Category: Banks

Reserve Bank should act on Absa’s interest mistakes

THE South African Reserve Bank seems to have little appetite to deal with the miscalculation of interest rates by Absa. The bank has been paying back its customers millions of rand because it overcharged them on their credit cards. I am told more than 50,000 clients were affected, with one client due a R90,000 refund.

One would have expected the Reserve Bank to move swiftly and assess how deep this goes. But the central bank’s response is that “in terms of section 33 of the South African Reserve Bank Act, (it) does not comment on individual entities. Complaints on interest rate charges are referred to the banking ombudsman as the (Reserve Bank), in terms of the Banks Act, does not have the legal powers to intervene between a bank and its client.”

I think the Reserve Bank is reading the act too narrowly. It does not know how widespread this problem is and immediately concludes that it should not intervene. What if it is widespread and affects other banks?

A few years ago, Absa miscalculated interest on a client’s car loan. A senior Reserve Bank official said — and I have it on record — that it was an “isolated incident”. I guess he was wrong, because it has happened again with another Absa lending product.

A miscalculation of interest can pose a risk to SA’s banking system. Imagine if a bank had overcharged clients interest to the tune of R2bn and these clients were suing to get their money back. This would be a problem for the bank as R2bn is a lot of cash.

Dealing with interest miscalculation should not be restricted to the National Credit Regulator and the banking ombudsman. The Reserve Bank is tasked with promoting the soundness of SA’s banking system, and should take on this battle.

Speaking of battles, all because of brinkmanship, about R500m owed to five large South African banks is now at risk and may not be fully recovered should there be a failure to sell African Bank Investments Limited (Abil) subsidiary Standard & General Insurance (Stangen). If other creditors are included, the sum owed to creditors is close to R1bn. Should Abil’s business rescue fail and a liquidation is granted, the biggest losers will be the creditors, including the banks.

The parties involved include Abil’s black economic empowerment (BEE) shareholders, business rescue practitioners and African Bank curator Tom Winterboer. Last week Winterboer, under pressure to create a “good bank” from Abil by February, walked away from acquiring Stangen.

Winterboer had offered R1.38bn for Stangen, but Abil’s BEE shareholders, Hlumisa and Eyomhlaba, thought they were being fleeced as Stangen produced half-year profits of R786m. The shareholders wanted at least R4bn for Stangen to recover something of the R1.5bn they had lost over the past nine years.

The sale of Stangen would have realised about R2.6bn for Abil shareholders if cash at Stangen is taken into consideration. The BEE shareholders, although they believe they are not the spoilers, essentially torpedoed the deal. They knew they stood to get nothing from Stangen and decided to play hard ball. Essentially, close to R1bn would have gone to the creditors and another R1.3bn would have gone to preference shareholders.

However, it seems that the parties who wanted the Stangen deal to go through for R1.38bn underestimated the hand of the BEE shareholders. Because Hlumisa and Eyomhlaba had already lost R1.5bn, they felt business rescue was aimed at helping creditors rather than ordinary shareholders.

Winterboer is not a loser. But the African Bank “good bank” has lost out on making close to R1bn in capital in the first two years, which is what Stangen was expected to bring in.

In Winterboer’s words: “The capital expectation over the first two years was a R955m contribution through recapitalisation of the bank. After taking account of other impacts of not needing to fund the acquisition of Stangen, the actual capital reduction is of the order of R640m, which will be compensated by the good bank taking a larger amount of cash across from the existing African Bank.”

Winterboer felt it was better to make an arrangement with another insurer to underwrite the unsecured loans advanced by African Bank, as he could not afford delays. That is his choice. He could not be forced to buy something he felt was too expensive.

South African best and worst banks list

A new report by social intelligence firm, Ubiquity, has revealed which of South Africa’s retail banks are winning over the country’s social media populace.

The report analysed Absa, Capitec, FNB, Nedbank and Standard Bank, gauging the opinions of South Africans on social media around key banking issues, such as customer service, banking fees, credit and savings.

