SEPA – The 2007 Issues and Way Forward
This document is a White Paper written in close collaboration between the European Association of Corporate Treasurers and TWIST Process Innovations. The White Paper is designed to feed the debate on how payment services should be developed under the umbrella of the Single Euro Payment Area (SEPA) to meet the needs of corporates in their role as heavy users of payment services in Europe.
The original SEPA design and the achievements by the EPC (European Payment Council) testify to the immense efforts made by the banking industry in making SEPA happen. This paper attempts to complement these efforts by pointing out the obstacles that still have to be overcome so as to achieve the full potential of SEPA and to meet the expectations of corporate stakeholders and other ‘heavy users’ such as public administrations. The EACT and TWIST observe that on the ”eve” of the inital implementation of SEPA in January 2008, there is still too much uncertainty, ambiguity and confusion about the project and its design. This deters corporations from making a clear commitment to SEPA. A serious dialogue between the banks, their corporate customers and public administrations about the removal of obstacles, plus the planning and monitoring of SEPA, might be the breakpoint between success and failure of this in itself laudable project.
This SEPA White Paper identifies the existing barriers to SEPA, as preceived by EACT and TWIST, and presents a list of actionable items for the banking community and its stakeholders.
Draft, not for general publication
Version 0.9 – London, August 21th, 2007
Aimed at providing a legal framework for harmonised payment services in the EU, the EU Council and the European Parliament have formally accepted a Payment Services Directive (PSD) that was carefully drafted by the European Commission. This PSD is now in the process of transposition in national laws of EU Member States. At the same time, the European banking sector is preparing for the related implementation of the first deliverables of a Single Euro Payment Area (SEPA) by January 28th 2008. Much work has been done by the banking community to design an inter-bank framework that can support standardised processing of payments throughout the EU. The result of this effort is impressive, but incomplete.
To help reach the objectives of SEPA and to ensure widespread adoption, there are three key themes that need to be addressed. Firstly, a deeper understanding of SEPA is still needed for a wider audience. Secondly, a more collaborative effort between the various parties in the payments and financial supply chain industry would greatly help to ultimately realise true end-to-end straight through processing in payments. Thirdly, national implementations of SEPA need to be more co-ordinated and made consistent with the overall objective of cross–EU harmonisation.
This White Paper assumes that for SEPA to be successful, it needs to be attractive for users of payment services to migrate their systems and practices from the current well known solutions to the new SEPA world. This means ensuring a business case for change, consisting of value adding solutions, minimised migration cost and limited project risk. Thus far much attention has been paid by the banking industry on meeting the various legislative requirements, reflected in the Payment Services Directive, in a cost-effective manner for banks. This has led to the focus in the SEPA design on inter-bank infrastructural needs and minimised migration costs for individual banks. The result is a design that does not meet many commonly known user requirements and even more importantly puts the burden of implementation much more with users than one would expect in a truly open and efficient payments market.
To help kick-start the dialogue between the banking industry and the users of payment services, this paper identifies both the existing barriers to SEPA, as perceived by EACT and TWIST, and specific recommendations. With an aim to widen communication channels to achieve a constructive dialogue, a draft version of this white paper will first be circulated in August 2007 to a small audience of corporates, bankers and regulators. After receiving feedback, the white paper will be updated to present a consensus about the issues and possible solutions, plus a clear list of actionable items for banks and their stakeholders. Wide publication of this White Paper is expected in the fall of 2007.
The EU Commission’s drive for a harmonised and automated internal market can be considered to be an excellent opportunity for enabling open market access and cross organisational automation. Pan-European commerce should flow as easily as electricity. But it currently cannot, as yet, given the complexity of paper trails and incomplete automation. Modern, straight through financial processing of purchasing, ordering, invoicing, payments and financing is frustrated by paper-based processes and disjointed attempts at automation. As part of the EU’s modernisation agenda much effort is put into creating a European environment where commerce can move as easily as electricity through integrated systems using common standards.
Each commercial transaction includes a payment to pay for products and services delivered. A well-designed payment process enables commerce to flow efficiently, both within a country’s boundaries and when crossing borders. However, in Europe currently a regime exists of 27 national payments markets, with divergent legal conditions and widely differing prices and speed of delivery. This denies EU citizens and businesses the efficiencies to be gained through a consolidated payments processing system. It obliges excessive use of cash and cheques, and sustains differences between national payment infrastructures, price and service levels. Reform will yield administrative savings and a seamless payment experience for consumers and merchants across the EU. Smaller enterprises in particular will then benefit from harmonised services as their banks import best practices from across the EU, withpayments within the EU made as easy and cheap as for cross border and those within their home country.
The European Commission and the European Central Bank have embarked on a mission to harmonise electronic payment processing in Europe based on user requirements. A substantial part of this effort is the creation of a regulatory framework. The EU commission has obtained acceptance of the Council of Ministers and the European Parliament for a comprehensive Payment Services Directive (PSD). This PSD is now in the process of transposition in national laws.
