2015 Reporting Updates Tuesday / December 15, 2015 1pm Central / 2pm Eastern Learning Objectives • Describe the reporting changes for the exhibits and schedules of the annual statement filing. • Explain the reporting changes to the Notes to Financial Statement and identify the related SSAP(s). • Identify the common reporting issues. • Identify the future issues that may impact reporting. Mary Caswell NAIC Data Quality Manager – Manages Data Quality Unit – Supports Blanks Working Group – Supports Health Reform Solvency Impact Subgroup – Supports Investment Reporting Subgroup • • Joined NAIC in August 2000 MBA • Contact email information: mcaswell@naic.org Adopted Changes 2014-19BWG – General Interrogatories, Part 2 reference and 5 Year Historical reference for statutory minimum capital and surplus. Health Blank: Changes the reference for Line 11 from “minimum net worth” to “statutory minimum capital and surplus.” 2014-20BWG – Note 32 & 34 Change to correct inconsistencies in the use of “market value” and “fair value”. The separate accounts disclosure, Note 34 change: Reserves by withdrawal characteristics, i.e., whether or not for the separate account: • Subject to discretionary withdrawal including the categories of: – Fair Market value adjustment – Withdrawal at book value without market value adjustment and with or without current surrender charge of 5% or more – At fair value – Withdrawal at book value without market value adjustment and with current surrender charge of 5% or less • Not subject to discretionary withdrawal 2015-01BWG & 2015-02BWG 2015-01BWG – Remove barcode listing form lists from barcode instructions in the appendix. 2015-02BWG – Supplemental Health Care Exhibit – Eliminate the Aggregate 2% Rule Column for Parts 1 & 2. – Replace with a column to capture Medicare Advantage Part C Plans and Medicare Part D Stand Alone Plans which are no longer excluded by statute. 2015-03BWG – Property Blank & Health Blank Supplements Property Line of Business Appendix • Consolidating lines of business definitions and added some definitions. – Deleted from Exhibit of Premiums and Losses – Added to the Appendix (examples:) • Occurrence, Claims Made Commercial Multi-peril: Builders’ Risk Policies, Businessowners, Commercial Package Policy, Manufacturers Output Policies, E-Commerce, Difference in Conditions (DIC) Definitions – Inland Marine • Animal Mortality • EDP Policies • Pet Insurance Plans • Communication Equipment (Cellular Telephones) • Event Cancellation • Travel Coverage • Boat owners/Personal Watercraft • Other Commercial Inland Marine • Other Personal Inland Marine 2015-04BWG - Title Blank Title Insurance 5 Year Historical Page (From Parts 2 & 3 of Scheduled P) • Add one year and two year loss development lines – Development in estimated losses and ALAE on policies (claims) effective before current year – Percent of such development to policyholders' surplus of prior year end Polling Question #1 Generally disclosure changes to the annual and quarterly filings Notes to Financial Statement are driven by changes in the SSAPs. True ____ 10 False____ U&I, Part 2B – Health Blank 2015-05BWG • Columns 1 through 4, line 10 of U&I, Part 2B should equal health care receivables on Exhibit 3, Columns 6 and Column 7 (excluding health care receivables, such as loans or advances to non-related party hospitals, established as prepaid assets that are not expensed until the related claims have been received from the provider.) • Note U&I, Part 2B is reported on a “net of reinsurance basis”, Exhibit 3 is reported “gross of reinsurance”. • Crosschecks added to gain consistency where possible. 2015-06BWG – Note 11B, FHLB • Add crosschecks to the illustrations data captured for Note 11B to clarify the inclusion of Class A and B membership stock not eligible for redemption. 