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Cryptocurrency Assets: Overview of Current and Prospective ETP Listings, Listing Requirements & End-to-End Processes

1. Introduction

Cryptocurrency ETPs (Exchange Traded Products) are becoming increasingly popular with the growing use of blockchain technology and growing interest in exposure to cryptocurrency as a financial asset.

Listing these ETPs on formal exchanges is challenging across all jurisdictions due to the substantial infrastructure required and the strict regulations which need to be met by the Issuer as set by the relevant Securities Regulator, even in the most crypto-friendly jurisdiction.

There is a distinct lack of regulation of cryptocurrency assets worldwide, which poses challenges as crypto-based products often have difficulty listing on formal exchanges where they cannot be classified as a financial product. Regulators raise concerns over the lack of oversight over cryptocurrencies, lack of consumer understanding of the related risks and the potential for market manipulation. Overwhelmingly, it appears that many more conservative regulators simply do not trust new technology and wish to observe its behavior for longer, seeing how it performs before taking a risk and approving any products linked to cryptocurrency to be formally listed. Regulators have a duty to protect the public and it is understandable that many are cautious when it comes to cryptocurrency, given that 1) they do not understand the products, 2) that the market is inherently volatile and 3) that there have been many instances globally of members of the public losing substantial funds (even life savings) by investing in crypto-products.

Regulation of crypto-products is near in many jurisdictions as regulators cannot ignore the appetite for crypto-products and cryptocurrencies, and they also have a duty to mitigate risks associated with free-trading of these products.

The below is a summary of research on various crypto-currency based ETPs globally to provide some insight into their structure and the regulatory framework in which they operate.

2. Summary

The most attractive jurisdictions for listing an ETF currently appear to be a mixture of Canada, Switzerland, Ireland and Australia. The aforementioned jurisdictions have actively trading crypto-based ETPs and ETFs — more specifically, even permitting spot-based crypto ETFs.

Some of the crypto-ETFs identified across the above jurisdictions are Purpose Investments’ Purpose Bitcoin ETF (BTCC) (Canada), 21Shares Bitcoin ETF (EBTC) (Australia)12, 21Shares Crypto Basket Index ETP (HODL) (Switzerland), the ETC Group’s Digital Assets & Blockchain Equity UCITS ETF (KOIN) (although note this is also a blockchain ETF) (UK), and hanETF ETF products (there are many under this umbrella fund which is noted for interest in the corporate structure and access to the European market).

Based on global reactions, a spot-based ETF is generally the more difficult product to list. On assessment of the ETFs to be discussed below, the following are factors which regulators look for in accepting an application to list:

a. A reputable custodian: some jurisdictions prefer banks to offer this service (where possible) as banks have a track record and are already regulated in some manner. Otherwise, preferred custodians tend to have a strong track record and an established reputation.

b. Cold-storage solutions: regulators understand that cold-storage is highly secure and seem to look on this favorably.

c. Holding the underlying asset in a 1:1 ratio to the issued shares in the ETF: this seems to be preferred as it provides security to investors.

d. Redemption: some crypto-ETFs only accept investments in-kind, in cryptocurrency. They also only (except in rare circumstances) allow redemptions in-kind. This might be favorable to regulators in that investors and funds will always be dealing in cryptocurrency, rather than fiat which is subject to additional regulation.

e. Partnerships: Funds partnering with established institutions appear to have success in listing, either by piggy-backing off of those institution’s licenses (if a license is necessary to trade) or by benefitting from those institutions’ established track record.

The above factors all form part of an ETP’s end-to-end process and the movement of funds within the product. Each jurisdiction has a different set of requirements for listing an ETF, the above is illustrative only of some insights collected through perusal of various prospectuses and regulator’s notices in connection with successful listings.

3. Definitions of ETPs, ETFs, ETCs & ETNs

The below definitions may vary between jurisdictions and are not unilaterally applied. Some jurisdictions regard ETPs (for example) as a standalone product while others may regard it as an umbrella term for the other three products: ETFs, ETCs and ETNs.

3.1 Exchange Traded Product (ETP)

Exchange Traded Product: a type of security that tracks underlying securities, an index, or other financial instruments.

3.2 Exchange Traded Fund (ETF)

Exchange Traded Fund: an investment which comprises a basket of different securities.

