002 52 52 NO NO YES (26 R) NO 2009 78 91 YES YES YES (26 R/P) NO 2011 65 78 YES YES NO YES (13) Reversion 2014 65 78 NO NO NO YES (13) 40
  41. 41. “The purpose of these employment and case management services is to provide workers the necessary information and support for them to achieve sustainable reemployment.” – TEGL 22-08 Case Management and Related Services 41
  42. 42. Case Management – Reversion 2014  Requires cooperating state agencies (CSAs) to, “make every reasonable effort,” to provide case management services through co-enrollment in ES, WIA, NEG or other partner programs  Assessments and labor market analysis required prior to approval of training  Co-enrollment with partner programs will be essential for participant success 42
  43. 43. Location, location, location. Job Search and Relocation 43
  44. 44. Job Search – All Programs  To cover allowable costs related to travel outside of a participant’s commuting area to seek suitable employment  Usually related to job interviews.  Must be within the “United States”  Limited to the 50 states, DC & Puerto Rico  Must be pre-approved by the state 44
  45. 45. Job Search Benefit Amount – Reversion 2014  Provided in accordance with the regulations of 20 CFR 617.49  90% of allowable costs up to $1,250  May included multiple trips  Governed by Federal Travel Regulations at 41 CFR §301  No longer an optional provision 45
  46. 46. Relocation – All Programs  To cover allowable costs to relocate a participant, their immediate family and their household goods to suitable employment outside of their commuting area  Limited to the 50 states, DC & Puerto Rico  Must be pre-approved by the state 46
  47. 47. Relocation Benefit Amount – Reversion 2014  Provided in accordance with the regulations of 20 CFR 617.40 through 617.48  90% of allowable costs  Lump sum payment up to $1,250  Governed by Federal Travel Regulations at 41 CFR §302  No longer an optional provision 47
  48. 48. Take two of these and call me in the morning. Health Coverage Tax Credit (HCTC) 48
  49. 49. Health Coverage Tax Credit (HCTC)  HCTC expires effective December 31, 2013  No advance or other tax credit will be available for the 2014 tax year under HCTC 49
  50. 50. Regulations are not statutes, statutes are not regulations. Merit Staffing Requirements 50
  51. 51. Merit Staffing Requirements – All Programs  20 CFR 618.890 [excerpt] – “The State must… engage only State government personnel to perform Trade Adjustment Assistance (TAA)-funded functions undertaken to carry out the worker adjustment assistance provisions of the Trade Act of 1974…”  The merit staffing requirement applies to all Trade programs and is not impacted by program reversion  States may continue to outsource functions that are “not inherently governmental” 51
  52. 52. Follow the money. Financial Management 52
  53. 53. Trade Funding Types  TAA = Training, job search, relocation, case management & related costs  TRA = Income support benefits  A/RTAA = Wage insurance payments 53
  54. 54. Funding for FY 2012, FY2013 and FY2014 through December 31, 2013 RTAA TRA Admin Job Search & Relocation Case Management Training Uncapped Funds Consolidated Allocation $575M CAP Conditions: Up to 10% of Consolidated Allocation may be used for Administration Not less than 5% of Consolidated Allocation must be used for Case Management 54
  55. 55. Recapture and Financial Reporting  DOL may recapture funds from States with remaining un-obligated funding  DOL may distribute recaptured funds to States in need of additional funding  Trade-specific ETA-9130 will remain in use 55
  56. 56. TAA Program, Case Management and Admin How much can I spend for what?  Be mindful of funding source – must be an allowable activity under that funding stream to be charged to the grant  Citations: Trade Act 235(A)(1)(6); TEGL 22-08 Section G(2) and G(3); TEGL 1011; 20 CFR 618 56
  57. 57. Funding Status Issues / Recommended Practices  3 Year Money  Trade funds are available for obligation and expenditure for three years  Different Law = Different Restrictions  You can only charge allowable costs to grants the activity is allowable under  Expiration and Closeout  Shifting pots  Must follow proper cost allocation  Ideally, funds should be expended as First In, First Out 57