1 2 3 Membership Stock 1. Class A 2. Class B Current Year Total Not Eligible for (2+3+4+5+6) Redemption Less Than 6 Months Eligible for Redemption 4 5 6 months to Less Than 1 to Less Than 1 year 3 Years 6 3 to 5 Years b. Membership Stock (Class A and B) Eligible and Not Eligible for Redemption 11B(2)b1 Current Year Total (Column 1) should equal 11B(2)a1(a) Total (Column 1) 11B(2)b2 Current Year Total (Column 1) should equal 11B(2)a1(b) Total (Column 1) 2015-07BWG – Schedule A, Part 1 / SSAP 40R • Modify the instructions for Schedule A, Part 1 to reflect the reporting of real estate owned by a LLC on Schedule A if it meets the requirements set forth in SSAP 40R, Real Estate Investments. • Adds a code “!” to Schedule A, Part 1, to identify all single real estate property wholly-owned by an LLC that meets the criteria set forth in SSAP No. 40R. Cash Flow 2015-08BWG/ SSAP 69 Cash Flow instructions - to reflect the inclusion of only cash transactions. Reconciliation of investment activity. Although non-cash items are included for reconciliation purposes, the Statement of Cash Flow shall only include transactions involving cash. In addition to excluding the lines that are explicitly non-cash items (e.g., change in admitted assets) from what is reported in the Statement of Cash Flow, adjustments are necessary to remove non-cash acquisitions or disposals. SSAP 69 guidance change 2015-09BWG -Note 5A, Mortgage Loans/SSAP 37 8) Mortgage Loans Derecognized as a Result of Foreclosure: Current Year a. Aggregate amt of mortgage loans derecognized b. Real estate collateral recognized c. Other collateral recognized d. Receivables recognized from a government guarantee of the foreclosed mortgage loan $ $ $ $ 2015-11BWG – Note 1, Significant Accounting Policies/ SSAP 1 D. Going Concern Provide disclosures regarding any going concerns of the company or plans for the entity’s ability to continue as a going concern. (1) If doubt about an entity’s ability to continue as a going concern is alleviated, the reporting entity shall disclose in the notes to the financial statements the following information: a. Principal conditions and events that raised substantial doubt about the entity’s ability to continue as a going concern (before consideration of management’s plans). b. Management’s evaluation of the significance of those conditions or events in relation to the entity’s ability to meet its obligations. c. Management’s plans that alleviated substantial doubt about the entity’s ability to continue as a going concern. 2015-11BWG – Note 1/SSAP 1 (2) If substantial doubt is not alleviated, the entity should indicate such indicating that there is substantial doubt about the entity’s ability to continue as a going concern within one year after the date that the financial statements are issued. Disclose management’s plans to mitigate the conditions or events causing the doubt about the entity’s ability to continue as a going concern. (3) Going concern evaluation and disclosures are required for both interim and annual financial statements and in subsequent annual or interim reporting periods to which the condition continues. In these subsequent periods the disclosures should become more extensive as additional information becomes available. (4) For the period in which substantial doubt no longer exists (before or after consideration of management plans), an entity shall disclose how the relevant conditions or events were resolved. 2015-12BWG – Note 5G, LIHTC / SSAP 93 (2) The amount of low-income housing tax credits and other tax benefits recognized during the years presented. (3) The balance of the investment recognized in the statement of financial position for the reporting period(s) presented. 2015-13BWG – Cybersecurity Insurance (Property) Stand-alone Policies Direct Premiums Number of Claims Reported 1 2 First Third Party Party 3 Written $ Direct Defense and Cost Containment 9 Paid $ 10 Incurred $ Direct Losses 4 Earned $ 5 Paid $ 6 Incurred $ Number of Policies in Force 11 Claims Made 12 Occurrence Adjusting and Other Expenses 7 Paid 8 Incurred 2015-13BWG – Cybersecurity Insurance Part of a package policy: Cybersecurity Insurance Direct Losses Number of Claims Reported 1 First Party 2 Third Party 3 Paid $ Cybersecurity Insurance Direct Defense and Cost Containment 7 Paid $ 4 Case Reserves 8 Case Reserves $ Cybersecurity Insurance Adjusting and Other Expenses 6 5 Case Paid Reserves $ $ Number of Policies in Force 9 Claims Made 10 Occurrence $ 3.1 Can the direct premium earned … be qualified or estimated? Yes [ ] No [ ] 3.11 If not, explain why not_________________ 3.2 If yes, provided premium numbers________________________ Cybersecurity proposal – Identity theft If the reporting entity writes any standalone identity theft insurance coverage, please provide the following: 2. Standalone Identity Theft Insurance Policies 1 Number of Claims Reported Direct Premiums 2 Written $ 3 Earned $ Direct Defense and Cost Containment 8 9 Paid Incurred $ $ Direct Losses 4 Paid $ 5 Incurred $ 10 Number of Policies in Force Adjusting and Other Expenses 6 Paid $ 7 Incurred $ Cybersecurity proposal If the reporting entity writes any identity theft insurance coverage that is part of a package policy, please provide the following: 4. Identity theft insurance that is part of a package policy 1 Number of Claims Reported 2 Paid $ 3 Case Reserves $ Direct Defense and Cost Containment 6 7 Paid Case Reserves $ Adjusting and Other Expenses Direct Losses $ 4 Paid $ 8 Number of Policies in Force 5 Case Resereves $ 2015-14BWG – Schedule D, Part 1 • Add new electronic columns for Issuer, Issue, ISIN Identification and Capital Structure Code. Issuer Column & Issue Column: The reporting entity is encouraged to use the following sources: • Bloomberg • Interactive Data Corporation (IDC) • Thomson Reuters • S&P/CUSIP • Descriptions used in either the relevant SEC filing or legal documentation for the transaction. Do not report ticker symbols, either internal or otherwise. 2015-15BWG – Note 22, Events Subsequent / SSAP 106 •Did the reporting entity write accident and health insurance premium that is subject to Section 9010 of the Federal Affordable Care Act (YES/NO)? •TAC – 5 year historical crosschecks 2015-17BWG Contracts Subject to Redetermination Assets page: Line 15.3 – Accrued Retrospective Premiums ($_____) and contracts subject to redetermination ($______) Liabilities page: Line 4 (Health), Line 2 (Life & Fraternal): Aggregate Reserves Include: payables for/accrued return premium for contracts subject to redetermination. Income statement: Line 2 (Health) Net Premium Income, Line 1 (Life and Fraternal) Premiums Include: Accrued return premium adjustments for contracts subject to redetermination. 2015-17BWG – Additional pages affected Include: Accrued return premium adjustments for contracts subject to redetermination. Health: U&I, Part 1, Direct Business (column 1) U&I, Part 2D, Aggregate Write-ins for Other Policy Reserves (line 5) Life and Fraternal: Exhibit 6, Aggregate Write-ins (line 6) Property: Liabilities page, Aggregate Write-ins for Liabilities (line 25) XXX/AXXX Supplement - Life and Fraternal • Part 1 - All XXX and AXXX Cessions • Part 2A - Transactions Subject to Part 2 Disclosure (Grandfathered or Special Exemption) • Part 2B - Transactions Subject to Part 2 Disclosure (NonGrandfathered) • Part 3 - Collateral for All XXX/AXXX Reinsurance Transactions Reported on Part 2A or Part 2B • Part 4 - Non-Collateral Assets Supporting Reserves for All Affiliate XXX/AXXX Reinsurance Transactions Reported on Part 2A or Part 2B • Part 5 - Supplemental XXX/AXXX Reinsurance Exhibit Interrogatories XXX/AXXX – Part 1 Adds definitions: – Actuarial Method – Covered Policies – Required Level of Primary Security – Primary Security – Other Security Part 1 Column 10 – Special Exemption by Domestic Regulator (YES/NO) A “yes” response means - ceding insurer’s domiciliary regulator, after consulting with the NAIC Financial Analysis Working Group (FAWG) or other group of regulators designated by the NAIC, determined that all of the following apply to risks ceded: 1) such risks are clearly outside of the intent and purpose of AG-48; and 2) such risks are included within the scope of AG-48 only as a technicality; and 3) the application of AG-48 to such risks is not necessary to provide appropriate protection to policyholders under all the facts and circumstances. Part 2A & 2B Part 2A – Transactions Subject to Part 2 Disclosure (Grandfathered or special exemption) Part 2B – Transactions