3.3 Exchange Traded Commodity (ETC)

Exchange Traded Commodities: investment vehicles (asset backed bonds) that track the performance of an underlying commodity index including total return indices based on a single commodity.

(Not to be confused with Exchange Traded Cryptocurrencies — as described on the German Stock Exchange XETRA).

3.4 Exchange Traded Note (ETN)

Exchange Traded Note: an unsecured debt note issued by an institution (typically a bank). Similarly to a bond, an ETN can be held to maturity or bought or sold at will, and if the underwriter (usually a bank) were to go bankrupt, the investor would risk a total default.

4. Synthetic vs Physical ETFs

All ETFs explored appear to value their underlying assets by use of an index. They “track” index prices. They may either hold the underlying assets directly (Physical ETFs) or they may be based on derivatives (Synthetic ETFs).

4.1 Physical ETFs

4.1.1 Holding

These are ETFs which actually hold the assets which form part of their “baskets”. E.g 21Shares’ Australian Bitcoin ETF.

4.1.2 Spot

This is a term commonly used for ETFs whose value is based on the real-time price of the underlying assets, rather than the synthetic futures market where prices are based on speculation and supply/demand for futures contracts.

4.2 Synthetic ETFs

With a physical ETF, the ETF provider attempts to track an index by buying the underlying assets of the index with the same weight as in the index, in order to mirror its rise and fall (full replication). If the ETF provider only invests in a selection of the assets, this is called sampling. An example of a Synthetic ETF is a futures ETF, where the ETF deals in futures contracts rather than the spot price of the asset it actually holds.

4.2.1 Futures

Derivative instrument based in futures contracts, speculating on the future price of an asset.

5. United States

5.1 SEC’s attitude to Crypto Products

The United States are considered by many as backward in their slow regulation of crypto products — for a developed, Western nation.

The Securities & Exchange Commission (SEC) is slow to approve crypto-products which are open to the public — those which are not closed, private funds. They have (recently) allowed ProShares to list a futures cryptocurrency-based ETF — ProShares Bitcoin Trading Strategy (BITO). 21Shares however, failed in its application to list a spot-based crypto-ETF, despite listing similar products in Australia and Europe.

Overwhelmingly, the current attitude by the SEC is that spot-based crypto-products cannot be approved because the underlying market is open to manipulation. The futures market is, by contrast, a regulated one, with many futures products trading on the Chicago Mercantile Exchange (CME). It is for this reason that the SEC has approved futures crypto ETFs — even if the underlying market is still, at the heart of it, unregulated.

5.2 Failed Crypto ETF listings: 21Shares & Wise Origin

21Shares recently failed in listing a spot crypto-ETF on the Cboe BZX Exchange. The SEC said in its rejection notice that the fund failed to either show that there was a surveillance sharing agreement in place or show that the underlying market is inherently resistant to manipulation. A surveillance sharing agreement is an agreement between an exchange and a regulated market of significant size aimed to provide for the parties to share in information which would allow them to identify and prevent market manipulation. Both 21Shares and Wise Origin attempted to show that the underlying market is inherently resistant to fraud. Neither Issuers were successful in this regard as it is a high burden to satisfy and the SEC could not be convinced that the cryptocurrency markets could be sufficiently protected from manipulation merely because of their nature as decentralized.

The hallmarks of a surveillance-sharing agreement are that the agreement provides for the sharing of information about market trading activity, clearing activity, and customer identity; that the parties to the agreement have reasonable ability to obtain access to and produce requested information; and that no existing rules, laws, or practices would impede one party to the agreement from obtaining this information from, or producing it to, the other party.

The SEC’s standard requires such surveillance-sharing agreements since they “provide a necessary deterrent to manipulation because they facilitate the availability of information needed to fully investigate a manipulation if it were to occur.” The SEC has emphasized that it is essential for an exchange to enter into a surveillance-sharing agreement with markets trading the underlying assets for the listing exchange to have the ability to obtain information necessary to detect, investigate, and deter fraud and market manipulation, as well as violations of exchange rules and applicable federal securities laws and rules.