The Directive sets the legal framework for payment processing in Europe. With regards to the operational framework, a wide range of European banks are working through the European Payment Council (EPC) on implementing the Single Euro Payments Market. The EPC is the decision-making and coordination body of the European banking industry in relation to payments. The EPC finalised a set of Euro payment schemes for core euro payment services covering direct debits and credit transfers, a framework for card transactions and a framework for cash to be used by the banking industry to offer to their customers in 2008.
However, after the approval of the Payments Services Directive (PSD) and the European Payment Council (EPC) Rulebooks, a number of significant SEPA issues are still unresolved. This causes confusion amongst banks and corporations alike throughout the EU. In turn, confusion leads to corporations adopting a wait-and-see attitude.
These key issues are:
- Limited current interest of corporations in SEPA
- Risks of limited adoption due to current SEPA design
- Limited engagement of software industry
- Risks of divergence of national implementations
It is widely acknowledged that corporations have only belatedly been engaged in the design and implementation of SEPA, given that it has come at a stage where much of the technical solutions were already agreed by the EPC and implementation commenced.
At the same time the current situation is paradoxal. Just a few months away from SEPA’s January 28th 2008 deadline, corporations have four major concerns regarding the implementation of SEPA.
- Corporations still do not know what kind of services will be offered by their banks and at what price.
- Corporations do not know what changes they will have to make to their systems, organisations and procedures to adapt to these services.
- Corporations do not know when individual countries will move to SEPA and when old payment systems will be dismissed.
- Corporations do not know how internal consistency is ensured between national SEPA migration plans and how migration costs will be minimised for multinational corporations.
These uncertainties clarify why corporations have not acted upon SEPA yet in any significant way. It is very likely that the situation for public administrations is similar if not the same. Hence, these uncertainties, if unresolved, may result in a slow take-up of SEPA, which might then be perceived as a political and industry failure.
The success of SEPA is largely dependant on the uptake by the corporates, who are the “heavy users” of payments and, like the banks, face huge changes to systems and processes. As parties that are significantly affected by the change, they must have a say on how to remove the hurdles that are still in place.
It is key that the SEPA standards are mutually agreed and used between the banks and their corporate customers. SEPA needs a more formal and recognised structure providing an efficient mechanism for controlling implementation and managing future changes.
Corporations are willing to accelerate the development of industry standardisation of financial supply chains beyond payments and to adapt their organisation and procedures to the new payment services that would be a component of such broader standardisation. At the same time, however, they do not perceive themselves as working with banks on an equal footing with regards to the design and implementation of the SEPA project and having a say in decisions on mutually beneficial solutions.
In the appendix, a list is presented of 10 specific areas of concern that require attention and consequential actions. These are all serious issues that need an agreed resolution between banks and corporations if SEPA is to be a success. If a resolution can not be achieved on these issues, there is a likely risk in particular of adoption of the direct debit scheme and a likely risk of failing to deliver on end-to-end straight through processing for corporate users and public administrations.
2.2.1 Risk of limited adoption of the Direct Debit Scheme.
Although many banks are now implementing the EPC’s SEPA Credit Transfer Scheme, there is still great uncertainty over the final configuration of the Direct Debit Scheme. More specifically, it is doubtful whether in its current form it will be widely adopted by corporations.
Moreover, little discussion with corporations has taken place on the Additional Optional Services (AOS), which together with pricing of SEPA payment services are the key drivers for adoption by corporations.
2.2.2 Risk of limited End-to-End Straight-Through-Processing.
Given that the EPC has been constrained by its mandate to limit itself to the design of inter-bank payment processing, the resulting solution carries the risk that end-to-end straight through processing as corporates mean it, that is from the payer to the payee or vice-versa, is not likely to become a reality. It may very likely stop at either one of the payer’s or the payee’s bank. This again will make the SEPA much less attractive than anticipated.
For many years, the software industry has been fundamental to the success of the financial services industry. SEPA has created a very sizeable commercial opportunity for the software providers and consultancies to offer systems and advice enabling their customers to achieve SEPA compliance as well as to attract new business.
However, to maximise success, in particular the software industry needs to be engaged much more to enrich the debate on effective solutions. They are often confronted by the EPC with its solutions, without a deeper analysis on the technical as well as commercial implications for the vendor community and hence it’s corporate and bank clients. Some vendors and consultants are involved in some form or another by the EPC, but this does not mean that the very extensive community of relevant software solutions providers and consultancy organisations are timely informed and engaged. A wider group of solution providers should be encouraged to take part in working groups that are formulating technical specifications and wider audiences should be informed timely about the considerations and results.
In particular, ERP solutions providers could be key to achieve rapid take up of SEPA across the EU and deliver the benefits of full automation to corporates of any size and to public administrations as well as their banks. For example, in the past a “de facto” standard was established with SAP’s IDOC. This could be achieved again with UNIFI ISO 20022, especially if strongly backed by corporations, their industry associations, public administrations and, last but not least, the banking community.
