Enhanced Communications Clarity – [FULL INTERVIEW]

Peter Wordsworth, from Consumer Duty Services, shares his insights on the evolving landscape of debt advice, the pivotal role of technology, and the impact of regulatory changes on the sector.

With an emphasis on the current economic pressures, he highlights the challenges and opportunities within debt advice, emphasizing innovation, the adoption of digital solutions, and the importance of data-driven decisions.

Peter sheds light on the shifts in consumer behavior and creditor expectations but also outlines the potential path forward for enhancing debt advice services and insolvency processes.

Find out more about Consumer Duty Services -> Here.

Key Points

  1. Increasing demand for debt advice amid economic pressures.
  2. Shift towards digital debt advice to meet consumer expectations.
  3. The need for a long-term solution to improve the delivery of debt advice.
  4. The impact of consumer duty regulations on the industry.
  5. The importance of evidence-based decision-making and data-driven approaches.
  6. The role of technology in addressing the supply-demand gap in debt advice.
  7. Innovations in the sector driving a more efficient delivery of services.
  8. The challenge of ensuring that consumers receive suitable and sustainable debt solutions.
  9. The necessity of collaboration between regulators, creditors, and service providers.
  10. The potential for statutory debt management plans as an addition to the existing solutions.
  11. The importance of clear communication and understanding in debt advice.
  12. The evolving landscape of insolvency processes and the need for a holistic approach.

Key Statistics

  • No specific statistics were mentioned directly in the transcript.

Key Takeaways

  • The demand for debt advice is rising, necessitating innovative delivery models.
  • Digital platforms are crucial in meeting the current demand for debt advice.
  • Consumer behavior is shifting towards digital interactions for debt solutions.
  • The implementation of consumer duty regulations is driving a more outcomes-focused approach.
  • Data-driven decision-making is becoming essential in the provision of debt advice.
  • Technological advancements are pivotal in bridging the supply-demand gap in debt advice.
  • Collaboration among stakeholders is key to enhancing debt solution frameworks.
  • There’s a recognized need for more sustainable and suitable debt advice solutions for consumers.
  • Transparency and understanding in the debt advice process can lead to better consumer outcomes.
  • The industry is moving towards a more holistic approach to address insolvency and debt advice issues.
  • The potential integration of statutory debt management plans could enhance the suite of debt solutions.
  • Continuous innovation and adaptation are necessary to address the evolving needs of consumers in financial distress.
Interview Transcript

Hi, everyone. I’m here with Peter Wordsworth today who’s the director of consumer duty services. Peter, thanks very much for joining

me. Thanks, Chris. Thanks for the invitation.

So I thought I wanted to talk given the fact that I know come some of your background we’ve worked together before in the past, particularly around the debt advice sector, I’ll just get a bit of your view around what’s happening in that sector, particularly with the economics or the economy and what’s going on in the economy. At the moment, I

think the problem we’re facing into, as far as that advice is concerned is the is the demand, the supply in terms of the financing, we’ve had, we’ve had the baps new approach to financing or funding the change of that changing of the guard there, we’ve had the historical sort of players losing their funding. So we’ve seen funding coming out of step change and a plan, and then having to move into a new model. And that has meant I think, is causing some stress in the market. And that they have changed, particularly has done a lot of sort of nominal negative accounts, advice and support for clients there. And it’s how you support that those solutions to those people, the negative, those negative budgets are really problem. I think at the moment, I think supply is always a problem. And no maps is Consulting at the moment about what it does going forward. I do think there’s got to be a longer term solution for how we get that that advice out there. I think we’re still finding our way I think they’ve shaken shaken things up a bit. And I think we need to just have a look at what the longer term solution is what struck

me when we when we we both heard Sheldon Mills talk. And it was just almost like the depth of the market. You mentioned the depth of the market there. And also we’re facing into this economic stress that’s going on in the country. But there’s only so much you can do from a telephony point of view. And he he almost pointed towards a digital get advice and a supply of debt advice. And the market just doesn’t match the demand for it, which just seemed like he was huge. Right? And and even he was talking about what are the other alternatives in places where we can have alternative solutions, trying to get the supply up? And those kind of things? Do you think that’s the kind of a direction because it feels like there’s quite a shortfall in terms of, at least why he was saying, Yeah, and

