Benelux forum 2014 - Regulation update

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Presentation from the SWIFT Benelux Forum held in La Hulpe on 19/20 March 2014

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Benelux forum 2014 - Regulation update

  1. 1. Benelux Forum – March 2014 Richard Young Regulatory Affairs - SWIFT richard.young@swift.com Regulation Update
  2. 2. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  3. 3. G20 Commitments & EU Single Market – Driving Regulatory Change G20 Commitments • Capital Requirements/Capital Buffers • Liquidity Monitoring • Shadow Banking Industry regulation • Greater Market Transparency • Safer OTC Derivatives • Robust Market Infrastructure EU • Progress the Single Market in Financial Services by continuing deployment of measures to remove barriers to cross border transactions. + • EU Interpretation of G20 Commitments 3
  4. 4. Rule-Making Process Legislative Process G20 Policymaking Process Political Commitment G20 Commitments & Regulatory Development ESRB European Systemic Risk Board ESCB European System of Central Banks CGFS Committee on the Global Financial System IASB International Accounting Standards Board IOSCO International Organisation of Securities Commissioners BIS Bank for International Settlements BCBS Basel Committee on Banking Supervision CPSS Committee on Payment and Settlement Systems FSB Financial Stability Board ODRF OTC Derivatives Regulators Forum IMF International Monetary Fund ODSG OTC Derivatives Supervisors Group US Senate US House of Representatives European Council European Parliament CRD IV Dodd Frank Act MIFID/R EMIR CSDR Congressional Oversight EC Endorsement & EP/Council non-objection US Administration CFTC SEC European Commission ESMA EBA EIOPA 4 Adherence / Compliance 2009 2013+
  5. 5. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  6. 6. Changing EU Regulatory Structure – Single Supervisory Mechanism • September 2012 - EU propose Single Supervisory Mechanism (SSM) for euro area. – A regulation conferring strong powers on the ECB for the supervision of all banks in the euro area, with a mechanism for non-euro countries to join on a voluntary basis. – Focus on decision making in the EBA to ensure balance and integrity of the single market. – First step to Banking Union • March 2013 Deal reached with EU Parliament on the SSM - banks with assets of €30 billion, or larger than one-fifth of their country's economic output, are supervised by the ECB rather than national supervisors. • The next pillar of Banking Union is the SRM (Single Resolution Mechanism). Ongoing discussions between EU Parliament and Council: member states decision making powers over bank resolution, which institution would ultimately be responsible for resolution and the borrowing capacity of the Single Resolution Fund. ECB Preparing to take up SSM role from November 2014
  7. 7. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  8. 8. SEPA and Payment Services Directive • SEPA • Early 2012 agreement reached between EU Parliament, Commission and Council on SEPA end date. Resulting timings: − A common and single end date of end January 2014 for the migration of euro retail credit transfers and euro direct debits to SEPA instruments. Deadline recently extended to August 2014 − An exclusion of the High Value Payment Systems from its scope. − Mandatory use of ISO 20022 XML as the standard for euro retail CT and DD messages for the interbank space AND for customers sending or receiving bulk files. − A ban on per transaction Multilateral Interchange Fees (MIFs) for DDs as from 1 November 2012 for cross-border and 1 November 2017 for domestic direct debits − Industry Challenges: − Corporate Segment Take Up − Differing Time lines per Geographic Area and Instrument Types – complexity of Implementation 8 No further deadline extensions beyond August 2014
  9. 9. SEPA and Payment Services Directive Contd. • Payment Services Directive (PSD II) Review • In July 2013 the EU Commission published legislative proposals to update the existing Payments Services Directive. • The new measures consist of a revised PSD Directive, together with a new Regulation on Multilateral Interchange Fees • PSD II facilitates and renders more secure the use of low cost internet payment services by including within its scope new so-called payment initiation services (PIS). • Banks, PIS and all other PSPs will need to improve online transaction security by including strong customer authentication for payments. • Payment Systems will be required to open up and allow access to ALL PSPs, subject to appropriate risk assessments including; such areas as governance and business continuity arrangements, all of which will be overseen by local regulators. • The PSD II Regulation on interchange fees imposes a cap on the interchange fees PSPs can charge for consumer debit and credit card transactions, which take place within the EU. It will also ban surcharges on such cards imposed 9 When: Agreement unlikely before EU Parliament elections, earliest implementation 2016?