  58. 58. Reversion 2014 Funds Awarded After December 31, 2013 ATAA Training TRA Admin Job Search Relocation Case Management ETA is still developing final guidance and interpretations of the allowability of costs under funding provided after Consolidated Allocation “Uncapped” Funds January 1, 2014. Additional guidance will $220m per year in Training Costs capped at be provided the near future. Conditions (reverted program): Costs for case management and related costs for participants covered under certifications issued under Reversion 2014 may not be charged to TAA Program funds. 58
  59. 59. Mean, and median, and mode! Oh, my! Program Reporting Requirements 59
  60. 60. Trade Act Participant Report (TAPR)  There are no changes to the TAPR as a result of program reversion  www.doleta.gov/performance 60
  61. 61. (Almost) Everything above in two handy slides! Program Reversion Summary 61
  62. 62. Reversion 2014 Program  No Trade funds available for case management or related costs for participants covered under Reversion 2014 certifications  Costs will need to be covered under ES, WIA, NEG or other American Job Center partner programs  Only three training waivers available  Health, Enrollment Not Available and Training Not Available will continue to be the only allowable waivers  No Remedial/Prerequisite TRA available  Completion TRA remains available  8/16 Week Deadline Re-established  No Earnings Disregard for TRA  No Election Provision for TRA  Service sector workers no longer eligible for certification  Shift in production certifications limited to certain countries  ATAA requires group certification prior to individual eligibility 62
  63. 63. Trade Program Major Element Matrix 2002 2009 2011 Reversion 2014 Service Workers Eligible NO YES YES NO Limited Countries for Shift in Production Cert. YES NO NO YES Maximum Length of Training (Weeks) 130 156 130 130 Part-time Training Allowable NO YES YES NO Earnings Disregard & TRA Election Provisions NO YES YES NO 6 6 3 3 Training Enrollment Deadlines (Weeks) 8/16 26/26 26/26 8/16 Prerequisite/Remedial Training Allowable YES YES YES YES Remedial TRA Available YES YES NO NO Prerequisite TRA Available NO YES NO NO Completion TRA Available NO NO YES YES Group Eligibility Required for ATAA YES NO NO YES Number of Waiver Types Available
  64. 64. Because knowing, is half the battle. References and Contacts 64
  65. 65. Internet References  TAA Homepage  http://doleta.gov/tradeact/ 65
  66. 66. Key References – Statutes and Regulations  Trade Act of 1974, as amended  19 USC 12  Public Law 93-618 (Trade Act of 1974)  Public Law 100-418 (aka: The 1988 Amendments)  Public Law 103-182 (NAFTA)  Public Law 106-113 (FY2000 consolidated appropriation)  Public Law 107-210 (TAA Reform Act of 2002)  Public Law 111-5 (Trade and Globalization Adjustment Assistant Act of 2009)  Public Law 112-40 (Trade Adjustment Assistance Extension Act of 2011)  20 CFR 617 (TAA/TRA Program Rules)  20 CFR 618.890 (Merit Staffing & Funding)  29 CFR 90 (Petition Process) 66
  67. 67. Key Guidance - TEGLs  TEGL 11-02 (2002 Operating Instructions)  Changes 1, 2 & 3  TEGL 02-03 (ATAA, RTAA reference)  Changes 1, 2  TEGL 22-08 (2009 Operating Instructions)  Change 1  TEGL 10-11 (2011 Operating Instructions)  Changes 1, 2        TEGL 05-00 (Program Integration) TEGL 21-00 (Program Integration) TEGL 15-12 (Program Integration) TEGL 05-01 (Travel) TEGL 09-05 (Distance Learning) TEGL 13-05 (Remedial Training) TEGL 08-11 (Equitable Tolling) 67
  68. 68. Key Guidance - UIPLs  UIPL 17-87 (Strike/Lockout)  UIPL 25-87 (Bumped Workers)  UIPL 29-91 (Incapacitated/Deceased)  UIPL 31-00 (TRA TAG) 68
  69. 69. Key Guidance - HCTC  UIPL 02-03 (Initial Guidance)  UIPL 05-03 (HCTC)  UIPL 33-03 (HCTC Q&A)  UIPL 05-06 (HCTC 1099-G)  UIPL 21-09 (HCTC)  UIPL 12-11 (ARRA Reversion)  TEGL 10-02 (Bridge/Gap-Filler Grants) 69
  70. 70. Regional Office Contacts – Region 1 Timothy Theberge Regional Trade Coordinator (Primary) 617-788-0139 theberge.timothy@dol.gov @timtheberge (Twitter) www.slideshare.net/ttheberge John Murphy TRA Coordinator 617-788-0392 murphy.john@dol.gov Kate McLaughlin Trade Coordinator (Backup) 617-788-0126 mclaughlin.kathleen@dol.gov 70

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