I think he’s right. And I think organisations are very much playing into that digital debt advice. space, I think there’s a lot of innovation in there. I think, actually, it’s a really exciting time in terms of there is a recognition that that we need technology to meet the demands, and to meet the expectations of customers, customers want to interact in a different way. Now they want to most of them want to be able to exercise on their mobile phones, not a lot of people have made me moving away from wanting to have a long conversation with people, ease of upload of documentation and things like that, over that mobile phones, and also a lot of work still to be done in terms of making that transition to digital, but also making it understandable. And now we’ve seen some of the excellent work in that area, with some of the some of the innovators in that space. So we’re looking at clarity of communication, because I think digital has a huge part to play. But it still feels like it’s got a long way to go before it can meet. And it can still it can really effectively substitute a lot of the traditional sort of device provision. So I do think it’s technology is beginning to play an increasingly important part in meeting the demand.

It’s interesting how it’s changing and changing very quickly. I think the I do think demand piece was interesting. And obviously this is on the back of consumer duty going in last year was obviously that you’re close to as well with your new role. What do you think the impact has been? I mean, when it came in, like July last year, are we done? Or is this more kind of to do? I know the answer that the way you are. But what do you think the impact has been? And what do you think the impact is going to be going forward?

It’s been a huge shift in the market, hasn’t it? In a very, I think it’s I thought it was innovative, brave. And I thought the move to an outcomes focused regulatory approach was really welcome. And rather than prescriptive, detailed sort of form ticking and everything else, I think it’s challenging for people because it’s a different way of approaching regulation. But I think it has, it has started, I think it’s it was Churchill who said, this isn’t the end, but it might be the end of the beginning. or beginning of the busy work. Yeah. Well, certainly we’re not there. Now. Yes, we should have had the first phase rolled out embedded the implementation plans should have been implemented. But we’re now moving to that next phase where we’re gonna get the first annual reports June this year. So the first reports will be due this year. We’re going to have those board reports as any reports do. We’ve got it. We’ve got the closed accounts being brought in July, that’s going to be huge, particularly the mortgage market where you have 1000s of closed products out there that are going to be brought in within scope. So I think that’s going to be The and we’re going to find other areas where they haven’t necessarily people haven’t necessarily been focused on the moment we’re talking a lot to the FCA about IPAs and the interaction between IPAs and consumer duty. So there’s no doubt in my mind that it’s really evolving. And it’s also evolving in terms when you speak to the FCA, they are still clearly thinking heavily about how they best roll this out other areas that where they need to, perhaps provide some clarification on will I suspect we’re going to see more deer IP letters out really hard for this year, giving further guidance and expectations. And we’ve just seen some more stuff coming out very, very recently about their expectations of what goes into the surfboard packs the annual annual reports on active duty. So it’s a start, it’s definitely started but we still got a long way to go yet those

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board reports in that was really heavily emphasised, I think the last session I attended. The other piece of sort of send chills down my slide is word evidencing right, and just trying to judge making sure you can actually evidence things and just the how ready we are to be able to do that how what was your kind of assessment in terms of readiness around KPIs and sort of date and being able to evidence you’re generating good

outcomes? Yeah, and I think that is the challenge. I think everybody’s got their heads round right? Consumer due to the need to focus on delivering good consumer outcomes. And it is held the evidencing that I think is one of the most challenging pieces, but also, the fact that it’s very clear that the FCA is going to be very data driven at the granular level of data they’re now expecting firms to be providing clearly indicates they want to be data driven, sort of organisation, they’ve been very open about that. So I think I think the challenge is to is you have people who may be acting very much with the right intentions, very much aiming to delivering good consumer outcomes, not in any way doubting their integrity or their intention. But they’re but they are going to have the ability to demonstrate objectively through data, how they are doing that, and how they are measuring that. And so evidencing sort of their decisions, and how they what they place that on what data they’ve done, because the FCA is not only looking to see that in place, they’re looking to see how you’re using that data to improve the outcomes moving forward. So we’re saying so you understand that now how we’re using your data to improve the outcomes for the next cohort?