  10. 10. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  11. 11. Basel III and CRD IV • Capital and Liquidity standards – Implementing Basel III in the EU. • Changes to the Capital Requirements Directive (CRD) – new Regulation and updated Directive: • Directive covers access to deposit taking facilities, regulation covers prudential requirements including: • capital: Increasing the amount of own funds banks need to hold as well as the quality of those funds.. • liquidity: Improving short-term resilience of the liquidity risk profile of financial institutions with introduction of a Liquidity Coverage Ratio (LCR) - the exact composition and calibration of which will be determined after an observation and review period in 2015. • leverage ratio: In order to limit an excessive build-up of leverage on credit institutions' and investment firms' balance sheets, a leverage ratio be subject to supervisory review is proposed. Implications of a leverage ratio will be closely monitored prior to its possible move to a binding requirement on 1 January 2018. • counter party credit risk: measures are introduced which are consistent with the regulatory policy for OTC (over the counter) derivatives, i.e. to encourage central clearing When: Agreement reached Feb 2013, entry into force expected from Jan 2014 – implementation phased in to 2019 11
  12. 12. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  13. 13. Foreign Account Tax Compliance Act (FATCA) • US tax authorities are concerned that US persons escape their US tax obligations by holding assets through offshore accounts; • Non – US Financial Institutions designated as Foreign Financial Institutions (FFIs); • FFIs suffer 30% withholding unless they enter into IRS agreement; • Participating FFIs must identify US account holders and may withhold payments to non-participating FFIs or recalcitrant accounts. • IGAs increasingly common = reporting to local tax authority GIIN – Global Intermediary Identification Numbers to be added to SWIFTRef 13 When: 25 April 2014 for the initial FFI list, ready for withholding to start from 1st July 2014. Participating FFIs will be expected to begin FATCA tax client reporting in respect of 2014 information by March 31, 2015. US Person Bank Account Platform Insurance Product Fund Custodian Trust Broker IFA/ Wealth Manager Foreign Financial Institutions Proceeds from Income & Sales US Assets
  14. 14. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  15. 15. AML Review (4th AML Directive – AMLD) The proposals provide for a more risk-based approach based on an understanding of the AML and Counter Terrorist Financing risks which impact individual countries. The new Directive: • Clarifies and reinforces the rules on customer due diligence and introduces new provisions to deal with politically exposed persons (i.e. people who may represent a higher risk of corruption by virtue of the positions they hold). • Goes beyond the FATF requirements by bringing within its scope all persons dealing in goods for cash payment of €7,500 or more. • Ensures a more comprehensive coverage of the gambling sector (in the light of concerns that the sector is vulnerable to money laundering) and includes an explicit reference to tax crimes (tax evasion) • Includes a reinforcement of the sanctioning powers of the regulators by introducing a set of minimum principle-based rules to strengthen administrative sanctions and a requirement for them to coordinate actions when dealing with cross-border cases. 15 • This review is to the existing 3rd Anti Money Laundering Directive which was adopted in 2005 and transposed into EU Member States' legislation in 2007. • AMLD implements international standards set by the Financial Action Task Force (FATF) on anti-money laundering and terrorist financing. The 4th AMLD will include standards updates made by the FATF in 2012.
  16. 16. • Example; payment service providers must ensure the transfer of funds is accompanied by information such as: – the name of the payer; – the payer's account number, or a unique transaction identifier – the payer’s address, or national identity number, or customer identification number, or date and place of birth. – the name of the payee; and – the payee's account number or a unique transaction identifier • The new Recommendations also have strengthened transparency requirements for reliable information to be available about the ownership and control of companies, trusts, and other legal persons or legal arrangements. AML Review (4th AML Directive – AMLD) – Contd. Improving Transparency 16 When – Legislation Feb 2013, Council and Parliament discussions during 2014. Implementation 2015? • Along with the general review of the AMLD there is a also a Regulation on the information accompanying the transfer of funds.