2.4 RISKS OF DIVERGENCE OF NATIONAL IMPLEMENTATIONS
The banking sector is putting much energy and commitment in overcoming the problems and high costs of the current fragmented EU payments infrastructure whilst achieving the objectives of both the Payment Services Directive (PSD) and SEPA. Many financial institutions however view the introduction of SEPA as a compliance issue that should be implemented at lowest possible cost. This leads to doing the minimum that is necessary to comply with the new rules (e.g., adapting the national payments and reporting standards).
2.4.1 Transposition of the Payment Services Directive (PSD)
The PSD is being transposed in national laws. This is a delicate process because the PSD is deliberately flexible and leaves much room for interpretations and enough leeway to EU Member States for introducing exceptions when defining their laws or regulations.
The result of this flexibility is that on a number of important points the PSD is vague or silent. It is therefore vital that the industry keeps a close watch on how these points are translated in national laws. Different interpretations will lead to confusion in the market, possibly harming the SEPA implementation and re-creating a fragmented payments landscape as we have today.
2.4.2 Implementation of SEPA via national banking communities
Regarding implementation of the SEPA project, the ball is mainly in the camp of the national banking communities as they are drawing up SEPA National Migration Plans. However from a point of view of the end-users, this creates a loss of “visibility“ and a lack of control, which is essential to have in the migration phase.
National implementation of SEPA is a necessity but, without close central monitoring and a strong guidance, it will deliver fragmented SEPA markets.
The EACT (European Association of Corporate Treasurers) has pointed out that there are few countries where treasurers associations and other stakeholders are seriously involved in SEPA national committees. Corporates are at the sending and receiving end of the vast majority of payments. Because corporates have strict operational procedures around payment processing and use tightly tuned systems, low corporate commitment means that national migration plans will not be implemented or cause significant delays and require additional investments by the banking sector. Corporates, large as well as small, generally operate cross border, which means that they will seek internal consistency between multiple national SEPA migration plans.
At the moment, if all EU states implemented their SEPA solutions, the effect from a customer perspective would be little change from today’s landscape of local solutions and will limit SEPA both in its immediate and long term impact as a European alternative.
Therefore, the situation needs to be addressed as a matter of urgency at the political, service provider and end-user level.
This is needed to avoid internal inconsistencies that may lead to higher costs and different levels of attractiveness of national SEPA implementation plans for the users of payment services.
SEPA is an EU-wide payments industry project with clear objectives in harmonising the payments industry and bringing benefits to corporations and, by extension, to all retail banking customers.
These objectives are under threat as the finance industry has difficulty in managing collaborative projects. Indeed, too many banks see SEPA as a threat to their competitive position and view it as a compliance issue that must be met with modifications to legacy systems at minimal cost.
If this is the case, then the best possibility for advancing SEPA might be an alliance of those banks and corporations that look at SEPA as a strategic opportunity. SEPA would then be viewed and managed by an influential sub-set of players as an essential stepping stone to move to a higher technology platform enabling new value-added services, better end-to-end integration and drastic cost reductions in the processes of both banks and corporations.
If this were the case, SEPA could in fact benefit from the establishment of an alliance of influential stakeholders whereby a number of key industry participants demonstrate leadership in the successful implementation of SEPA and the specification of well-designed AOS. Best would be for such a group of aligned banks and corporate representatives to operate within the current structures. Thus, the recommendations in this paper have been directed at the EPC.
This paper is trying to draw the attention of key stakeholders of the SEPA project, including the European Commission and the European Central Bank, to the problems that exist today and is a plea for assistance to provide the payments industry with the governance tools to ensure SEPA does not fail. The approval of the PSD is welcomed as a very positive step, but its benefits will not be achieved if its transposition in national law by member states is not closely monitored centrally and if no timely attempt is made at avoiding member states from putting measures in place that conflict with the sprit and the letter of the Directive.
It is hoped that the various participants in “the payments chain” will be able to constructively co-operate with the EPC in the future. A number of specific and realistic recommendations are made in this White Paper. Once again, corporations feel that addressing the issues hampering a pan-European SEPA implementation with corporate engagement is more important than meeting the original SEPA deadline.
The EPC published its draft proposals on its governance for consultation, but only a few treasurers associations responded. Our observations are the following.
- It is strange that the same body that designs and operates the system (a legal monopoly) also regulates itself and settles disputes. Logic and prudence would dictate that an independent body (Trusted Third Party) regulates payment systems. If it is perceived to be too complicated to create an independent body, the ECB might consider adopting the role of payment system regulator.