In the context of this standard, the terms “significant market” and “market of significant size” include a market (or group of markets) as to which (a) there is a reasonable likelihood that a person attempting to manipulate the ETP would also have to trade on that market to successfully manipulate the ETP, so that a surveillance-sharing agreement would assist in detecting and deterring misconduct, and (b) it is unlikely that trading in the ETP would be the predominant influence on prices in that market. A surveillance-sharing agreement must be entered into with a “significant market” to assist in detecting and deterring manipulation of the ETP, because a person attempting to manipulate the ETP is reasonably likely to also engage in trading activity on that “significant market.”

Consistent with this standard, for the commodity-trust ETPs approved to date for listing and trading, there has been in every case at least one significant, regulated market for trading futures on the underlying commodity — whether gold, silver, platinum, palladium, or copper — and the ETP listing exchange has entered into surveillance-sharing agreements with, or held Intermarket Surveillance Group (“ISG”) membership in common with, that market.

Listing exchanges (Cboe BZX Exchange in 21Shares’ case) have also attempted to demonstrate that other means besides surveillance-sharing agreements will be sufficient to prevent fraudulent and manipulative acts and practices, including that the bitcoin market as a whole or the relevant underlying bitcoin market is “uniquely” and “inherently” resistant to fraud and manipulation. In response, the SEC has agreed that, if a listing exchange could establish that the underlying market inherently possesses a unique resistance to manipulation beyond the protections that are utilized by traditional commodity or securities markets, it would not necessarily need to enter into a surveillance-sharing agreement with a regulated significant market. Such resistance to fraud and manipulation, however, must be novel and beyond those protections that exist in traditional commodity markets or equity markets for which the Commission has long required surveillance-sharing agreements in the context of listing derivative securities products. No listing exchange has satisfied its burden to make such demonstration.

Wise Origin Bitcoin Trust also failed in its listing application on the basis that the exchange could not show that the market was inherently resistant to fraud or that a surveillance sharing agreement was in place. There were some additional factors cited by the SEC in its rejection relating to the valuation of the underlying products and in the influence of other markets on the market in question, but market manipulation was the SEC’s primary concern.

5.3 Looking Forward

The SEC’s current attitude is not shared by the organization as a whole, with some individuals within the SEC disagreeing with Chairperson Gary Gensler’s take on crypto to date, and the US Government has an interest in fast-tracking approval of crypto-products, to discourage the outflow of investors to more friendly jurisdictions. This indicates that the SEC is under pressure to develop regulations for crypto-products and to do so quickly.

Grayscale has a pending application with the SEC for a spot crypto-ETF, due 6 July, and it will be interesting to see the outcome and any difference between the SEC’s treatment of this product and the previous failed products.

6. Canada

6.1 Purpose Investments

Purpose Investments listed a spot Bitcoin ETF in 2021, the Purpose Bitcoin ETF (BTCC) claiming to be the “first Bitcoin ETF”. 8 Purpose Investments’ filing process with the Toronto Stock Exchange was confidential. The notable features of this fund are similar to other approved ETFs — secure cold storage, a fund backed by actual Bitcoin.

The Purpose Bitcoin ETF is considered an “alternative mutual fund” under National Instrument 81–102, which means it is permitted to invest in asset classes or use investment strategies that are not permitted for traditional mutual funds. It is established as a trust and administered pursuant to a Declaration of Trust, which is the primary governing document for such investment funds. Purpose Investments Inc. serves as the trustee, manager and portfolio manager.

Alternative mutual funds (also “alternative investment funds” (AIFs)) are authorized to invest in non-traditional assets where a conventional mutual fund is not.

Canadian securities laws regulate AIFs by province, but with “passportablility” of registration between provinces so that a fund registered in one province is also registered in another.

The general regulations applying to AIFs state that:

(a) those who act as an investment fund manager of an AIF to become registered as such with the relevant Securities Regulator (the “Investment Fund Manager Registration Requirement”);

(b) those who engage in, or hold themselves out as being engaged in, the business of trading in securities of the AIF to prospective investors to become registered or licensed as a dealer (the “Dealer Registration Requirement”);

(c) those who engage in, or hold themselves out as being engaged in, the business of managing the investment portfolio of the AIF to become registered or licensed as an adviser (the “Adviser Registration Requirement”); and

(d) the AIF that distributes securities to investors to file a prospectus with, and obtain a receipt therefor from, the applicable Securities Regulator(s) (the “Prospectus Requirement”),

unless the securities legislation provides for an express statutory exemption from the relevant requirement; or an order or ruling can be obtained from the applicable

Securities Regulator which exempts a trade, a security or a person or company from the relevant requirement.10

The Canadian regulatory environment thus seems well suited to accepting crypto listing applications as it has a structure set up to allow non-traditional investment vehicles.