  17. 17. Financial Sanctions • Sanctions lists are increasingly imposed by national governments and bodies such as the EEAS and the UN in pursuit of foreign policy objectives and to fight crime and terrorism. • Compliance with Sanctions regimes is a challenge for the financial industry (and for SWIFT).
  18. 18. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  19. 19. EMIR – European Market Infrastructure Regulation • Moving OTC Derivatives as far as possible to centralised clearing through one or more CCPs - G20 Commitments – ESMA will decide the derivatives contracts across asset class included in mandatory central clearing; – All EU counterparties must comply – although exemptions for non-financial counterparties below ‘clearing threshold’, intra-group transactions and pension schemes. • Standardisation of OTC Derivatives contracts permitting exchange trading and clearing; • Non-cleared derivatives subject to bilateral risk mitigation; G20 Commitments • Increased market transparency via reporting to Trade Data Repositories (at least one per asset class). G20 Commitments When – Entry into force August 2012; Reporting Feb 2014, Clearing obligations – Q4 2014? 19
  20. 20. EMIR – Contd. - Focus on CCPs • EMIR includes rules for the operation of CCPs including: – Client asset segregation; CCPs must offer an account structure so that Clearing member assets can be distinguished from the assets of the CCP and Clearing member client assets can be distinguished from the Clearing members assets (omnibus segregation). The CCP may also, at the request of a clearing member, set up individually segregated accounts in which the positions and assets of indirect clients of a client may be recorded, but there is no obligation to do so. – CCPs must collect margin limiting credit exposure from clearing members until the liquidation of the relevant positions. The margin must be sufficient to cover losses resulting from 99% of exposure movements over a time horizon. Margin calls will be collected on an intra-day basis. Margins collected must be adequate to cover the risk stemming from positions registered in each individual client segregated account. – Further measures to limit CCPs credit exposures are contained in the requirements for pre-funded default funds to cover losses not covered by margin requirements. 20
  21. 21. EMIR - Contd. - Focus on Non-Central Clearing • EMIR also covers non-centrally cleared OTC derivatives. Some technical standards are still under development, but will take their starting point from the BCBS-IOSCO work. • EMIR mandates risk mitigation for non-centrally cleared trades including: – Timely confirmation (phasing in, but for financial counterparties this will be required by T+1 from later in 2014), ideally by electronic means; – Portfolio reconciliation and dispute resolution; – Daily mark to market of outstanding contracts; – Risk-management procedures that require the timely, accurate and appropriately segregated exchange of collateral (note: it is expected that the EMIR rules in relation to the margining for non-centrally cleared derivatives will be largely based on the BCBS-IOSCO framework and will have a similar application timeline) – Capital hit to cover risk not protected by collateral exchange Reminder - Cleared or not-cleared - all transactions need to be reported – by both counterparties 21
  22. 22. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  23. 23. MiFID Review – Markets in Financial Instruments Directive • Originally implemented in November 2007 to promote greater competition in securities trading across the single market, review includes G20 commitments on Derivatives trading. • MiFID Review: Revised Directive and new Regulation (Mifid & Mifir) • The review includes: – increased transparency and oversight in respect of the trading of derivatives, including pushing OTC derivatives trading as far as possible onto regulated platforms – G20 Commitment; – a new type of regulated trading venue – Organized Trading Facilities (OTFs), OTFs will provide an additional channel for the trading of bonds, structured finance products, emissions allowances and derivatives; – increased transparency across asset class, with expanded pre and post trade and transaction reporting obligations for all types of traded securities; – new rules around high frequency trading and place restrictions on commodity derivatives; – a harmonised third country equivalence regime, including passporting; – removal of barriers for access to post-trade infrastructure. When: Political Agreement in Feb 2014, Level 2 Rule making 2014/15, Implementation 2H 2016? 23