How much of a changing culture do you think that is for firms, we tend to get quite focused on outcomes and getting our head around outcomes is relatively straightforward. I mean, it’s easier to say than to do but we’re focused on we’re quite practical as an industry, we’re quite practical around, like helping customers, those kind of things with any of that on the back on his head and saying, You’ve got to have data to be able to show that it can be a different way of thinking to in terms of process design, and how we think about how the data goes through those processes. How much of a cultural change, do you think we’ve got a leap? Do you have to do we have to make,

I think it’s a, it is a big cultural change. And but I think hopefully, people will be making starting to make that change over the last sort of six months or so because you’re absolutely right. For years, we have designed processes about getting customers from A to B. And now we have to get customers from A to B, but make sure that B is the destination that really is a good that B is a good outcome for them. And if we shouldn’t be taking them from A to C, then we should be able to identify that C is a better place for them. And I think that is a very different process of design, then the extra layer of design that we have to build into those processes and those client journeys to make sure the end point is the right end point for them. And that applies very much in depth advice as well, obviously,

just thinking about legacy processes. You mentioned a grandfather grandfather, the products which is coming in this year, but it’s almost legacy products and legacy systems don’t really help us with those kind of regards, because some of this stuff’s innate within the system design, isn’t it?

Yeah, it is. It is and and I think the only thing that gives me an I think that is a big problem. But I do think what’s really interesting is we are seeing some really good and innovative tech coming into this market. Now. I can’t remember a time when I’ve seen more tech more and more products coming to market more providers coming to their with their with ideas and different things. You think just about that sort of benefits income maximisation the ability for products out there for people to go in there and identify the benefits they might be able to or check they’re entitled to. I think there’s a lot of recognition that technology really has got a key part to play in this solution here. And there is a real change in step change in the speed of sort of innovation in this marketplace. And something I haven’t seen in the last 10 years or so certainly.

I couldn’t agree more on the last sort of five years, a lot of these interviews have been around just the speed of the speed of change is just terrific, isn’t it? A lot of it’s driven by the platforms that come through but amount of innovation that’s out there is just I just think it’s incredible. And new ideas coming all the time last year was another example of that. The one challenge I think that that I often hear though, is almost like how do you differentiate between buying something where someone’s clearly it’s their business and they’ve thought about it and they’ve gone through it? They put the investments and come up with these new innovations versus I don’t want to spend the money. And I just do it myself much. What do you think? Do you see that hesitation? And is it justified? Or do you think? Or how do you get rounded? We said,

I agree, I think there is a problem we face is there’s almost an embarrassment of riches or or choice here. Yeah, and every organisation has a finite budget and can only deal with not only, not only is it sort of the budget of the cost of implementing some of these solutions, the other is the resource to implement them. So you have to decide what your priorities are. What are you going to focus on? What are the key areas we need to address, which are the products that best address those, we see quite a lot of innovative partnerships coming to the fore now. And I think that is clearly the way people looking to go to say we want to partner with you. Because we feel you can help us get to where we need to get to the meat water, my journey for the longer term. And I think that’s appealing to both sides.

I think this whole sort of ecosystem and ecosystem management is you can just create a dramatically different kinds of business processes a result of it quite leading edge very relatively quickly. It’s just I get frustrated when you said I know, we can see all that we’re just gonna do on a spreadsheet. I

think we’re almost moving into a sort of classic, what I would call it sort of classic FinTech scenario whereby when the back challenger bank started coming along, some of the Challenger banks, they had all the tech for the mainstream banks had all the customers. And so this instead of Battle of whether it was how you got the customers onto the new tech, and that sort of that tension between it’s always easier to start with a clean sheet with a new challenger, than it is to adapt what you have because you have to take long to do but you have the customer the established people have the customers and the clients look after so you really need to find a solution that is currently deployed for the people with the with the customers as well.

Very good. So I want to change tack a little bit on honestly, just with your background around insolvency, in particular talk a bit about that insolvency process and check ins in reference around that advice, iba zeros etc. And there was some new, I think the latest study came out was talking about iba started to see a decrease insolvency or bankruptcy seem to be relatively the arrows are increasing. I don’t know if you had a view of that. And you must have seen it in terms of what’s going on. And I know we had a lot of changes in the IBA market last year.