6.2 Evolve

Evolve launched its Evolve Cryptocurrencies ETF (ETC) in September 2021. The Fund is also an AIF like the Purpose ETF but this Fund offers exposure to multiple cryptocurrencies.11 The Fund currently has $24.182 M assets under management (AUM) .This Fund permits investors to invest in cash and to redeem in cash. This ETF is (like Purpose) backed by the underlying asset and uses a custodian (CIBC Mellon Trust Company) providing cold-storage solutions.

As with most listed spot crypto-ETFs, Evolve’s prospectus makes substantial risk disclosures which are likely in compliance with listing requirements for this type of alternative investment fund.

6.3 Looking forward

Commentators have suggested that the Canadian regulators’ approach is to allow investors to decide on the merits of cryptocurrency, but intend to use regulatory mechanisms to provide investors with adequate disclosures to inform their decisions.

In 2020 the CSA indicated that crypto exchanges are subject to securities regulations and have taken steps towards regulating these exchanges.

7. Australia

7.1 21Shares ETFs: Notable features

21Shares Australia listed a Bitcoin ETF (EBTC) on the Chicago Board Options Exchange (an official exchange with Australian presence). This ETF is domiciled in Australia and tracks the spot price of Bitcoin, which the Fund also holds. The Fund’s listing application is not publicly available, although its prospectus provides insights into the Fund’s mechanisms. 21Shares also has a similar Ethereum Fund listed and trading in Australia (ticker: EETH)

The end-to-end process is described in the below graph provided in EBTC’s prospectus.

Some notable features of this end-to-end chain are that the Custodian (HSBC) is a regulated financial institution. The Custodian holds the underlying Bitcoin in cold storage on the Fund’s behalf.

The Fund’s prospectus describes its method of holding Bitcoin in the following terms:

‘The Bitcoins that back the Coin Interests are held in Secured Accounts at the Custodian. Bitcoins attributable to the Coin Interests are held in “Cold Storage” accounts. The accounts at the Custodian are separate segregated accounts maintained by the Custodian in the name of the Responsible Entity as trustee of the Sub-Fund which evidence and record the Bitcoins held by the Custodian as well as the withdrawals from and the deposits to each account.’

The issuer in this structure is ETFS 21 Shares Bitcoin ETF and is a registered entity, complying with CBOE requirements. ETFS 21 Shares Wholesale Bitcoin Trust is not a registered entity. The investor has a direct claim to underlying Bitcoin by virtue of the ETF’s Trusteeship of the Trust, which holds interests in the Bitcoin on behalf of the investor.

The Fund’s prospectus also makes substantial risk disclosures, as do most crypto-based funds across the board.

This Fund accepts investments and issues redemptions “in-kind” — in Bitcoin. Under rare circumstances payments may be made in cash.

The Fund values its underlying Bitcoin through tracking an Index. The relevant extract from the Fund’s prospectus states:

“The Fund aims to track CryptoCompare’s Crypto Coin Comparison Aggregated Index (“CCCAGG”) (before fees and costs). CCCAGG represents a real-time, USD equivalent spot rate for Bitcoin. The index value is algorithmically calculated in real time based on observed trading activity on over 70 Bitcoin exchanges. The index has been in operation since April 2014 and was launched publicly on November 3, 2014.”

It is notable that this index is as old as 2014 and is publicly available, the relevant listing requirements likely favor this.

There are restrictions on this Fund’s redemption requests — presumably designed to keep the Fund liquid. For example -

“Where the total Redemption Requests for the Fund represents 10% or more of the Net Asset Value of the Fund, the Responsible Entity may delay each Redemption Request rateably so that the total number of Coin Interests of the Fund for redemption on that Cboe Business Day shall not exceed 10% of the Net Asset Value of the Fund.”

Regulators are likely to have favorably reacted to the above restrictions on redemption requests, to the transparency in valuing NAV and underlying assets, to the highly secure storage solutions and to the in-kind redemption procedure.

