Subject: Global KYC passes banking cmte
Date: Fri, 9 Jun 2000 12:38:29 -0400
From: JBJ["Institutional imperialism" is how the prime minister of a neighboring country refers to our global money laundering policy (explicitly praised in HR 3886, the money laundering bill passed by the House banking cmte yesterday). All this to stamp out "harmful tax competition." Ignorant of the effects of their actions, many congressmen may support legislation that will cause diplomatic rows and possibly worse - JBJ]
WORLD NEWS: US & CANADA:Privacy advocates lose telephone records case
Financial Times, 6 Jun 2000
By PATTI WALDMEIR[The California Bankers Association v. Shultz (1974) that upheld theThe US Supreme Court yesterday ignored the pleas of privacy advocates and refused to limit the way that American telephone companies use customers' information to try to sell them new services.
constitutionality of the Bank Secrecy Act said that the government could
require private companies to collect information on you and that you did not
have an expection of privacy to those records. Rep. Ron Paul has introduced
HR 518 to repeal this act. http://www.house.gov/paul/privacy]The court let stand a Court of Appeal ruling that overturned federal regulations requiring telephone companies to get permission from customers before using or disclosing their telephone records - calling patterns and other personal information - for marketing.
The Court of Appeal had ruled that federal regulators' efforts to protect consumer privacy in this area violated the constitutional free speech rights of telephone companies. The Supreme Court declined to review that decision. Federal regulators are now drawing up new rules to protect privacy while satisfying the courts.
The case captures the increasingly potent conflict between consumer privacy and the rights of companies to "commercial speech", rights that the Supreme Court has expanded in recent years. In a separate decision, the court agreed to referee a dispute over federal rules intended to keep telephone service affordable in high-cost areas. Patti Waldmeir, Washington
WORLD NEWS: LATIN AMERICA & CARIBBEAN:
Caribbean protest over Forum ratings
Financial Times, 6 Jun 2000
By CANUTE JAMESCaribbean offshore financial centres have attacked criticism of their standards of supervision and transparency in last month's report by the Financial Stability Forum.
The centres said that the ratings by the Forum, a group of financial regulators, finance ministries and central banks, represented another unfair attack on their jurisdictions. [snip]
"Institutions in the developed world that have no authority under any treaty, convention, agreement or legal instrument known in international law, are simply attempting to bend the course of development in countries such as ours, to their will by use of crude threats and stigmas," said Owen Arthur, prime minister and finance minister of Barbados. "It is nothing more than a form of institutional imperialism." [snip]
Eduardo D'Angelo Silva, the president of the Cayman Islands Bankers Association, said he was surprised to see the territory put in the lowest of the FSF's categories "when a number of other financial investigating bodies have put us on the top list and commended us for the quality of our supervision and regulation."
Recent investigation by the British Foreign and Commonwealth Office had given the Cayman Islands high praise for co-operation, legislation and regulation. "The grouping is totally unjustified," said Mr Silva. [snip]
The FSF's listing was published a month before the Organisation for Economic Co-operation and Development plans to list jurisdictions which its says provide "harmful" tax competition, and whose regulatory oversight offer opportunities for financial criminals.
The OECD, based in Paris, said last month that it will delay by a year punitive action against delinquent jurisdictions. Caribbean governments have concluded that the FSF's listing is part of the OECD effort, said a St Lucian government official.
"As a member of the World Trade Organisation, Barbados subscribes to the General Agreement on Trade in Services," said Mr Arthur. "This is the only agreement which has a standing in international law that binds us on the matter of trade in services."
Coalition for Constitutional Liberties - Weekly Update for 6/8/00 Volume 3, Number 23
Brought to you by the Center for Technology Policy of the Free Congress Foundation
Lisa S. Dean, Julie McIntire"FOR THE SAKE OF THE CHILDREN" -
Endangered Liberties Commentary, Lisa DeanFor the past eight years Republicans and conservatives have been beating up on the Clinton Administration for being so pro-big government and with good reason. No Administration in recent history has taken the slogan "I'm from the government and I'm here to help you" more literally than Clinton has, nor has any Administration in history been likened to George Orwell's 1984 more than Clinton's. Every program has been in the name of protecting children, or fighting the drug wars or protecting national security and those same programs have done very little to correct those problems but have done quite a lot to erode our Constitutionally guaranteed liberties. Therefore the criticisms by Republicans and conservatives are not without merit, in fact, many were on target.