South Africa’s best and worst banks list

Granting of emolument attachment orders

The South African Human Rights Commission (SAHRC) welcomes the judgment handed down yesterday by the Western Cape High Court in a matter relating to the lack of judicial oversight in the granting of emolument attachment orders (“EAOs”). The SAHRC intervened in the matter as amicus curiae, to champion the human rights of people who are poor and vulnerable. In handing down his judgment, Judge Desai placed on record the court’s ‘indebtedness to the amicus curiae and their counsel.’
This case raised important questions about the protection of human rights of people who are poor, marginalised and vulnerable. The case was instituted by against the Minister of Justice, the Minister of Trade and Industry, the National Credit Regulator, 13 micro-lenders and a firm of attorneys.   The applicants were a group of low income earners living in Stellenbosch, who support themselves and their families on salaries of between R1200.00 and R8000.00 per month. They were represented by the University of Stellenbosch Law Clinic.

Prior to this judgement, EAOs were issued in the magistrate courts to compel employers to deduct moneys (instalments in terms of judgment debt) owing to creditors, from the wages of employees. This continued until the full amount of the debt was paid off. Such orders, were issued by a clerk of court. The clerk was not obliged to evaluate the implications of the order on the livelihood of the debtor. This meant that there was no judicial oversight in the entire process. The orders could also be issued in courts where the debtor did not live or work.

Banks to be sued over repossessions

Fifty people, represented by Housing Class Action, are taking the countrys four major banks, Nedbank, Absa, Standard Bank and FNB, to court.

Johannesburg – A class-action lawsuit to force banks to stop repossessing the homes of South Africans and then selling them off at a fraction of their value is expected to be heard in the high court.

Fifty people, represented by Housing Class Action, are taking the country’s four major banks, Nedbank, Absa, Standard Bank and FNB, to court. They want either their repossessed property returned or substantial monetary compensation.

While banks often reject allegations that they care little for ordinary South Africans, the human rights group says it has records of houses being sold for R200 or R300, with the worst case being a house sold for R10.

“In most cases, properties are sold for 30 percent below market value,” the organisation said on Tuesday.

It has taken on the services of advocate Duncan Shaw, a specialist in banking law from Scotland.

“This matter may become a class action whereby the banks might have to pay back everyone in the country in the same position,” said the organisation, which is linked to the Financial Services Sector Campaign.

It said Shaw had studied the practices in other countries and found that most – if not all – the other countries require banks to sell repossessed homes at market value.

It said that despite the constitution and the country’s laws, the judiciary, sheriffs and the police acted contrary to the law in most cases.

“Whatever the law and the constitution say in defence of the people, in real, practical terms, working-class black people do not have the right to own property in certain areas in South Africa in 2015,” the organisation said.

It also plans on hauling other institutions to court which it believes have acted negligently in allowing the repossession to take place and the homes to be sold for less than their market value.

The group’s spokesman, Ian Beddowes, said they had put together a 200-page submission, but a court date had not been set.

“We’ve been up against syndicates which involve the courts, the police – people don’t want to deal with the issue of evictions. Most evictions are illegal and against the laws of South Africa,” Beddowes said.

“In South Africa, we have one of the most predatory banking systems in the world. The banks consistently do not comply with the provisions of the act that deals with repossessions.”

On Tuesday, Absa rejected the allegation that it was selling repossessed homes far below market value.

“As we have said previously, Absa does its utmost to ensure that our customers remain in their homes. With regard to sale in execution, auctions are a last resort after the bank has exhausted all possible rehabilitation solutions and resources available to the bank to recover the bad debt,” the bank said.

It said it had established a programme in 2011 to assist financially distressed home-owners to sell their properties privately before having the bank get involved.

“This programme is aimed at ensuring the highest possible price for the property is reached, as it is clearly in our and our customer’s best interest.”

FNB Home Loans head of operations Calvin Ndlovu said that if a property was purchased at a public auction, it was auctioned by the sheriff on behalf of the court.

“The bank has no authority over the auction process and therefore refers you to the sheriff’s department involved in the particular claim(s) made,” Ndlovu said.

Researchers make startling allegations of securitisation fraud at South African Banks

The Commercial Crimes Unit of the South African Police Services has asked for additional information relating to new evidence of securitisation fraud by the banks. Researchers sampled 600 bonds and expected – based on the banks’ own reported figures on securitisation – to find between 120 and 200 of these had been legally transferred to new owners. Instead, not a single bond had been reflected as having a new owner. This is a statistical impossibility, according to an expert statistician, pointing to widespread fraud by the banks. 