- However, if for political and practical reasons, the EPC is left to regulate itself, the governance should ensure adequate participation by other stakeholders and absolute transparency in all internal procedures (primarily litigations, resolution of conflicts and the process of innovation). The presence of a few independent members in the EPC’s Committee that rules on disputes may not be enough to ensure equanimity of decisions. Independent members are not there to represent the interests of non-bank stakeholders but are chosen because they bring special competences. In the current proposals, their name can be proposed by anyone but they are elected by the EPC. Non-bank stakeholders would feel more represented if the independent members of the EPC’s governance were appointed by the EC and / or the ECB.
- Regarding the other vital objective of SEPA, realising change and innovation, end users can submit proposals to the EPC but are not part of the evaluation and development process. Stakeholder Forums are the only form of cooperation envisaged and experience has shown that the current approach is focusing more on broadcasting of – and consultation on – finished products rather than on joint development of solutions.
- After the successful delivery in July 2007 of a report on the issues of e-Invoicing in the EU by an informal task force, the EU Commission is planning to formally establish a Steering Committee for a European Electronic Invoicing Framework before the end of 2007. This Steering Committee will be responsible for developing and monitoring progress of an agreed strategic roadmap concerning e-Invoicing and, in future,e-Procurement in the EU. The Steering Committee will have the remit to assist the EU Commission in drafting appropriate regulatory incentives if necessary. This EEI Steering Committee is likely to consist of stakeholders from public administrations, corporations, service providers and standard organisations. Given the implications of SEPA for the success of e-Invoicing, it would be logical for the EPC to take into consideration the implications of the roadmap and other recommendations that will be made by the EEI Steering Committee.
- The EACT and TWIST are currently involved in structuring a corporate panel of 20-30 large multinational corporations that are active and very experienced in national as well as cross-border supply chain automation. This panel is intended to be a forum for evaluation, development and validation of design issues around harmonised e-identification, e-mandates, e-procurement, e-invoicing, e-tax declaration and e-payments in the EU, linking into the anticipated activities of the EU Commission’s EEI Steering Committee. The same corporate panel could also be engaged by the EPC with regards to the SEPA designs and implementation plan.
There are many unresolved issues concerning the agreed use of ISO 20022 and the implementation of specific fields within the message standards. There is also a need to agree the used of XML between corporations and their banks. Many of these problems can be resolved by a concerted effort of all parties.
Corporations and ERP vendors should support the UNIFI ISO 20022 standard in its original and formally published version and put pressure on banks to offer payment initiation and reporting services based on the new XML standards. EU authorities should facilitate the effort and give the market a clear message in this direction. The market can then produce a market practice process that begins to bring together standards and will eventually fuel adoption. There is no need to develop new technology for SEPA as there are already many good off-the-shelf solutions. Firms wishing to develop their own systems will face inevitable delays in meeting SEPA deadlines.
TWIST and the EACT’s CAST projects are cross-industry initiatives that include corporations, banks, ICT suppliers. They identify requirements and deliver detailed “best practices” designs, based on the participants with significant experience in financial supply chain dematerialisation. They have the potential to mobilise the industry for ISO 20222 and XML, cooperate with the banking industry to develop new value-added services, organise and monitor pilots, help introduce the new standards, communicate benefits to the wider audience of treasurers associations and stakeholders representative organisations.
SWIFT can be an important agent in SEPA’s successful implementation because of its competence and deep involvement with the EPC and the banking industry. The only reservation about SWIFT is its governance, possibly limiting the extent to which SWIFT can cooperate with corporations on new standards and open solutions.
The European Association of Corporate Treasurers (EACT) has raised issues on SEPA during numerous meetings with other stakeholders and has held consultations with various European authorities. Notwithstanding those efforts, the EACT is concerned that the banks and the EPC are only focusing on meeting their self-defined deadlines for the SEPA project and postpone any serious discussion on the issues raised.
Whereas it is of course recognised that the financial industry is under huge pressure to implement SEPA, it should also be accepted that the EACT’s request to establish “mixed” working groups will produce better result than the current “banks-only” approach.
Furthermore, SEPA is suffering an implementation delay because of the PSD, disagreements over direct debits and other unresolved issues. This delay is not necessarily “unhealthy” and indeed provides an excellent opportunity to “pause and regroup” and start a different type of cooperation between banks and other stakeholders.
This pause for reflection should be used to create the much needed proper governance model, to resolve any unsettled issues, eliminate uncertainties and launch a credible implementation plan which includes the changes and the AOS that are considered necessary for the acceptance of SEPA.
The commitment of corporations and other stakeholders is vital for the success of SEPA. This commitment is not there today and will not emerge if banks, corporations and the EU authorities don’t succeed in establishing “real cooperation” on the issues and a “modus operandi” which involves banks and corporations together in a meaningful way.
Corporations don’t expect that all their requests will be accepted and executed in a short period of time like in the original SEPA Master Plan (2008-2010). It is much more important for corporations to see that their requests are taken seriously: that they are discussed and “filtered” at a “European level”, that they are compared with alternative solutions and that decisions are made in a democratic and transparent way, with input from all interested parties.