Yeah, I think we’re probably seeing sort of a bit of a hiatus in the IBA market. There. There are a significant number of factors to play. And I think it’s true, there are a number of factors at play here. There’s been some very significant changes to the way funding as tax has taken place. We’ve seen for quite a long time, historically, there’s been significant funding and investment in this market that has driven a lot of the growth. And that was funding a lot of introducer, firms etc. And we’re seeing a lot of customers coming into the process by that route, then we have the FCA ban on introduces and we’ve seen some changes in the marketplace there that’s definitely had an impact, I think it’s going to have I think we haven’t seen all of that that’s changed the route into market for people coming into the IPOs. People are finding different ways of rooting people in there. But there has certainly been an adjustment, there’s had to be an adjustment in terms of how people get to help people attract people into that IPA Mark into that IPA base. There is also a lot more, I think, focus in terms of this market. So I think there is we’ve now seen the insolvency service starting to investigate historical allegations of over selling. And they’re looking at that very carefully. So I think there is I think the whole market is going through a bit of an adjustment where it’s saying, Okay, there’s a change going on here. How do we get this into a better place? And I think that’s the I think that’s actually really welcomed, because I think the IPAS have always been a very good solution. And I think they lost their way of it, some in terms of suddenly their reputation. And I think a lot of people got disengaged with them or the creditors have got to engage with them. And I think that there is now a wind blowing, that I haven’t felt for maybe over 1015 years, whereby there’s a desire on behalf of both IPs and creditors and regulators to to address some of the issues we’ve got without we’re not going to get primary legislation. We know we’re not going to fix it through that. But I do think there is a desire to look at this and say, Okay, how do we get some of the things how to get the IP market work better?

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Do you think we’ve got the right set of solutions? I’m particularly talking around Kenan Wales here. But if we got the right set of solutions for people in financial difficulty, he took him to insolvency type solutions or regulated regulated solutions and example, do we have the right kind of suite or do we need other kinds of solutions that’s often talked about? And I suppose then there’s the following question, which is, if we do have the right sets of solutions, was the IAVA. Almost like an imbalance where too many people go into one solution rather than going really having the right solution paid for them, which is part of the kind of review that’s going on underway? Yeah, I

think there’s a review. They’re gonna whether IVs were over promoted with that will run its course and don’t really want pine on on that I think there are lessons to be learned there are lessons to be learned from it. And I think, but I think that there are I think there, I think the range is good in terms of ova is Dr. Rose bankruptcies, the only thing that’s missing to my mind as potentially a statutory debt management plan solution, which I think was a missed opportunity. But there were issues around like a flexibility, etc, that we talked about. But I do think that potentially a flexible statute management plan would be a helpful addition, just in terms of setting out the parameters of what can be done with interest charges, things like that, giving debtors that sort of statutory protection whilst they were in the plan and abiding by the plan at the Justice they do within the OVA, because they have that protection within the IPA, but not within a sort of democratic government. So I do think that is a missing, that was a missed opportunity. But it may not have met it as being completed severe over the horizon we made it may reappear, we shall we shall see.

I’m just my question was just looking in the context of economic stress that’s going on with people and just making sure that we do have the right kind of suite as it helped people out knowing that there’s, there’s potentially a supply and demand kind of issue. But there’s also making sure you go through through to the right solutions as well, to making sure that people are getting all those solutions.