So that's why it is beyond appalling to see Republicans and conservatives now engaging in the same sort of activity - in the name of protecting kids, fighting the drug war and protecting national security.
On October 1, 1997 President Clinton instituted the National Directory of New Hires, better known as "the deadbeat dads database". It would require every employer in the U.S. to report the personal information it collects on every new employee whether full or part time to the federal government. This information would then be added to the database, allegedly, Clinton said, for the purpose of catching those parents who didn't pay child support. At the time, an official for the Department of Health and Human Services called it the largest effort on the part of the federal government to collect personal data on its citizens.
This pitiful attempt at protecting our nation's children also took away some of the privacy we as citizens have enjoyed in our lives because now the federal government keeps tabs on where you work, what your responsibilities are and so forth. At the time of the database's institution, many Republicans and conservatives were outraged at this big government intrusion into our lives and we naively thought their outrage was directed at the big-government Democrats. Now we realize that it was just directed at Democrats.
Rep. Nancy Johnson, a Republican from Connecticut has introduced "The Child Support Distribution Act of 2000", a bill that supposedly helps children by making sure their deadbeat parents pay their child support. Sounds all well and good. It does something else too. It expands the use of the National Directory of New Hires while further eroding the Constitutional rights of the rest of us. In addition to the personal information already being collected by the government, this bill would also allow financial institutions to get into the act. The same financial institutions that are legally permitted and encouraged to monitor your account and report you to the federal government if they think you might be committing a crime now will be able to cooperate with the government if they believe you are a deadbeat. So the bottom line is that, in addition to the federal government having your personal information on file to be shared with whomever it chooses, they will also have your financial information such as income and where you spend your money, not to mention what you spend it on. A proponent of the bill referred to it as a "conservative answer to the problem." Funny but since when have conservatives looked to Big Brother to solve the nation's problems? I guess it's okay - after all, it's a Republican taking away our rights in the name of children, rather than a Democrat.
Now, in case that example didn't convince you, allow me to offer another. H.R. 2987 the "Methamphetamine Anti-Proliferation Act of 1999" was offered by Rep. Chris Cannon, a Republican and co-sponsored by conservative Members Asa Hutchinson, Charles Canady and Matt Salmon on the House side and in the Senate, a similar measure was introduced by conservative Republican Senator John Ashcroft of Missouri.
While the bill is designed to better equip law enforcement to stop drug trafficking and shut down methamphetamine labs, it does more. It shuts down the Fourth Amendment to the Constitution. A section of the bill deals with Notice Clarification and traditionally that refers to the issuance of search warrants and court orders by a judge to law enforcement, in accordance with the Fourth Amendment to the Constitution. However, H.R. 2987 seems to agree with the Justice Department's "we need a Fourth Amendment for the Information Age" viewpoint and tramples all over the one that our Founding Fathers gave us.
Under current law, owners must be immediately notified if any seizure of their property takes place by law enforcement conducting a criminal search. That includes your residence, your offices, your vehicles or any other property you may have. H.R. 2987 rescinds that portion of the law and allows for law enforcement to search and seize your property WITHOUT HAVING TO INFORM YOU, THE OWNER OF THE PROPERTY, all in the name of fighting the war on drugs. Even though the section is included in a bill that is related to methamphetamines, it does not apply strictly to that type of investigation. I don't know about you but I would put that in the category of "unreasonable search and seizure".
We're told that "the era of Big Government is over" and the era of bipartisanship has finally arrived, but quite frankly, I don't see much of a difference between the two. But in the rare event that anyone hears a Republican open his mouth to speak against a Democrat, the only honest words we could possibly hear him say would be, "Hello Mr. Kettle, I'm Mr. Pot. You're black."
Endangered Liberties Program Excerpts:
Regarding the four Big Brother 2000 Awards, host Paul Weyrich asked Endangered Liberties guest Dave Banisar of the Electronic Privacy Information Center about the recipients of each award: "Let's work through the categories. What's the first one?" Banisar replied, "The first category was Worst Project. That goes to some sort of proposal or suggestion or government plan that is really totally invasive of privacy. ... This year we gave the award to the FAA for their body-scan proposal.