In the absence of such a collaborative process at the European level, it is likely that individual banking communities as well as corporate communities will resist switching to SEPA products and/or develop community-specific AOS.
Unless compliance, change and innovation are governed at a “European level”, the risk is substantial that there will not be a single Euro payments area but a series of national SEPA-compliant systems. However, those different national systems would then have to be made interoperable, which, in turn, would require additional complexity and cost. That prospect does not encourage corporations to invest in SEPA.
This White Paper recognises that the financial services industry has to meet its challenges in running the inter-bank payments infrastructure and does not dispute in any way how the industry manages the issues of a pan-European inter-bank infrastructure. Instead, this paper puts forward the expectation of corporations to be involved in the shaping of the payments schemes and the banking services that are based on their requests. A concrete example of this expectation is that standardisation be carried out end-to-end from the payer’s operational processes and systems to the payee’s operational processes and systems and not be confined to the bank-to-bank domain only.
The resolution of issues around SEPA at a pan-European level should not hamper those banks and corporations that would like to progress with SEPA-based implementations. For these parties it will be important to ensure that early implementations are in line with what can be expected to be the outcome of further discussions between banks and stakeholders with regards to end-to-end designs for payment services.
To facilitate these parties to continue their path towards SEPA implementation, the EACT and TWIST collaborated with B.I.S.S. Research in producing a template to benchmark the functionality of SEPA service offerings and system designs from a corporate requirements point of view. The template will allow firms to assess whether their SEPA offerings are aligned with the corporate requirements and detailed specifications underlying the TWIST standards and the ISO 20022 message range used in the SEPA rulebooks developed by the EPC. There are two benchmark templates, one is for Banks wishing to test in-house developments and third party vendors and the second for software vendors anxious to prove their systems functionality. These templates can be found on the websites of TWIST (www.TWISTstandards.org) and B.I.S.S. Research (ww.bissresearch.com).
To help reach the objectives of SEPA and to ensure widespread adoption, leading banks and corporates should encourage the EPC, and where applicable the EU Commission and ECB, to adopt he following 6 general recommendations:
- Corporate Representation
A “Panel of 20-30 corporates” who are “best of practice” in payments and supply chain dematerialisation and who are committed to adopting XML-based standards should be created by the EACT and TWIST to support the action of the EC’s future EEI Steering Committee and to be consulted by the EPC on technical questions and validation of proposed standards.
- Engagement EPC with users of payment services
The EPC should reconsider its engagement with stakeholders and the appointment of stakeholder representatives. It should take note of the activities of the EU Commission’s Task Force on e-Invoicing and could seek engagement with the corporations and corporate representatives that are increasingly playing an active role in reviewing and supporting the development of standardised solutions for supply chain automation.
- Engagement EPC with software industry
The software industry should be more actively engaged in SEPA and encouraged to fully adopt the standard designs agreed between banks and their stakeholders for SEPA. To be effective and ensure a healthy open market for software vendors that may benefit significantly from the changes triggered by SEPA, they should have timely access to information on all facets of SEPA so as to prevent concentration of knowledge leading to competitive imbalances.
- Transposition of Payment Services Directive
The Payment Services Directive (PSD) will be implemented by the Ministries of Finance with the support of banking associations and central banks. End-user associations, particularly of corporations, should seek to be consulted to support the process.
The process of transposition needs to be watched very closely by the European Commission (EC) and the European Central Bank (ECB) with support from the EPC to make sure no situations are created that are inconsistent with the objectives of the PSD and SEPA and provide barriers for cross-border interoperability.
It should further be encouraged that translations of the transposition into national law are provided in the main languages of the EU, i.e. English, French and German, at the websites of EPC, EACT and TWIST and others that can reach a wider audience interested in SEPA.
- Monitoring of SEPA national implementation plans
A strict monitoring and a comparison of SEPA national plans should be done urgently by the EPC and / or the ECB with the EC, together with representatives of stakeholders, before they are implemented by national banking communities.
- Standardisation of customer-to-bank and bank-to-customer process
Careful consideration should also be given by EC, ECB and EPC to more standardisation in the Customer-to Bank (C2B) and Bank to Customer (B2C) space and to extend their reach to the Business-to-Business (B2B) and Business-to-Government (B2G) spaces which lie beyond theSEPA-related issues which are specifically targeted by this paper.
The success of SEPA and its ultimate objectives are in doubt because there is no standards basis yet for end-to-end straight-through-processing and because the current process for defining and implementing SEPA products is sub-optimal.
Furthermore, with the implementation of SEPA being left to the national banking communities, there is a loss of SEPA visibility and a perceived lack of direction and leadership. To correct this situation not only the general measures listed before need to be taken, but also the following set of 10 specific issues needs to be addressed. These issues are presented in detail in the appendix of this paper.