Subject to Part 2 Disclosure (Non-Grandfathered) Part 2A TRANSACTIONS SUBJECT TO PART 2 DISCLOSURE GRAND- FATHERED OR SPECIAL EXEMPTION) 1 Cession ID 9999999 Total 2 NAIC Company Code 3 ID # 4 5 Name of Company Effective Date or Prior Year Annual Statement Date As of Effective Date or Prior Year’s Annual Statement 6 Reserve Credit Taken 7 Required Level of Primary Security “Economic Reserve” Level 8 Primary Security 9 10 Primary Security – Trust Primary Security – Funds Withheld or ModifiedCoinsurance 11 Other Security As of Current Year’s Annual Statement 12 13 Reserve Credit Taken Required Level of Primary Security “Economic Reserve” Level 14 Primary Security 15 Primary Security Adjustment 165 176 187 Primary Security – Trust Primary Security – Funds Withheld or ModifiedCoinsurance Other Security Part 2B Part 2B – Transactions Subject to Part 2 Disclosure (Non-Grandfathered) 1 2 3 NAIC Cssn Cmpny ID ID Code # 9999999 Total As of Effective Date or Prior Year’s Annual As of Current Year’s Annual Statement Statement 6 7 8 9 10 11 12 13 14 15 16 17 18 Effective Prmary Primary Date or Scrty – Security – Prior Rqred Funds Required Funds Name of Year Rsrve Level Prmry Withheld Resrv Level of Primary Primary Withheld Cmpny Annual Credit of Prmy Scrty – or Othr Crdt Primary Prmry Security Security or Othr Statement Taken Prmry Scrty Trust Modified- Secty Taken Security Scurty Adjmnt – Modified- Scty Date Scrty Coins Trust Coins 4 5 Part 3 Applies to all the cessions identified in Part 2A or 2B; – Provided, that if the reporting entity has not received any collateral in connection with a cession identified in Part 2A, the only information required is the Cession ID number, Name of Company, NAIC Company Code, and ID Number. – The reporting entity should prepare a separate page for each Cession ID reported on Part 2. – The reporting entity should also provide a Grand Total page. Part 3 Part 2 Cession ID __________ Name of Company: ________________________________ NAIC Company Code__________ ID Number __________ Effective Date or Prior Year Annual Statement Date: __________ Security Category Description Primary Security As of Effective Date or Prior Year’s Annual Statement 1 2 Affiliate or Parental Guarantee Assets (YES/NO) As of Current Year’s Annual Statement 3 4 Affiliate or Parental Guarantee Assets (YES/NO) 1. Cash 2. NAIC 1 SVO-Listed Securities 3. NAIC 2 SVO-Listed Securities 4. NAIC 3 SVO-Listed Securities 5. NAIC 4 SVO-Listed Securities 6. NAIC 5 SVO-Listed Securities 7. NAIC 6 SVO-Listed Securities 8. Commercial Loans 9. Policy Loans 10. Derivatives acquired in the normal course 11. Subtotal Primary Security XXX XXX Part 3 Other Security 12. Cash 13 NAIC 1 SVO-Listed Securities 14. NAIC 2 SVO-Listed Securities 15. NAIC 3 SVO-Listed Securities 16. NAIC 4 SVO-Listed Securities 17. NAIC 5 SVO-Listed Securities 18. NAIC 6 SVO-Listed Securities 19. Commercial Loans 20. Policy Loans 21. Derivatives acquired in the normal course 22. Other Investments Admissible per the NAIC AP&P Manual 23. Evergreen, Unconditional LOCs 24. Other LOCs 25. Affiliate or Parental Guarantees 26. LOC-like Assets 27. Excess of Loss Reinsurance 28. All Other Assets 29. Subtotal Other Security 999999930. Total XXX XXX XXX XXX Part 4 • Applies to all the cessions identified in Part 2A or Part 2B where the assuming insurer is an affiliate of the reporting entity. • The reporting entity should prepare a separate page for each Cession ID required to be reported on Part 4. • The reporting entity should also provide a Grand Total page. Part 4 Part 2 Cession ID __________ Name of Company: __________________ NAIC Company Code______ ID Number_________ Effective Date or Prior Year Annual Statement Date: __________ 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Asset Category Description Cash NAIC 1 SVO-Listed Securities NAIC 2 SVO-Listed Securities NAIC 3 SVO-Listed Securities NAIC 4 SVO-Listed Securities NAIC 5 SVO-Listed Securities NAIC 6 SVO-Listed Securities Commercial Loans Policy Loans Derivatives acquired in the normal course Other Investments Admissible per the NAIC AP&P Manual 