Johannesburg Commercial Crimes Unit
Johannesburg Commercial Crimes Unit

The Johannesburg Commercial Crimes Unit of the SA Police services called for an urgent meeting yesterday with Advocate Douglas Shaw following explosive new evidence alleging “serious fraud” by the Big Four banks over securitisation of home loans.

The police have asked Adv Shaw to supply further information and will then decide whether to brief the Public Prosecutor.

A team of researchers instructed by Adv Shaw investigated 600 bonds and found not a single one had been ceded to the new owners. What this points to, says Adv Shaw, is that the banks have been deceiving the courts and home owners about their securitisation activities in order to appear as if they are still the registered bond owners, when in fact they are not. This allows them to collect mortgage bond payments on behalf of the new owners and take judgment against defaulting borrowers, neither of which are legal where the bond is securitised (securitisation is the practice of bundling thousands of mortgages together and on-selling them to investors on the JSE).

In effect, the research suggests that what the banks have done is simply hide the fact that they have sold the bonds to new owners and carry on as if nothing has happened, and then lie in front of the court that they remain the registered owners of the mortgage bond. It was long suspected that this was the case, but now some real evidence has emerged.

The researchers expected to find at least 20% of the 600 bonds examined had been ceded, as this would chime with the banks’ own reported figures on securitisation. The fact that not a single bond had been recorded as having a new owners (which is what the cession actually means) has raised grave suspicions of fraud by the banks.

What this means is that many of the securitisation instruments traded through the JSE may be “empty shells” with no, or under-reported, underlying assets. The evidence also seems to suggest bondholders are being habitually lied to by the banks when they ask for evidence as to whether or not their loans have been securitised.

If so, this could prove to be one of the biggest banking frauds in South African history, according to one securitisation expert contacted for comment.

This could prove to be one of the biggest banking frauds in South African history

This follows an investigation headed by Adv Shaw into the shadowy practice of securitisation. Where loans have been securitised, the banks lose legal title to these loans. When questioned by bond holders, the banks typically deny their loans have been securitised or ceded to new owners, and demand the bondholder provide evidence, which is a virtual impossibility because of the secrecy surrounding this practice. The banks continue to act as collection agents for the new owners, which is expressly prohibited in terms of Section 78(g) of the Banks Act.

Ammunition for home owners under threat

A few years ago it was reckoned by the banks’ own figures that upwards of R30 billion in loans were securitised each month. This new research should provide ammunition for home owners under threat of losing their properties. When these matters come to court, the banks typically hold up the title deed and show no evidence of a cession as supposed proof that the loan has not been securitised. Now, it seems, we know why. The loans may have indeed been securitised, but the banks have not complied with the law by reflecting the cession in favour of the new owner on the Deeds registry. This allows them to sue the home owner in the bank’s name, rather than the new entity. In doing so, they are effectively committing fraud on the courts since they have no legal right to be there.

test the banks’ honesty when it comes to securitisation
test the banks’ honesty when it comes to securitisation

Adv Shaw said he decided to launch a project to test the banks’ honesty when it comes to securitisation, and what he found was shocking. “I’ve been arguing securitisation for years in the courts, and it disturbs me that the courts tend to take the banks at the word when they deny securitisation. So I decided to dig deeper and find the truth.”

A number of researchers instructed by Adv Shaw decided to test whether the banks had ceded their mortgage loans to new entities. Based on available evidence, 20% to 30% of all mortgage bonds in South Africa are securitised, which means these bonds should be ceded to the new owners and reflected as such in the Deeds register.

A sample of 600 bonds dating back to 2009 were searched, representing bonds issued by all four major banks. Not a single bond was reflected as having been ceded. The mortgage bonds selected were “traditional securitisations” rather than derivative-based, and are therefore supposed to reflect ownership of the underlying assets.

“Statistically, we thought we might find that 20% or even 10% of bonds had been ceded,” says Adv Shaw. “We found that not a single bond had been ceded.” A statistician has provided evidence that the chances of this occurring randomly are statistically negligible.

Is this important, and if so, what does it mean?

“It means that the new owners of the bonds have bought empty shells with no assets. We are increasing our sample size to validate the initial research, but on the face of it, the banks are guilty of committing serious fraud on the investors to whom they sold these mortgage bonds, and they are committing fraud on the bondholders.”