This is where they're putting these very intrusive X-ray devices into airports. ... And these X-ray devices are not like normal X-ray devices. They actually create an image of somebody underneath their clothes. And they're putting these into a variety of airports for security reasons. And so we gave one to them." Weyrich asked, "Did anybody from the FAA pick up this award?" Banisar answered, "We do these very tongue-in-cheek, so we actually had somebody dress up as a skeleton and receive the award on their behalf and give a speech on their behalf, but unfortunately nobody from the FAA has actually ever called us to get their award."
Weyrich asked, "The second category of the awards is what?" Banisar said, "The second category is for Worst Government Agency or Government Official." Weyrich asked, "Who ended up getting the award for the Worst Government Official?" Banisar said, "Well, this year it was William Daley and the U.S. Department of Commerce receiving the award for all their efforts ... for the past seven years on privacy. They've given us crypto export controls for a number of years that are still in place; they've been relaxed somewhat, but they still impose controls. They've given us opposition to passing privacy laws. They've given us any number of bad proposals on collecting information from individuals, including the Census this year."
Weyrich said, "Let's move on to the next category." Banisar responded, "Well, the next category was Worst Corporate Invader." Weyrich queried, "Who was this year's awardee?" Banisar said, "The winner this year was DoubleClick, which has sort of done for the Net what Stasi East Germany did for East German civil rights. They have managed to insert themselves into tens of thousands of web pages and monitor people as they cross everywhere on the web. On something like 70 to 100 million Americans they're keeping records."
Weyrich asked, "What is your fourth and final category?" Banisar said, "Our final category is for the Lifetime Menace Award. And this was to give to some entity ... who's been doing this for a long time and who's done just a terrible job of messing with people's privacy for a long time." Weyrich asked, "And the winner is?" Banisar replied, "We gave it to Trans Union, which most people probably haven't heard of, but they're one of the big three credit agencies. They hold your credit record. And when somebody steals your identity because they get your Social Security number, the odds are it's a good chance they probably got that indirectly somehow through Trans Union because Trans Union sells pieces of your credit report without your permission in violation of federal law and have been doing it for 20 years now, no matter what government agencies are trying to shut them down." Contact: Producer Joseph Starrs 202.546.3000
NSA TO TURN OVER NON-SPY TECHNOLOGY TO PRIVATE INDUSTRY
By Vernon Loeb, Washington Post Staff Writer, June 7, 2000 ; A29The super-secret National Security Agency announced yesterday that it plans to turn over to private industry the development and management of most of its nonclassified information technology in a single, 10-year contract that could be worth as much as $5 billion to the winning bidder.
Lt. Gen. Michael V. Hayden, the NSA's director, called the initiative "unprecedented" at an agency that has historically kept most of its technology development in-house. He said the contract would free NSA management to focus on retooling critical spy technologies that are increasingly threatened by fiber-optic cable, digital cell phones, encryption and the Internet. "It narrows our front and allows us to focus the energies of the agency on the things that only the agency can do," Hayden said in an interview.
NSA officials said the initiative--"Project Groundbreaker"--could save the government as much as $1 billion over the 10-year term of the contract and provide much faster modernization of the agency's desktop computers, servers, computer networks and telecomunication systems. Once in place, the contract would eliminate the jobs of 1,200 to 1,500 NSA employees and an additional 800 contractors. However, all NSA employees affected by the change will be guaranteed jobs by the winning bidder. Those who do not accept the offers would be laid off--a first for the agency, officials said. Three private-sector consortiums led by major U.S. corporations have been assembled to bid on the contract. Officials declined to name consortium members. The bids are due in late November and the contract is scheduled to be awarded in April 2001.
Hayden and Stephen E. Tate, the NSA's chief of corporate sourcing, said the contract would be one of the largest, and the most complex, information technology contracts ever awarded by a federal agency, covering network management and security, workplace computer systems, telecommunications and network development. "Our information technology infrastructure is a critical part of our mission and it needs some repair," Tate said. "It is a burning platform and we've got to fix it."
The contract would not cover management, development or operation of the NSA's "mission systems"--acres of supercomputers, multiple satellites and numerous sophisticated ground stations in the United States, Europe and Australia used to intercept and process global electronic communications.