12. Evergreen, Unconditional LOCs 13. Other LOCs 14. Affiliate or Parental Guarantees 15. LOC-like Assets 16. Excess of Loss Reinsurance 17. All Other Assets 999999918. Total As of Effective Date or Prior Year’s Annual Statement 1 2 Non-Collateral Assets Affiliate or Parental Supporting Reserves – Guarantee Affiliate Transactions (YES/NO) XXX As of Current Year’s Annual Statement 3 4 Non-Collateral Assets Supporting Reserves – Affiliate or Parental Affiliate Transactions Guarantee (YES/NO) XXX Part 5 • Includes Interrogatories relating to Part 3 and Part 4 collateral – – – – Letters of credit, contingent note, or similar Pledged to a financing provider Duration less than the duration of the underlying policy liability Guaranteed by an affiliate or parent Supplemental Health Care Exhibit • 2015-19BWG - Cautionary statement and web link reference • 2015-20BWG - Risk Adjustment (contracts subject to redetermination), Risk Corridor (retrospectively rated contract) References SSAP 54, 66, 107 – Direct Premiums Written (SCHE Part 2) - Include: Premium adjustments for contracts subject to redetermination where premium adjustments are based on the risk scores (health status) of covered enrollees, rather than the actual loss experience of the policy • (examples: Medicare Advantage risk adjustment and ACA risk adjustment). – Rate Credits – instruction added for risk corridor premiums paid or received, and all other premium refunds paid or received related to retrospectively rated contracts. Supplemental Health Care Exhibit • 2015-21BWG - Footnote table addition – To capture 3R’s receivables, payables and receipts by state for individual and small group plans. AFFORDABLE CARE ACT (ACA) RECEIPTS, PAYMENTS, RECEIVABLES AND PAYABLES Current Year Prior Year Comprehensive Health Comprehensive Health Coverage Coverage 1 2 3 4 Small Group Small Group Individual Employer Individual Employer Plans Plans Plans Plans ACA Receivables and Payables 1. Permanent ACA Risk Adjustment Program 1.0 Premium adjustments receivable/(payable) 2. Transitional ACA Reinsurance Program 2.0 Total amounts recoverable for claims (paid & unpaid) XXX XXX 3. Temporary ACA Risk Corridors Program 3.1 Accrued retrospective premium 3.2 Reserve for rate credits or policy experience refunds ACA Receipts and Payments 4. Permanent ACA Risk Adjustment Program 4.0 Premium adjustments receipts/(payments) 5. Transitional ACA Reinsurance Program 5.0 Amounts received for claims XXX XXX 6. Temporary ACA Risk Corridors Program 6.1 Retrospective premium received 6.2 Rate credits or policy experience refunds paid 2015-21BWG AFFORDABLE CARE ACT (ACA) RECEIPTS, PAYMENTS, RECEIVABLES and PAYABLES Current Year Prior Year Comprehensive Health Comprehensive Health Coverage Coverage 2 Small 1 2 1 Small Group Group Employer Individual Employer Individual Plans Plans Plans Plans ACA Receivables and Payables 1. Permanent ACA Risk Adjustment Program 1.0 Premium adjustments receivable/(payable) 2. Transitional ACA Reinsurance Program 2.0 Total amounts recoverable for claims (paid & unpaid) XXX XXX 3. Temporary ACA Risk Corridors Program 3.1 Accrued retrospective premium 3.2 Reserve for rate credits or policy experience refunds ACA Receipts and Payments 4. Permanent ACA Risk Adjustment Program 4.0 Premium adjustments receipts/(payments) 5. Transitional ACA Reinsurance Program 5.0 Amounts received for claims XXX XXX 6. Temporary ACA Risk Corridors Program 6.1 Retrospective premium received 6.2 Rate credits or policy experience refunds paid Polling Question #2 For Schedule D, Part 1 description column report only what is reported in: A. B. C. D. Electronic issuer column Electronic issue column ISIN number column None of the above is correct 43 RISK-BASED CAPITAL CHANGES – YEAR-END 2015 44 Learning Objectives • Describe the reporting changes for the risk-based capital formula by line of business for year-end 2015 – Health – Life/Fraternal – Property/Casualty 45 Crystal Brown NAIC Sr. Insurance Reporting Analyst - RBC – Maintains the Health Risk-Based Capital Formula and Supports the UCAA application – Supports Health Risk-Based Capital (E) Working