The SA Police Services were immediately notified and asked for an urgent meeting, which took place today. Further information has been requested and likely then be forwarded to the Public Prosecutor.

Says Shaw: “This is quite similar to numerous other frauds in the US, where banks played fast and loose with the law when it came to securitisation. The difference is there they were slapped with hefty fines. The banks in South Africa have been lying about the nature and extent of their securitisation for years, and they have been pulling the wool over the eyes of the courts.”

The JSE replied to questions sent to it by Acts Online (see the full response below):

“While the JSE ensures that adequate disclosure is made in respect of the securitisation scheme, it does not authenticate the underlying securities in the scheme. However agreements required in order to list these structures on the JSE include detail of the relevant assets, as well as security provided by the originator. That being said, if specific information is provided to the JSE demonstrating that there are no ‘assets’ within a particular structure, then we will certainly take this up with the issuer concerned. However, we do not believe this to be the case.”


One of the researchers briefed by Adv Shaw, Norman Morgan, who investigated 50 mortgage bonds issued by Absa, deposed in an affidavit: “I have read the Absa accounts in which they aver that they have securitised a large percentage (about 20% to 40%) of their mortgage loans and I was therefore expecting that 6 to 12 (30% of the 20%-40%) of the deeds that I pulled would have bonds properly registered in the name of the securitised entities that they use.


“I was therefore extremely shocked and surprised to find that none of the 50 bonds that I drew on Windeed (an on-line deed search facility) were registered to any of Absa’s securitised entities.

“I understand that other people in the same position as myself have done similar searches on Windeed for the properties around their home and have also found no bonds registered to Absa’s securitised entities.

“It is therefore established on the balance of probabilities and indeed beyond reasonable doubt that the bank is deceiving the courts on a massive scale by claiming that a deeds registry search showing that the bank is the owner of the bond is in evidence and that the bank still owns the bond.

“It is thus evident that the bank is knowingly repossessing 20-40% of the time when it has no locus standi to do so.

“It is therefore evident that the bank is committing a systematic fraud on the court by securitising bonds and then failing to come in the name of the new entity.”

Other banks are likewise accused of the same practice by researchers briefed by Adv Shaw.

The fact that your bond is not ceded in the Deeds registry means nothing. This likely can no longer be used by the banks to rebut claims of securitisation.

Expert statistician Garth Zeitsman investigated the research data and deposed in an affidavit: “I have studied this matter in detail and my expert opinion is as follows: The probabilities indicate that the banks do not in general register their bonds with the deeds registry. They are thus knowingly attempting to deceive the judges who hear cases when they support their contention that a particular bond is not securitised by reference to the deeds registry. They would be aware that they have not, in fact, properly registered their securitised bonds there. They would also then be aware that providing an entry from the deeds registry would prove nothing.”

Not only does this mean many investors may have bought securitisation instruments that are legally suspect, they may also be technically worth less than reported – if anything at all. The research provides powerful new ammunition to bondholders who suspect they have been victims of fraud by the banks.

Hundreds of thousands of South Africans have come to learn about securitisation over the last few years due to a media campaign that was carried, in the most part, through social media and the internet. The mainstream press largely ignored the issue.

Each year more than 10,000 South Africans are hit with summary judgments and stripped of their homes by the banks after defaulting on their loans. What many thousands of customers have been trying to find out from the banks is whether their loans have been securitised. They are generally brushed off with a blanket denial, or the banks insist the customer provides proof, on the legal basis that “he who avers must provide proof.” But Adv Shaw counters this by arguing that he who hides evidence inherits the burden of proof.

Game changer

This is certainly a game changer for those arguing the securitisation defence, since they can now buttress their arguments with the new research. It puts the banks on the back foot.

If a mortgage bond is securitised, the law requires the banks:

·         To inform the bondholder of the change in ownership (under the National Credit Act)
·         To cede the mortgage bond to the new owner at the Deeds office, and
·         Section 79 of the Banks Act prohibits the banks from assuming the role of collection agent for the new owner.

It has long been suspected that the banks have been conducting securitisation in secret and in doing so are in wilful violation of several statutes.

This latest research increases pressure on government and the National Credit Regular to establish a registry in terms of section 69 of the National Credit Act (NCA). “This is required to provide investors with confidence and to clear up uncertainty about whether or not they actually have any backing for their investments,” says Adv Shaw.