A computer meltdown at the NSA's Fort Meade, Md., headquarters in January rendered the vast spy agency incapable of processing its global intelligence signals for several days. While no vital intelligence was lost during the crash and no international crises occurred then, Hayden and other top NSA officials were alarmed by the computing failure.
While Hayden's predecessor, Lt. Gen. Kenneth A. Minihan, began considering a massive outsourcing initiative 15 months ago, the computer crash dramatized the need for faster modernization at an agency that helped create the computer industry in the 1950s. Since his arrival a year ago, Hayden has accelerated the pace of change at what had been for years the country's most secretive, insular bureaucracy. He and other intelligence officials say the next three to five years will be crucial in determining whether the NSA can adapt to changing technology and continue its preeminence in signals intelligence.
HOW SAFE ARE ONE-STOP FINANCIAL WEB SITES?
Look, there's your portfolio
By Heather Timmons in New York, NewsweekManaging your finances online appeals to you, but the bank account is at one Web site, the brokerage at another--and each of your credit cards has its own site as well. Now, instead of jumping around the Net, popular Web sites are offering to collect all that financial information for you, allowing you to use it the same way you always did--but with just one log-on name and password. Some 300,000 consumers already use these services, and 3.7 million more are expected to sign up over the next 18 months.
Web users can gain access to these services at some well-known sites such as CNBC.com and Ameritrade.com, but the bulk of the data-gathering, record-keeping, and security functions belong to one of two companies that you've probably never heard of--VerticalOne Corp. and Yodlee Inc. Both data processors, or ''aggregators,'' are little more than a year old. Unlike banks and brokers, they are unregulated and may have no responsibility for fraud. The two are quietly amassing a trove of valuable data on consumers' buying, borrowing, payment, and investment habits, much to the chagrin of bankers. ''They're doing what banks should have,'' says Octavio Marenzi, managing director at Celent Communications Inc., a Boston consulting firm.
Here's how the aggregation process works. A customer signs up for the finance-managing service at a ''partner'' Web site such as CNBC.com. In setting up the account, customers must type in their account numbers and passwords--information that goes directly to VerticalOne or Yodlee. Every night, their computers go online to Web sites run by the banks and brokers, and log on with the customer's name, account number, and password to retrieve information. This data-gathering process is known as ''screen scraping.''
If you've ever had doubts about putting one credit-card number online, how about your entire financial life? VerticalOne and Yodlee insist their security is bulletproof. Account numbers and passwords are never actually in the hands of the Web-site partner. Instead, they're collected and held by the aggregators.
The account information is separated into names, numbers, and passwords. It's then encoded and stored in high-security databases that use palm-scanners for access. Although together the companies have several hundred employees, there are only six--three executives at VerticalOne and three at Yodlee--who have complete access to the information.
That is an enormous responsibility for these two small companies. Anyone with access to the databases at one of these sites could have thousands of accounts and passwords at his or her disposal, critics worry. Unlike a thief who steals just your credit-card number, this person could theoretically wipe out your entire financial portfolio.
The portfolio wipeout scenario isn't just idle speculation, some say. ''There's a real risk that someone could break in and run amuck,'' says Marenzi. ''Every system that human beings have ever built has failed at some point. It's not a question of if, it's a question of when.'' Armed with the information that these sites compile, a brazen thief could start mailing checks, running up charge-card purchases, and even set up a second bank account, Marenzi says. Hacking into retail sites and illegally using credit-card numbers is already common. About 15% of all purchases made over the Internet are either frauds or chargebacks to correct mistakes, adds Naftali Bennett, chief exec of Cyota.com Inc., a New York City company that makes software designed to limit credit-card fraud.
Account aggregators deny that a break-in is possible. VerticalOne, a subsidiary of bank adviser S1 Corp., collects data for more than a dozen different Web sites, including Ameritrade's OnMoney.com, Smartmoney.com and iVillage.com. VerticalOne chief executive and founder Gregg Freishtat says logging on to one of the Web sites his company services is no more risky than going online to each bank or credit-card company where you have an account. The risk lies where your account information and passwords are held, Freishtat explains. In VerticalOne's case, that's at the company's Atlanta data center. Security measures include 24-hour video surveillance, round-the-clock security guards, and regular drug tests and background checks for employees.