Group – Supports Health Risk-Based Capital Drafting Group (informal) – Supports Company Licensing Transactions (E) Subgroup – Joined NAIC in May 2006 – Bachelor’s Degree – Business Administration – Contact email information: cbrown@naic.org NAIC RBC Contacts Capital Adequacy (E) Task Force Jane Barr - Manager I – Company Licensing & RBC jbarr@naic.org 816-783-8413 Health Risk-Based Capital (E) Working Group and Health RBC Formula Crystal Brown - Sr. Insurance Reporting Analyst - RBC cbrown@naic.org 816-783-8146 Life Risk-Based Capital (E) Working Group and Life & Fraternal RBC Formulas Dave Fleming - Sr. Insurance Reporting Analyst - RBC dfleming@naic.org 816-783-8121 Property/Casualty Risk-Based Capital (E) Working Group and P/C RBC Formula Eva Yeung - RBC Technical Lead/Reporting Analyst eyeung@naic.org 816-783-8407 47 2014-24-H, 2014-39-L and 2014-30-P – Risk Adjustment & Risk Corridor Sensitivity Test – New Page 48 2014-25-H – Medicare, Medicaid and Other MLR – Page XR012-A 2014-36-L & 2014-31-P – Underwriting Risk – Experience Fluctuation Risk - Info Only Page LR020-A, FR020-A & PR020-A 49 2014-26-H – Pandemic and Biological Risk Interrogatories 50 2015-01-H – Investment Affiliates – Type Code 5 and Formula 2015-02-H – Clarification to Affiliates that are Subject to RBC Instructions 2015-01-H - The purpose of the change was to simplify the calculation of the charge for Investment Affiliates by applying a straight factor times the carrying value of the common and preferred stock. A correction to the formula calculation was also made in conjunction with this change on page XR002 2015-02-H - The purpose of this proposal was to clarify the instructions for Affiliates that are Subject to RBC and to ensure that the formula and instructions matched. 51 2015-06-H – Instructional Change for Other Coverages on page XR012 & XR012-A 52 2014-32-L Treatment of Cash Collateral Pledged for Derivatives Page LR012 – Miscellaneous Assets LR017 – Off –Balance Sheet and Other Items 53 2014-33-L XXX and AXXX Qualified 54 2014-35-L Shortfall of Primary Securities 55 2014-42-L RBC Shortfall 56 2015-16-L C-3 Phase 1 Informational Filing 57 2014-27-CR R6 and R7 Contingent Credit Risk 2015-04-CR EP Curve Sorting 2015-10-CR OEP Basis Factors for R6 &R7 58 2014-37-CR Exemption Criteria (Structure & Wording 59 2014-40-CR Attestation for Cat Risk Charge Methodologies The structure change allows companies to indicate which of the methodologies was used to sort the net and gross probable maximum losses. The purpose is to collect data on how companies are deriving their modeled catastrophe losses. 60 2014-38-P R3 Credit Risk (For Informational Purposes ONLY) 61 2015-07-P Asset Concentration – LIHTC & WCFI 62 2015-08P Valuation Basis Column on the Affiliated Investments Page 63 2015-11P Underwriting Risk Line 1 for Reserves Industry Average Development Factors and Net Written Premiums Industry Average Loss and Expense Ratios Factors 64 2015-12CR Line 1 Ex-Cat Industry Average Loss and Expense Ratios and Line 4 Ex-Cat Industry Losses and Loss Adjustment Expense Ratio 65 2014-22-CA Instruction Clarification for RBC Requirement Amounts, TAC and RBC Factors 2015-03- CA Jurat Signature Requirements 2014-22-CA 2015-03-CA 2014-23-CA AVR is limited to the Amount not used in Asset Adequacy Testing (Health & P/C) • Footnote Change: Instructions Change: “The portion of the AVR that can be counted as capital is limited to the amount not utilized in asset adequacy testing in support of the Actuarial Opinion for reserves.” 2015-05-CA ACA Fee Sensitivity Test Instruction change and reference change 2015-09-CA Broker’s Receivables Factors 2015-05-CA 2015-09-CA Health – 0.026 Life – 0.014 P/C – 0.027 2015-13-O – Operational Risk Factors (Informational Only) 2015-17-CA – RBC Procedures 2015-13-O 2015-17-CA • Developed procedures for the Capital Adequacy Task Force and all RBC related Working Groups and Subgroups. • Developed procedures for proposal submissions, exposures, adoptions and posting of adopted proposals until RBC publications are available. 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