- End-to-end Straight Through Processing (“true STP”) with SEPA
The ISO 20022 data model in its original design for the instruction of credit transfers and the receipt of remittance information and bank statements needs to be enforced as a payments industry standard for Corporate to Bank, Bank to Corporate, Public Administration to Bank and Bank to Public Administration within SEPA.
- The need for focus on end-to-end security
The efforts of the EU Commission regarding cross border e-identification, e-procurement and e-invoicing should be taken into consideration for SEPA with regards to adopting best practices for issues such as identification, authentication, guaranteed delivery and non-repudiation of the ISO 20022 messages between corporates and public administrations and their banks.
- SEPA Direct Debit scheme
The EPC should engage with corporate representatives and with other stakeholders to discuss the current diversity in direct debit schemes and define an action plan to further improve the CMF scheme, re-consider incorporation of a DMF scheme and / or develop complementary but commonly defined Additional Optional Services for direct debit mandate management.
- Migration / Renewal of existing Direct Debit mandates
The Ministries of Finance, Central Banks and / or Banking Associations that are charged with drafting the disposition of the PSD for their country should collaborate in defining a single and where possible simple solution for de validity of existing direct debit mandates within the EU.
- Bank account identifier: IBAN + BIC
The EPC should develop solutions in consultation with corporate stakeholders that removes the BIC as part of the bank account identifier. The EPC should further develop solutions that enable a low-impact and secure migration of corporations from existing account identifiers to IBANs.
- Unique Entity Identifier (UEI)
The EPC should collaborate with the EEI Steering Committee in specifying and propagating a Unique Entity Identifier, that can be used for e-procurement, e-invoicing as well as e-payments under SEPA.
- Additional Optional Services (AOS)
The EPC should be the focal point for validation of Additional Optional Services in much the same way as the validation of the ISO 20022 standard, and should be tasked with identifying and propagating the complementarity of these AOS to the existing EPC schemes.
- Balance of Payments Reporting
The ECB and EPC should create a stakeholder group of experts that proposes a standard for Balance of Payment Reporting. The ECB and EPC should then broker the adoption of a standard by the various departments in Member States that obtain BOP reports.
- Multilateral Interchange Fees
The EC should take a clear position whether the multilateral interchange fees that are defined within the banking community are distorting competition and should be abolished or whether such fees should be allowed provided they are determined with full transparency.
- Pricing of SEPA Products
A general statement on SEPA pricing by the EC and ECB should give banks the direction they obviously need. If established in this manner, this principle would be difficult for banks to ignore in negotiations with their clients, and it would have a very beneficial effect on the implementation of SEPA.
This section lists 10 specific areas of concern that require attention and consequential actions. These are all serious issues that need an agreed resolution between banks and corporations if SEPA is to be a success. If a resolution can not be achieved before January 2008, starting a serious and engaging dialogue between the banking community and corporate community now should still bear fruit for SEPA in the medium and longer term.
The key benefit of SEPA for corporate users of payment services is assumed to be true end-to-end straight through processing for corporates (STP). The banking community stresses this topic, given their understandable desire to entice corporate clients and public authorities with the potentially large savings expected from efficiencies in business-to-business and business-to-government
by “STP-ing” of supply chains. Banks intend to position SEPA as a supply-chain-automation facilitator, a selling point to trigger the necessary changes by corporate customers and relieve the pressure from customers on the pricing of payment services post-SEPA. However, at this stage, it can be stated that the activities of national banking communities and the details in the designs for SEPA do not deliver to corporates and public administrations what is needed to achieve this primary objective of SEPA: “real end-to-end STP”.
The EPC Rulebooks focus only on full standardisation of the inter-bank processing of payments. The data model for SEPA has been developed by SWIFT’s standards department based on the UNIFI ISO 20022 standard. This data model does not fully equal the ISO 20022 standard that had been developed in collaboration between IFX, OAGi, SWIFT and TWIST. A notable difference is the treatment of remittance information. The SEPA variant restricts to 140 characters the amount of characters that can be delivered via the internal banking infrastructure from payer to payee. The generic recommendation by the EPC that banks adopt the ISO 20022 standard for the Payment initiation and Reporting phases has gone unheeded. No standard guidelines have been provided for ensuring that all relevant information is delivered to the payee – either via the banking structure or in parallel – in a structured and predictable manner. This leads to uncertainty with corporates and public administrations as to their ability with SEPA to realise full reconciliation of their accounts receivable for any payment received within the SEPA region, irrespective of the bank used by the payer and irrespective of the bank used by the payee.
Some banks may wish to deliver the full remittance information to their customers and might find ways to do so, at least for a subset of the payments they process. Yet the approach by the EPC results in practical restrictions for corporations to make use of such services, with their existing ICT infrastructure. This is the case, even if the existing systems would be “upgraded for SEPA” by their vendors as currently planned for. As an example, SAP has stated that it does not support the complete ISO 20022 design for payment initiation but only the reduced SEPA subset.