8. Switzerland

8.1 21Shares Crypto Basket Index ETP (HODL) is another 21Shares crypto-based product trading, this time in Switzerland.

It is worthwhile to note that 21Shares has a variety of Exchange Traded Products (described as such) listed on the Swiss Stock Exchange SIX. These are described broadly as ETPs but resemble ETFs on perusal of their prospectuses.

This Fund invested in the top 5 cryptocurrencies. The Custodians are listed as The Kingdom Trust Company, Coinbase Custody Trust Company, LLC, Copper Technologies (UK) Limited, Bitcoin Suisse AG. All the aforementioned appear to have a strong track record of Custodianship (which was likely favorable to the Regulator in approving the ETP).

This Fund is generally settled in cash. Authorized Participants may, under certain conditions, settle in-kind.

Note that this Fund engages in staking — stating: “Any staking rewards paid out as a result of the use of the collateral pool for staking will be added to the total value of the collateral pool less any applicable fees and commissions”

In Switzerland, there are published guidelines on crypto-assets. They are not exhaustive but the jurisdiction has proven more friendly and open than its US counterpart to listing crypto-assets. AML laws apply to cryptocurrency.

9. Ireland

9.1 Notable fund structures: Grayscale Future of Finance (GFOF)

The Grayscale Future of Finance ETF (GFOF) is listed on the London Stock Exchange through its partnership with hanETF and the ETC Group.

The exact structure of this arrangement is still being investigated but it appears that Grayscale has partnered with hanETF as a sub-Fund to its already-registered Irish Collective Asset Management Vehicle (ICAV).

ICAVs are juristic entities in Ireland that appear to operate much like a holding company would in South Africa — holding various other limited-liability companies within its structure. However, these ICAVs are specifically designed for collective investment schemes and each sub-fund (with a different offering in potentially differing jurisdictions) has its own separate legal personality. 14 ICAVs allows Fund managers access to the EU-wide marketing passport for Undertakings for the Collective Investment in Transferable Securities (UCITS) and alternative investment funds (AIFs). 15

This is notable because hanETF, largely in partnership with the ETC Group, has listed many crypro-based ETFs/ETPs this way. The Issuers in question are taking advantage of hanETF’s license(s) and listing their products under its umbrella.

The above diagram illustrates how ICAV fund structures operate.

Another fund under the hanETF structure is The ETC Group Digital Assets and Blockchain Equity UCITS ETF (ticker: KOIN), this is not a crypto-ETF but a blockchain ETF.

There are numerous crypto-funds in the hanETF/ETC Group called “ETCs”- Exchange Traded Cryptocurrencies. Examples include MATICetc — ETC Group Physical Polygon, ATOMetc — ETC Group Physical Cosmos, AVAXetc — ETC Group Physical Avalanche.

All these examples are physically backed but they are structed as debt securities, not equity. This resembles more an ETN than an ETF. It is likely that relevant regulatory bodies in Europe prefer this debt structure to equity in relation to crypto-products. This appears to hold true for many ETPs listed in Luxembourg, which also include the above ETC Group offerings.

10. Germany

German regulators are indicating a growing acceptance of crypto-products listing on the Deutsche Börse Xetra (German Exchange). Crypto debt instruments, as in Switzerland and Luxembourg, seem more prevalent in Germany.

These instruments include the ETC Group’s Zeth product and Fidelity’s Physical Bitcoin ETP (Primary Ticker FBTC). FBTC tracks the spot price of bitcoin but is structured as an ETN, not an ETF. Otherwise, this product displays many similar characteristics to spot ETFs listed in Canada and Australia. It is 100% physically backed, its prospectus describes relevant risks at length, and it uses secure cold-storage solutions through its custodian.

11. South Africa

South Africa is unknown territory as no cryptocurrency-based ETFs have been successfully listed. The JSE has indicated that it does not accept applications for listing spot crypto-ETFs. The CTSE has indicated a more flexible attitude to crypto-products, although the territory is new and applications have not yet formally made their way through the listing process. The CTSE has recently indicated a preference for spot-based ETFs, in contravention with the global norm which seems to be that derivatives products are regarded as safer and are preferred. This may be because in other jurisdictions futures markets are more developed, where the CTSE is a new organization and does not list futures products or have a track record in doing so.