Those Absa fires again

Of all the banks, Absa is unique in claiming that many of its original mortgage bond documents, along with electronic copies, were destroyed in a fire at the Docufile storage facility in 2009. As we reported previously, it has been able to obtain summary judgment and repossess countless homes without the original documents. Absa has been able to do this by placing unsigned “standard agreements” before the court, claiming these were identical to the ones signed by the defendants. Adv Shaw challenged this story by holding up several different Absa agreements in the South Gauteng High Court, some with 11 clauses and others with more than 100, arguing that it was impossible for the bank to pass off an unsigned agreement as the same as the ones signed by the banks’ customers. Last year Judge Sutherland of the South Gauteng High Court refused Absa’s attempt to take summary judgment against two home owners who allegedly defaulted on their loans, Kevin Jenzen and James Grobbelaar, and ordered the bank to present proper documentation should it wish to pursue the matter. He referred the matter to trial. This now stands as a crucial precedent for others in the same situation.

Greece to freeze home repossessions

Interestingly, as Greece debates whether to stay or leave the EU, the new left-leaning Greek government is playing tough over home repossessions. According to Fortune magazine, “Greek PM Alexis Tsipras vowed to roll back deregulation of the labor market, one of the main reforms of the bailout. He also said he will present a new bill stopping banks from foreclosing on loans against primary residences, according to the Greek newspaper Kathimerini. (Eurozone officials grumble privately that the government is already pressuring the banks to be too easy on their bad loans.)”

This is likely to set an international precedent that could quickly sweep the world as the latest financial crisis deepens.

The JSE replies:

The JSE sent the following reply to questions posed by Acts Online on the above findings.

In South Africa, securitisations are regulated according to the securitisation regulations issued under the Banks Act 94 of 1990 (the Banks Act). These regulations were published under Government Notice 2, in the Government Gazette 30628 of 1 January 2008 (the Securitisation Notice). The Securitisation Notice regulates the corporate status, ownership and control of the issuer SPV, and the issue of commercial paper by the issuer SPV.

Securitisations are therefore regulated by the Registrar of Banks under the Banks Act. The prior approval of the South African Reserve Bank (SARB) must be obtained before the issuer SPV can issue commercial paper in a securitisation. Thus, the creation of securitisation schemes are regulated by the Registrar of Banks.

In your email, you refer to a legal obligation to cede bonds to the new owners at the Deeds registry. Such a requirement is not included in the Listings Requirement and as a result we are not best placed to comment on this.

The JSE’s jurisdiction relates to the listing of the instruments that were created, in accordance with the securitisation regulations mentioned above. This is done through the JSE Debt Listing Requirements (the Debt Requirements). While the JSE does not regulate the creation of securitisation schemes, the exchange ensures that adequate disclosure is made in respect of the securitisation scheme.

The Debt Requirements provide for the minimum disclosure which investors and their professional advisers would reasonably require so that they can make an informed assessment of the nature and state of the issuer’s business. The Debt Requirements contain the rules and procedures governing new applications and the ongoing obligations of new and existing issuers. Section 6 of the Debt Requirements makes specific provision for listing of instruments issued by a securitisation SPV, requiring requires disclosure of the (i) underlying assets, (ii) details of the securitisation scheme and (iii) a description of the sale and transfer of the assets or assignment of any rights in the assets to the applicant issuer.

While the JSE ensures that adequate disclosure is made in respect of the securitisation scheme, it does not authenticate the underlying securities in the scheme. However agreements required in order to list these structures on the JSE include detail of the relevant assets, as well as security provided by the originator. That being said, if specific information is provided to the JSE demonstrating that there are no “assets” within a particular structure, then we will certainly take this up with the issuer concerned. However, we do not believe this to be the case.

Securitisation expert comments on Adv Shaw’s findings

A securitisation expert, formerly with one of the Big Four banks comments:

My gut-feeling tells me that the banks are using securitisation as a means of moving non-performing loans (NPLs) off of their balance sheets and thus window-dressing their financial statements.  This is done by freeing up capital which is tied up in these NPLs, so that cash can be utilised for a new batch of lending to bank clients.