The EACT was asked by the EPC to structure the 140 chars space and presented a draft design. At the same time, it refused to lend its name formally to a proposal that is only focused on the the interbank space. The EACT repeatedly asked that the whole payment chain be discussed to make sure banks and software vendors had clear guidelines to provide a common interface and reporting format rather than many national solutions like the situation within Europe today .
Discussion has been going on with SAP, SWIFT and the EPC for some time. But at this time there is for instance still no clarity as to what SAP will do regarding their needed full support of the ISO 20022 standard both for payment initiation and the bank statement used in payment reconciliation
The EPC does recommend to use the SEPA version of the ISO 20022 standard between banks and corporations. In spite of the flaw just mentioned, the EPC’s effort to effectively propagate the use of XML between corporates and banks and to use the unambiguous data structure as developed under ISO 20022 standard for C2B (payment initiation) and B2C (bank statement) is a very important step towards low-cost end-to-end supply chain automation. Unfortunately however, the national banking communities are apparently not adopting this recommendation. This is with the exception of a few individual banks that will accept / generate ISO 20022 XML messages. A notable exception is further the banking association of Italy, which in the new version of its CBI solution will adopt only ISO XML formats. Elsewhere banking communities are adapting their domestic standards for Corporate to Bank payment instructions to support SEPA data and PSD transparency requirements.
The result would be for a company or public administration that operates cross border in the EU that it must invest to change its current multiple bank interfaces that are based on national standards. After that investment, which would be a multiple of a single investment in a standardised SEPA interface, the corporate would still have multiple bank interfaces to maintain, often based on older EDI-based technology and without the guarantee for full reconciliation of any payment sent or paid within the SEPA area. This is not what SEPA should mean!
These different approaches per Member State for banks receiving credit transfer instructions from their customers and for delivering bank statements to their customers lead to a very limited desire by software vendors to invest in the necessary changes to their software products. New different versions of software to be used in every country will represent for EU multinationals a significant higher cost than that of a single EU-wide standard. Even if national communities could motivate software vendors to deliver national SEPA versions, these software vendors might not have the resources available to make the necessary changes. These vendors may as a result also charge higher sums for SEPA roll-out based on such multiple national standards than a single-standard based roll-out, given that such charges are not only based on development costs, but also on the expected size of the market for such SEPA adjustments to their applications.
On the B2C front, which is crucial for reconciliation purposes and, as such, the most important component for reaching end-to-end STP benefits, banks generate the bank statement out of their own applications. They should all adapt to the standard bank interface as designed under ISO 20022. ERP software vendors serving corporates should update the reconciliation procedures in their software to be able to receive and process the ISO 20022 standard information. . Any other format should be considered non-standard and entail customisations and additional costs.
The current focus of SEPA is primarily inter-bank and then to a limited extent bank-to-client or client-to-bank. From a corporate and public administration point of view, “True STP” means from seller to buyer and vice versa, via all intermediaries involved in the whole supply chain.
A “single euro payment area” only bears its meaning if and only if the finality of payments can be guaranteed from end-to-end, again from the buyer to the seller. This involves more than a structured data model and covers issues such as guaranteed delivery of instructions and / or information, identification and authentication of individual users, plus non-repudiation of instructions and / or of information delivered.
Between business partners, there are different options under which guarantees can be provided around messaging. They may range from so-called “legal compliance” to ad-hoc contracts where trade partners agree about the elements to be provided for “tracing” the transactions (traceability).
In any case e-business services will be trusted if they rely on trusted cross-domain and cross- border identity infrastructures. A few exist in closed circles. The challenge is to find the right balance between simplicity, openness and traceability on the Web. This is what TWIST has been trying to specify from a business perspective and is part of the EACT CAST projects dealing with such issues like electronic signatures.
A part of the banking community has put considerable efforts into e-invoicing as a banking service to large but more importantly small corporate customers. It is expected by these banks that the offering of e-invoicing services would enhance their business case for making the investments for SEPA. Where payees may benefit from SEPA to automate their accounts receivables processing, payers may benefit in their accounts payables processing from e-invoicing across the EU. The exchange of structured information between invoicer, invoicee, payer and payee would significantly support the supply chain automation between corporations and between corporations and public administrations. An EC informal task force on a European e-Invoicing Framework has resulted in the accelerated collaboration of multiple standard organisations, which should lead to an extension of the ISO 20022 design to e-invoicing and possibly e-procurement. If banks desire to deliver e-invoicing services to their customers, the need for consistency between ISO 20022 based invoicing and ISO 20022 based payments is obvious. But also for corporates that implement e-invoicing solutions with non-bank solutions, there will be a strong demand for their implementations of e-invoicing to be fully consistent with their SEPA implementation and vice versa. This development strengthens the point made earlier that customer-to-bank implementations of SEPA should be based in detail on the ISO 20022 designs.