TRIPLE-CHECKED. Yodlee.com, which consolidates account information on its own site as well as partnering with Altavista and Intuit, among others, was founded by P. Venkat Rangan, a former University of California at San Diego computer science professor, and his two brothers. At Yodlee, names, account information, and passwords are also separated and stored in a secure site away from its Sunnyvale (Calif.) headquarters. Information is encrypted and employee backgrounds are checked. ''We've had three different security firms come in to check our system, as well as some financial institutions,'' says Matthew Idema, vice-president for operations.
So would cracking the codes at these data consolidators require a James Bond-like effort?. The two firms are ''following the right design principle'' to ensure that data is secure, says Daniel Geer, chief technology officer of @Stake Inc., a security firm. But other security experts are quick to add that their allure for a thief is unmistakable. ''If these companies get as big as they want to be, they're going to be like the Grand Prix for hackers,'' says Adi Shamir, security adviser at Cyota.
If naysayers like Shamir are correct, the big question becomes: Who's liable if hackers steal your accounts? The aggregators are not regulated by the federal government like banks, and technically have no responsibility to make consumers whole in case of a break-in. VerticalOne guarantees to reimburse up to $100,000. Yodlee makes no such guarantees.
Sensing their vulnerability, some banks began criticizing these sites last> year. Under the Electronic Funds Transfer Act, the law that governs electronic transactions, banks are on the hook if a hacker or employee gains access to account information at an aggregator and illegally transfers funds, explains Kit Needham, co-chair of BITS, Banking Industry Technology Secretariat, a trade group. ''Nobody anticipated this kind of technology when this rule was written,'' she says. ''Banks have no way to protect themselves.'' BITS has asked the Federal Reserve to issue an opinion about banks' specific liability; it's expected this summer.
QUESTIONS REMAIN. The Web sites that offer the aggregators' services also present a competitive challenge to banks. They keep customers away from the banks' online sites, making it harder to sell additional products. And though the aggregators say they don't share specific account information with anyone, they are exploring ways to market to specific customers. For example, if a cell-phone operator is looking for frequent travelers with high mobile-phone bills, aggregators could identify them. But instead of giving up names, the aggregator could display the cell-phone company's ad when those customers went online.
Banks have fought legal battles to keep the screen scrapers from gathering data at their sites without success. In fact, rather than fight them, some banks are even partnering with Yodlee or VerticalOne to develop account aggregators at their sites. Everbank.com and Hibernia Corp. have already announced such partnerships, and more such deals are expected. ''Many would argue that account consolidators are as safe as online brokerage services,'' says Robert Foregger, executive vice- president at Everbank.com.
Still, questions about security and liability remain. Says Gayle Wellborn, director of customer advocacy at First Union Corp.: ''Should something happen, it's not going to reflect well on anyone.'' Indeed, if there is a security breach that leads to large losses, consumers will paint the aggregators, the Web sites, and the banks with the same brush.
SUPREME COURT LETS PHONE COMPANIES USE CUSTOMER DATA
The use of information such as people's calling habits to market more services to them is criticized as an invasion of privacy
By Kalpana Srinivasan, The Associated Press, June 6, 2000WASHINGTON -- The Supreme Court on Monday allowed telephone companies to continue using customer information -- such as their phone-using habits -- to market other services to them without their permission.
That means phone companies don't need to get written, oral or electronic consent from consumers before using their records to try to sell them other products -- as federal rules had sought to require. Instead, the companies could use phone bills to target pitches for new services as long as they disclose they are doing so and customers do not expressly object.
An appeals court had knocked down the Federal Communications Commission rules implementing parts of a 1996 telecommunications law. On Monday, the justices, without comment, refused to reinstate the protections.
US West, SBC Communications and other local phone companies had challenged the FCC's rules, which said customers must actively "opt-in" to allow their data to be used. The commission said such an approach would ensure that customers knowingly waive, at least partially, the privacy of their phone records.
But the companies said the rules violated their free-speech rights by taking away their ability to tailor their communications to their customers. "The court has taken a responsible and consumer-friendly position," US West spokesman David Fish said. "Now the phone companies can protect privacy while at the same time answering customers' desires to be kept up-to-date about new products and services."
US West, a Baby Bell providing local phone service in 14 Western states, said the FCC could safeguard customers' privacy by allowing an "opt-out" approach instead.
The appeal acted Monday was filed by the Competition Policy Institute, an independent nonprofit organization that advocates greater competition in telecommunications and is funded primarily by companies seeking entry into the local phone market.