  24. 24. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  25. 25. Central Securities Depository Regulation (CSD-R) • Regulation of CSDs and Harmonisation of EU Settlement cycle – Regulatory standards at the EU level for access to and operation of CSDs – CSD Governance and scope of services – Cross border issuance of Securities into CSDs (Giovannini Barrier 9) – Harmonisation of settlement cycles on T+2 (Giovannini Barrier 6) from 2015 plus procedures to address settlement fails – Full dematerialisation by 2025 – Account segregation – Trade date confirmation measures – Support by CSDs for open messaging and reference date standards When – Political Agreement Feb 2014, Entry Into Force Summer 2014 ESMA Level 2 Q4 2014/Q1 2015 Full Implementation 2015/16 25
  26. 26. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  27. 27. Shadow Banking – EU Communication Autumn 2013 • Measures to address Shadow Banking covered in recent EU Commission communication, included the following areas: – Increasing transparency, including use of LEI, collection and exchange of data between authorities and use of trade repositories, data collection on securities financing e.g. ECB proposal on repo central repository – Specific new legislative framework for money market funds; – Initiative on securities financing transactions - repo and securities lending. – Strengthened Prudential Banking arrangements; – Greater supervision of the shadow banking sector. 27
  28. 28. Shadow Banking Contd.– Securities Financing Transactions (SFT) – Reporting and Transparency • An EU framework under which financial and non-financial counterparties of an SFT will report transaction details to a Trade Repository (TR). The intention is to build upon the TR infrastructure which is already in place for the collection of trade reports relating to derivatives. • Measures to increase the transparency of the use of SFTs to investors. The aim here is to ensure that investors are aware of the risks associated with the use of SFTs. As such UCITS and AIFMs must inform their investors on the use they make of SFT’s, as well as of other financing structures. • Transparency on rehypothecation. Counterparties will retain the right to rehypothecate assets, but only if the providing counterparty has granted prior consent 28 When – Political Agreement during 2015, Entry Into Force 2016?
  29. 29. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  30. 30. CPSS-IOSCO Principles for Financial Market Infrastructures (PFMI) 30 Foster financial stability Limit systemic risk Increase safety Support greater efficiency • Published by CPSS-IOSCO • 24 principles • Issued for consultation in 2011 • Finalised in April 2012 • Applied by local supervisors from 2013 HVPS LVPS RPS SSS CCP CSD TR Critical Services Providers (annexe F) CPSS-IOSCO Consultation on the Assessment of CSPs – December 2013
  31. 31. CPSS-IOSCO Principles for Financial Market Infrastructures (PFMI) (contd.) – How SWIFT helps Compliance as a CSP 31 PFMI Annex F: Oversight expectations applicable to CSPs Description SWIFT 3402 and High Level Expectation Assurance report Risk Identification management Manage relevant operational and financial risks Information Security Efficient policies to secure confidentiality & integrity of information Reliability and resilience Be available, reliable and resilient, including continuity plan Technology planning Robust method to plan technology selection and use Communication with users Clear communication to understand risk management on critical services √ √ √ √ √ Today, SWIFT supports FMIs in their Compliance…
  32. 32. FMI Resolution • EU Commission expects to publish a legislative proposal for the resolution of non-bank financial institutions. This will include the resolution of Financial Market Infrastructures – particularly CCPs and CSDs. • EU Parliament has already published an own initiative report on a recovery and resolution framework for non-banks, which will be voted on later this year. This has protection of client assets at its core. This report, along with the FSB consultation is likely to inform the content of the Commission legislative proposal. Diagram below, taken from the report, illustrates the default waterfall for a CCP under EMIR 32