The process is as follows:

·         The bank sets up a company referred to as its SPV (Special Purpose Vehicle) to facilitate the transaction; it then batches and “sells” (cedes) selections of its assets to this SPV.
·         This SPV is then a company with assets but no financing
·         Enter asset management companies and pools of investors’ cash (be it through hedge funds, unit trusts, etc.) which want to earn a better rate on their investments than what is offered by the local money market.  Obviously, if the investment is asset-backed (the old adage “safe as houses” applies), then these investors aren’t even venturing significant additional risks for this increased return.

Now, the problem comes in … What if the loans continue to be non-performing? Who has the jurisdiction to enforce debt recovery?  The client did not enter into an agreement with the SPV.  Nor was the client aware that the bond had been ceded.  The bank has potentially set up the SPV and the offer to investors with the assurance that they will remain in charge of the administrative duties of the loans in the SPV (probably at a considerable fee). This is an arguable transgression of Section 78(g) of the Banks Act.

And this is probably why the bank still appears as the bondholder on the properties that have been ceded (the discovery of Adv. Shaw’s team therefore does not surprise me). This is so the bank continues to appear as the bondholder and that everything is still under control.

But, once the loans are in default, how can they sue?  They are no longer a party to the contract … or as the courts have stated so eloquently: they have no locus standi.

So, now they’re in a tight spot. They have to perform on their contracts with the SPV and the investors owning the bonds, but legally they can’t.  Hence excuses and litigation without documentation.

R30 billion a month (in securitisation) sounds a bit much. But, what I’m wondering (given competitors in the industry buying from each other, such as SA Home Loans buying from Standard Bank) is what the Competition Commission will think.  I am rather certain that no bank will disclose on its financial statements that an SPV or any other organisation owns some of its bonds. That makes it fraudulent towards investors owning Bank shares (and regulators). This also implicates their auditors to a large extent.

I welcome the involvement of the Commercial Crimes unit, and I wish to be part of the investigation.

To contact Adv Shaw’s research group, please contact

Also from Acts Online:


Judges rule for property owners against banks

After three years, the Moores finally own their house. Again! Six years ago, the Vereeniging couple fell prey to a reverse mortgage scam known as the Brusson scheme, named after the unregistered credit provider who managed to dupe about 900 people into handing over ownership of their properties in exchange for a loan. The Moores received notice that the sheriff of the court would attach their property in August 2011, but less than two weeks ago, they knew that their home was safe. This is because the Legal Resources Centre (LRC), which is representing about 100 people affected by the scheme, won a judgment in the high court in Joburg on September 26 to return ownership to the Moores. Although the bank was not party to the scheme, Acting Judge Mohammed Chohan found Absa could not attach the property because the Moores had not intended to transfer ownership of their property to a third property. ‘It was amazing,’ a relieved Christine Moore said. ‘It was a stressful period but we can now breathe again.’

The LRC won a similarly favourable judgment on September 25 in the case of the Radebes, who in 2007 were also caught in the scheme. ‘We’re over the moon, we’re so happy. We thought it would never end,’ the Radebes said. The LRC has been battling with 90 different cases involving Brusson Finance, which was never a registered credit provider and has since gone into liquidation.

Essentially, Brusson would deceive homeowners into signing over ownership of their properties into a third party ‘investor’ to secure loans. ‘Quite clearly, the Brusson scheme was widespread and would seem to have targeted the most vulnerable of people, namely those who were already over-indebted,’ Judge Chohan wrote in his judgment. In a statement issued after the judgments were handed down, the LRC said these two rulings were vital for future similar cases involving the Brusson scheme and banks, which it accused of reckless lending. ‘With such a favourable judgment, the LRC is in a better position to litigate on behalf of the other 90 clients we are currently assisting, some of whom are in various stages of litigation,’ the LRC said.

In the Moore and Radebe cases, Absa and Nedbank, respectively, had provided the loans to the fake investors, although Judge Chohan said there was no doubt there would be other financial institutions that had made loans to the Brusson scheme. The banks argued in the two cases that the homeowners should have known or foreseen of the binding consequences of the contract with Brusson. But the judges in both matters, Judge Chohan and Judge Caroline Nicholls, to different extents, agreed that the homeowners had no intention of selling their properties and were deceived by Brusson. Both judges said the banks were still entitled to pursue claims against the investors.

Judge Nicholls ordered Nedbank to pay the legal costs in the Moore case, while Judge Chohan ordered each party to pay its own legal costs.

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