11.1 Financial Sector Conduct Authority’s (FSCA) attitude to Crypto Products

Crypto-products are currently unregulated in South Africa as they are not defined as financial products. They are considered a type of asset rather than a currency.

The FSCA has acknowledged crypto assets as a new financial innovation and agree on accommodating it within the regulatory framework, where appropriate and where sufficient regulatory safeguards can be implemented. The FSCA is considering various policy recommendations for bringing crypto-assets within the regulatory framework but has reserved its rights to change its position should crypto-products pose a material risk to its regulatory mandate in the future.

The South African policy position on crypto assets is neither explicitly ‘hostile’ nor explicitly ‘friendly’: through the IFWG CAR WG position paper, the South African financial sector regulators aim to remain neutral with the objective of enabling responsible innovation in the crypto asset ecosystem, while ensuring a level playing field between both incumbent and new role players. In addition, in line with the revised standards of the Financial Action Task Force (FATF) issued in October 2019, all jurisdictions are required to regulate crypto assets and crypto asset service providers (referred to as ‘virtual assets’ and ‘virtual asset service providers’ by the FATF) for anti-money laundering and combating the financing of terrorism

The FSCA has yet to indicate approval for any crypto-ETF for listing, although it has not expressed much of an opinion on the subject since few applications have been made to the JSE and CTSE.

The FSCA is not favorable to crypto-based derivative products, this would indicate that spot ETFs may have more success in SA compared to the reverse which is true overseas.

11.2 Johannesburg Stock Exchange (JSE)

The JSE has previously rejected a spot-based crypto-ETF’s application for listing. There may be scope for a futures-product but no successful applications have yet been made.

11.3 Cape Town Stock Exchange (CTSE)

The CTSE has indicated a more flexible attitude to crypto-products, although the territory is new and applications have not yet formally made their way through the listing process.

They have indicated they are cooperative in participating in the listing process for a product so new as a crypto-ETF. On face-value it seems the more promising exchange to apply to list a spot ETF on.

11.4 Looking Forward

Regulations are expected to be published by the end of 2022. We will have a better indication of where South Africa is going when we know which jurisdictions it is looking to for guidance.

12. OTC Exchanges

Over-the-counter (OTC) exchanges are not as exciting to list on compared to formal exchanges, but they do offer an opportunity to build a track record and gain market confidence. These are factors which might rank positively with regulators when it comes to formally listing a product.

EasyEquities in South Africa, for example, lists a product called EC10 by a subsidiary (or related) company EasyCrypto. EC10 is described as follows:

“The EC10 bundle employs a passive investment strategy that seeks to track the top 10 largest cryptocurrencies by market capitalization as a single financial product. The fund’s assets are held in 100% cold storage with a regulated, insured custodian, and are audited annually. The underlying index — the EC10 Top 10 Crypto Index — has a public, formal methodology that includes eligibility rules meant to embrace best investment practices, and screen critical risks regarding custody, liquidity, regulatory hurdles, and other concerns. Rebalancing and reconstitution of the EC10 is implemented on a weekly basis. The EC10 harnesses a passive market cap-weighted approach to index rebalancing, in consonance with the methodology of the eligibility requirements.”

This sounds quite similar to many overseas crypto ETFs/ETPs, although EasyEquities itself does not call this bundle an ETF.

EasyEquities has over one million accounts trading on its platform. The company makes it clear that, when investing in crypto offered by EasyCrypto, you are not investing through a registered Financial Service Provider (FSP) . EasyEquities, by contrast, is a registered FSP. When buying non-crypto products you are investing through an FSP.

The Easy group of companies is owned by the Purple Group in South Africa and is looking to expand into a variety of financial services and products.20

13. Conclusion

This research in ongoing and this is a fast-moving industry. Depending on the product in question and the desired jurisdiction and market exposure, advice on the appropriate product “packaging” may differ. Regardless of the exact type of crypto-product developed (whether an ETN or ETF), it will be important to assess the relevant regulator’s preferences when it comes to fulfilling listing requirements and packaging the application to best fulfil those requirements. Custody, security, managing redemption requests, and the manner of holding the underlying assets seem to be factors which regulators closely look to in assessing applications. If possible, partnering with institutions with a track record in providing these products (whether custody providers, payment agents, market makers, etc) will assist in listing a new product and lend confidence to regulators in making their decision.

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