Yeah, I honestly believe that the problem is not so much about the products that are available. I think, as you identified, it’s about making sure we get the right people into the right products. I think consumer duty is extremely helpful in that regard. Like one of the things we’re we’ve been talking a lot to both the insolvency service. And the FCA most recently about is that interaction between IVR voting and consumer duty, because we know there’s no there’s not going to be any private legislation because there’ll be no parliamentary time when the insolvency service review concluded, wasn’t going to be pushing at this timeframe for the prime ministration changes. So you know, the way forward here with the overlay of consumer duty is to getting the creditors reviewing and invoking in an informed way. And if we can achieve that. And so I think that was will be hugely helpful in terms of, because I think we have an issue currently, whereby the IPS feel that some of their ideas, which they put forward are not being supported when they share EPs and a very good outcome for the consumers that there’s frustration on that behalf. There’s a sort of, there’s a bit of stress around on what is printed currently within the market. And some of the IPAS are not even being promoted because they know their side of room, which is seven to seven weighting engines. And I think, and also we there’s a feeling from cultures that they perhaps don’t feel empowered to to vote against IPAs, the fear of being being seen to be unduly unsupportive or unhelpful to their, to their customers. And I think all of that can change if we can start to use some data into that environment. And people can vote with a bit more confidence in terms of I have evidence and something I can produce to the FCA, that shows me this is a good sustainable IPA. Therefore, I’m going to vote in favour of it. And perhaps it’s the IP providing that evidence to those which makes the consumer think or the creditor think about when they’re voting whether they should be supporting. And perhaps it’s the creditor saying I’ve evaluated the Riba and it’s a good sustainable Opa, and therefore, I’m going to vote in favour of it, or we don’t think it is and therefore we’re going to feel empowered to vote against it. And I think that is, I think all that comes together under that whole FCA consumer duty overlay for the creditors about the insolvency service overlay of the IPS and how we demonstrate we’re not over selling this solution. And I think those two things collect together very well to producing a more healthy approach to IPAs. And I think that’s really welcome. And what’s really encouraging me Chris is the first time we’re now seeing the insolvency service and the FCA working collaboratively together. So we saw the FCA attended the recent IPA event. We’ve seen them engaging with players and stakeholders and including ourselves in about the IVIG space with the FCA has been for some time being tough, probably filled out enough on its plate. It wasn’t fully engaging with that. But the FCA now seems to be really engaging with this area. And I think that combination of the FCA and the insolvency service filling that what was sometimes a bit of a grey area because it was IVs weren’t regulated by the FCA regulated through the included regulatory bodies. And there was that sort of the creditors were very collated by the FCA. So how do we now we’re seeing a joining together of those two regulators to address the issue. And I think that is what I mean, in terms of there being a wind of change coming that I think actually will be good news for creditors, I think it’ll be good news for IPs. And then it’ll be good news for consumers, if we can get it all. The data angle

seems quite interesting, just in terms of historically, it was almost like it was a little bit feels like it was a little bit more hands off. And so if you’re in the process, it wasn’t quite as hands off when you’re dealing with individuals. But from a creditor point of view is like it was more of a, you didn’t have the time or necessarily the data or the techniques to be able to go down almost down to individual parameters or customer parameters to really disables that the right decision or not. But it seems like that’s a that’s an opportunity now in terms of getting access to that information to get much more almost like customised type decisions. Whereas people may be a little bit more reliant on almost like policy type decisions before rather than this is what’s right for customers. And that good customer outcome almost like drives that to certain extent plus data. Yeah,

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and that, for us is absolutely fundamental. And I’m sure it’s in it, chords entirely with the FCA is approach of being a data driven approach. One of the things we’re really keen to do is to and we’ve started to do this already is to look at the actual data and look at what the what are, what it tells us, and how it can inform those decisions. Because I think there’s been a paucity of data across DMPS and IVs. Historically, it’s been it’s not been widely accessible. And we’ve been able to, and with this new spirit of sort of cooperation across the piece, we were able to start to access data, produce some analysis, which was shared with the FCA. And we’ve shared with the insolvency service, and we’ve shared with a number of parties, in terms of looking at what the current behaviours are, and how we could use data to more effectively and intelligently in terms of this piece, there is a good solution out there that we can, can take this forward. But data has got to be the key part of it the objective use of data. And that I think, is the groundswell and that’s part of the future for a lot of these things. And it’s back to a technology driven solution that can be applied easily.

Yeah, I always find it fascinating when you almost like you have preconceived or common understanding around what is actually going on. You look at the data and you find that something maybe something else is slightly going on. Right? It’s Oh, I didn’t really think that was going on. And I don’t know if you’re getting any of those kind of aha moment as you get into it. Oh, actually, it doesn’t quite work the way I think it is. And maybe we got to concentrate on this. Right? That’s, that’s fascinating, because it especially if leads to better customer treatment. Right?