  33. 33. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  34. 34. Funds Regulation-UCITS Enhancement to the EU Directive 85/611/EEC from 1985 designed to allow Collective Investment Schemes to operate freely i.e. be sold ‘across border’ or ‘passported’ within the EU on the basis of authorisation from one member state. • UCITS V (the latest manifestation of the above) is designed to define the notion of safekeeping and to clarify custody duties. • It also proposed to harmonise depositary oversight duties between different legal structures, restrict delegation to safekeeping duties and ensure that risks are specified where sub-custodian networks are used. • It is proposed to clarify depositary liability by introducing a 'strict liability' standard obliging depositaries to return instruments lost in custody. • It is proposed to introduce consistent eligibility criteria for depositaries across the EU, which must be either credit institutions or investment firms subject to extensive conditions. When - UCITS V, dealing with depositary obligations (and remuneration questions) introduced Summer 2012, expected political agreement 1H 2014, Implementation 2015? 34
  35. 35. Alternative Investments Directive (AIFMD) • The Directive impacts all funds that are not harmonised under the UCITS Directive e.g. Hedge Funds, Private Equity and Real Estate investment funds • The Directive: – establishes a secure and harmonised EU framework for monitoring and supervising the risks that these funds pose to their investors, counterparties, other financial market participants and to financial stability; and – permits, subject to compliance with strict requirements, alternative investment managers to provide services and market their funds across the internal market of the EU. – Defines depositary responsibilities e.g. Depositaries must reconcile their records with prime brokers’ records and with third parties to whom custody functions are delegated. Where third parties are used it is still the responsibility of the main depositary to ensure the safety of the fund’s assets and to ensure that all obligations for accurate record keeping are discharged. When – Implemented July 2013 but with transition of 1 year for existing AIFs, transposition delayed in some states. Further implementation guidance awaited in others 35
  36. 36. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  37. 37. LEI Local Operating Unit (LOU) Local Operating Unit (LOU) Local Operating Unit (LOU) Central Operating Unit (COU) Board of Directors Regulatory Oversight Committee Governance Operations •Composed of international financial market regulators •Upholds governance principles and oversees that global LEI system functions for public interest •Made up of Plenary & Executive Committee • Oversees functioning of the COU, operational integrity and implementation, maintenance of standards specified by the ROC • Appointed & overseen by ROC, composed of stakeholders from financial & nonfinancial firms • COU ensures the application of uniform global operational standards and protocols to maintain uniqueness of LEI and high data quality • Manages federation through LOUs • Maintain a central logical database of identifiers and corresponding reference data • LOUs provide local provision of all LEI functions which the Regulatory Oversight Committee determines do not need to be centralized. • Service providers such as local registries and numbering agencies 37 Defined Infrastructure SWIFT/DTCC GMEI Utility – 125,000 + Pre-LEIs issued (57% of the total Pre-LEIs issued – 32% of which apply to the EU)
  38. 38. Agenda • Section 1 • Background to Regulatory Changes • The Changing EU Regulatory Structure • Section 2 • SEPA and Payment Services Directive • Basel III and CRD IV • FATCA • AML & Financial Sanctions • EMIR • MiFID Review • CSD Regulation • Shadow Banking • CPSS-IOSCO Principles for FMIs • Funds Regulation – UCITS, AIFMD • LEI • Section 3 • Timetables
  39. 39. Q2 ‘13 – CPSS_IOSCO Members begin assessments 39 2013 2014 Timeline Summary – Key Regulatory Initiatives Q1 ‘13 – 17 Phased Implementation FATCA 1 JULY ‘14 Withholding obligations introduced CPSS-IOSCO Principles for FMIs Adherence Basel III (CRD IV in EU) Adherence July 2013 Entry into Force of CRD IV in EU, Phased implementation in EU (CRD IV) and globally 2015 - 2019 2015 2016 February 12 – Reporting OTC/listed Derivatives Adherence European Market Infrastructure Regulation (EMIR) March – TS - Entry into Force Q4 2014 beginning of Clearing obligations March 2014 Final TextMIFID/MIFIR CSD-R Shadow Banking (Sec. Lending & Repo) UCITS V Dodd-Frank Feb 2014 Final Text Adherence Jan 14 EC legislative proposal Adherence Adherence Q1 2014 Political Agreement AdherenceExpected Rule Making Expected Rule Making Adherence Expected Rule Making Expected Rule Making Adherence Expected Legislative Timeline
  40. 40. Questions ? 40

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