The group had sought to reinstate the commission rules -- thrown out by a three-judge panel of the 10th U.S. Circuit Court of Appeals -- arguing that such information is "data, not speech."
On Monday, the group said it hoped the FCC would be able to implement new rules that would protect consumer privacy and be defensible in court. "I think it's alarming what might happen unless responsible policy-makers get involved and return consumers rights to them," said Ron Binz, the institute's president. He warned that companies could release the profiles of customers' calling patterns to third parties.
Jason Catlett of Junkbusters, a New Jersey-based privacy advocate, said without safeguards, phone records could be used to "counter-coupon." For example, if a consumer orders items from one catalog company, that information could be sold to a rival. "The last thing we need is an Orwell long-distance," Catlett said.
Phone companies have insisted that they only want to use the information within their own divisions and that they support getting prior consent from customers to give the data to unaffiliated third parties, said Laurence H. Tribe, a professor of constitutional law at Harvard Law School, who had argued on behalf of US West in the 10th Circuit case. Tribe expressed hope that in crafting new regulations the FCC would "draw a more sensitive balance and a distinction between use by the telephone company itself and use by a third party," he said.
The circuit court, while throwing out the commission's regulations, did not strike down the underlying provisions of the telecommunications law and did not bar the FCC from trying to impose new privacy-protecting rules. In light of that, the commission decided not to mount a Supreme Court appeal. Clinton administration lawyers said Supreme Court consideration of the case would be premature because the FCC has not yet decided what rules might suffice.
CONGRESS IS WORRIED ABOUT WHO HAS YOUR SOCIAL SECURITY NUMBER
[Rep. Ron Paul has introduced HR 220 limiting use of the SSN]CNN.com, May 9, 2000WASHINGTON -- The misuse of Social Security numbers has skyrocketed, setting off alarms on Capitol Hill, where lawmakers are considering ways to protect consumers from fraud.
Every time you open a bank account, file your taxes or admit yourself to a hospital, you will be asked to provide your Social Security number. But when you do you might give someone an opportunity to steal the nine-digit number that has almost become a virtual national ID number.
It happened to retired Air Force Lt. Col. John Stevens Jr., 72, and his wife Mary. The couple said the theft set off a financial nightmare that started in March 1977. The Stevens testified Tuesday before the House Ways and Means subcommittee on Social Security, telling how their names and Social Security numbers had been used to establish credit to buy cars, jewelry and much more. The 33 fraudulent transactions so far total about $113,000. "We are prevented from buying a home, establishing a credit account, making purchases and leading a normal life," the colonel said. "We are tired of the harassing phone calls and the threatening letters."
Areas of vulnerability
The couple is not alone in their predicament. The Social Security Administration's fraud hot line received 62,000 phone calls last year from Americans claiming misuse of their Social Security numbers. The agency also reported that fraud increased 175 percent between 1998 and 1999, and the rate is expected to go even higher because of the ever-increasing use and sale of electronic data.
Many states use the numbers on drivers' licenses, although some, including Ohio and Georgia, have made that optional to protect privacy. It is neither illegal nor unusual for businesses to request, share or sell Social Security numbers for tracking customers, or along with other information used for marketing or financial background checks.
Social Security numbers are sold by information brokerage firms, along with other personal data gathered legally from public documents such as court files, tax liens and professional licenses. The files list Social Security numbers because government agencies use them as identifiers. "There needs to be some focus on regulating the use of the Social Security number and there also needs to be some aggressive deterrents," testified James Huse, inspector general of the SSA.
Possible protective action
Among the suggestions the inspector general made to improve security concerning Social Security number were:
* Make it illegal for businesses to refuse service if someone does not disclose their Social Security number, when it is not relevant.
* Require photo identification when conducting business with the Social Security Administration. [snip]Business groups and some state and local governments have opposed restrictions in the past as a costly and inefficient way to devise new and disparate identification systems. But the widespread use of Social Security numbers can give people with dishonest intentions easy access to others' personal records, including financial and medical data, or help criminals assume another person's identity to obtain credit or government benefits.
It is currently a federal crime to assume another person's means of identification. But there is no federal law regulating the public or private use of Social Security numbers.
Correspondent Jeanne Meserve and The Associated Press contributed to this report.
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