Exactly. Right. And Chris, you’re absolutely spot on. When we started looking at the actual data. It was you made you realise that sometimes the widely held preconceptions or views, the data was showing something quite different. Sometimes it is clearly evidence that is happening. But other times, it’s clearly shown really surprising things like data usually does, when you remove all the preconceptions when you move are all opinions. And you just talk about the data and show what that actually says to you and let the numbers talk rather than than anybody else view. It’s very insightful and very clear. And we have had a number of those aha moments or we’ve gone. Gosh, that that is surprising, shall we say. But it’s, it’s been very, we continue to gather data. And we continue to use data and we had a conversation with the insolvency service. And they were really pleased with the level of data we’ve been able to get access to. And we continue, we are grateful for the support that we have from all the people who are providing the data to us, because it is giving a much better and informed and objective understanding of what’s going on and how he moves things forward positively, and genuinely. For all parties. We are looking at this from the basis of how we make IPAs work and for IPAs to work. They have to work for creditors, for customers and for insolvency practitioners. And it’s no good for a long time, I think we’ve tried to approach this to fix it for creditors or to fix it for IPs or, and we’ve got to have a more holistic approach to this market to make it work. And I do believe that combination of consumer duty services, insolvency service review and the market dynamic changing because all coming together to coalesce to make that actually actually something that can be achieved. And I

know you’re at the startup side looking at some of that data, as you say I’d be interested to see some of the outcomes once they come out and then we’ll make sure everyone check back to you to see what see what comes out. Really, I think it’d be be fascinating for sure. Now, there was no doubt you’ll be talking at some of the conferences later in the year.

Yeah, we really hope so. Look, we are we are wanting to be clear, we’re not looking to challenge the current environment. We’re not setting setting up in competition with anybody. We’re just trying to facilitate better outcomes here. So I hope that we can be regarded moving forward as non threatening, supportive, and that we would very much welcome where we are being So we’ve shared this information in this answer service with the FCA. And we’ve shared it with with a number of the voting agents already some of the creditors we’re not, you know, we’re not, it’s not, we’re not trying to be super secretive about this. But we do want to get the information in the data out into the market. And we do want people to understand what’s actually going on and what the opportunities are to make things better. So we would really welcome the chance to talk about those events this year. Because I think we will have a very compelling data pool in terms of what is actually going on.

We have over five aha moments, as you as you see the data coming up. So it’s fascinating. Where do you think we go from here in terms of we’ve come a long way, as you said, right at the top, there’s still more to do. But what’s what do you see sort of like, if you look out into the next year or two years? Where do you think it’s what do you think is going to change environment wise? What’s your kind of sense? I think,

I’d like to feel that we would move to a more a much more data driven, I think we are going to have to be have a much more data driven approach, because I think that’s what the regulators are going to demand. And I think that’s what’s going to be delivered. And I think that need for data that need for evidence is going to derive a much more technology enabled much more fleeter foot sort of environment. And I think that we will see the way people receive that their data device change that’s already beginning to happen. But I think that we will see significantly, I really hope we’ll see significant improvements in how that advice is delivered. The intelligibility of that advice, the understandability, that advice, I’m a huge fan of the work that I provide global have been doing in terms of that clarification by numbers, people like that they’ve got really, there’s no doubt whatsoever, what we want is people on the right sustainable debt solutions. And I think getting and I think making sure they understand what they’re getting into at the outset is a key part of that. So I hope that we will see long term sustainable debt solutions. And that will, we’ll finally start to deal with some of the historical sort of anomalies or areas where it hasn’t worked quite as well as it could have done. And I think, as I said, I think what we’ll see my big prediction would be that we will see technology, playing a significant part in addressing the debt advice. shortfalls, we can call it that. But also in terms of improving the customer experience and improving the sort of way we get the right people the right solution.

Now, and as you said, the pace of change has been huge. So it’s going to be it’s gonna be very interesting to watch the next year or so just as all of these techniques are sort of tumbling down into this kind of sector, right? We’ve seen it upstream in social media, those going to introduce almost using the data understand what’s going on with expanding to this sector is really quite interesting.

And I agree, Chris, we’ve both been in the industry for 20 years. Plus I think it’s fair to say, and I cannot remember a time when it was more exciting in terms of technology. I think the last time I was excited about this about how technology changes things was when litre power dialers came that will fry the noodle of anybody who’s under so

Peter, thanks very much for making the time I appreciate it’s fascinating. It’s gonna be very interesting to watch length as you say how things develop and we’ll check back in so thanks very much.

Thanks, Chris. Really appreciate the chance to chat.


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