As explained before, end-to-end STP depends on issues of security as much as standardisation of data formats. The EC informal task force on a European e-Invoicing Framework has identified key issues and bottlenecks regarding trust and operational risks around electronic messaging. The related recommendations are presented in the task force’s final report that was published in July 2007. The recommendations will be followed up the formal EU EEI Steering Committee that will be established before the end of 2007 ,as mentioned earlier in the White Paper. The recommendations themselves are already worked on by multiple standardisation groups and gatherings between for instance corporations and fiscal auditors. The EACT and TWIST are both actively involved in these efforts, using the output of EACT’s CAST and TWIST’s Financial Supply Chain Working Group and Bank Mandate Working Group as a useful basis. Given the need for internal consistency between the invoicing and payment processes and given the importance of delivering e-invoicing services for a significant part of the banking community in Europe, it is important that the implementation of SEPA by banks and corporations be consistent with the best practices developed under the EU e-Invoicing Framework.
The Payment Services Directive (PSD) provides a regulatory framework for cross border processing of direct debits. The PSD will require changes to practices in a number of Member States. One example is the introduction of an eight-week period to revoke a transaction, a period that differs from the current situation in many Member States and a measure that by itself requires adjustments to the role of the creditor and its controls over the process of receiving funds via direct debits.
Lawyers commissioned by the banking sector are currently considering the implications of the PSD for the rulebooks developed by the EPC. But whatever the outcome of their review, at the moment the design of the direct debit product is SEPA’s major stumbling block. A number of national banking communities are reluctant to adopt the basic SEPA CMF (Creditor Mandate Flow) scheme where the debtor signs the direct debit mandate , the creditor authenticates the issuer of the mandate and maintains proof of authentication for legal purposes. In many Member States, this role is new for the creditor (i.e. the corporate bank client) and represents a significant change to current practices.
Some national banking communities and corporate representatives in the EACT consider the current CMF scheme insufficient with regards to securing certainty of the “finality” of collection. The EACT found a basis of consensus for a reinforced CMF scheme (CMF+) which could be given wider attention.If the CMF scheme that is formally approved by the EPC is not adjusted, there will be the risk that direct debits will continue to be done within the current national schemes, which would result in limitations in cross-EU harmonisation.
A number of countries (such as Italy, Spain, Portugal and the Nordic countries), would also have liked for the EPC to adopt a DMF (Debtor Mandate Flow) option as part of the same direct debit scheme plus a separate model for dealing with mandates. In this DMF option, debtor banks could receive and store the original electronic or paper mandate of the debtor to the creditor. Within this solution, bank details and other debtor information can be validated by the debtor bank and by the corporate creditor, providing more security to the debtor and certainty of collection to the creditor. The EPC has decided it will not change the core CMF scheme of Rulebook Version 2.2, which banks have already implemented in software applications. It does not plan to incorporate the DMF scheme in the existing CMF scheme. The EPC is willing to accept DMF as a value added service. A separate, optional, electronic mandate scheme is now under development which intermediates debtor banks in the mandate flow.
At the EPC’s June 2007 Plenary, the proposed E-Mandate model was approved for submission. The EACT’s position is that whereas the E-Mandate model could meet the requirements for a stronger CMF (CMF +), it also still leaves a number of issues unresolved like the treatment of old and new paper mandates, the optional nature of the model for the banks and the lack of a DMF option for corporate customers, where as mentioned the debtor banks receive and store the original paper mandates.
The details of the E-Mandate model still have to be worked out in the next phase and a number of issues (e.g., legal issues) must still be verified. It seems however that the EPC is prepared to engage with the stakeholders in tackling these issues together before the design of the model is finalised.
To support the process and possibly assist in unlocking the unresolved issues, the EACT is gathering information from the corporates of various countries on the volumes of B2C and B2B DMF mandates, on the relevant legislation, corporate practices and banking conventions.
To address this need for more information, the EACT has distributed a questionnaire to NTA’s and to a number of European corporations that use Direct Debits. Once all the information from the corporations has been received, it will be possible to invite banks and their stakeholders to a meeting with the objective to define possible actions and / or plan the development of common Additional Optional Services.
Informal discussions with the EPC have indicated that the e-mandate scheme could be extended to include dematerialisation of old and new paper mandates, provided the banks are ready to offer such a service. Currently, this extension is out of scope. Corporate insistence on the matter could lead to EPC support for a resolution.
From a legal point of view, the PSD does not make mention of anything related to the migration of current direct debit practices to the new practices and as such does not mention the issue of re-signing mandates for direct debits. As a result this is left to each individual Member State to resolve this difficult issue. In the transposition of the PSD into national legislation, some countries like Italy will probably pass a one-line article stating that the existing direct debit mandates maintain their validity in SEPA i.e. debtor banks will continue to accept direct debits on its account from a specific creditor provided that the existing contracts do not contain any clauses that are in contrast with the PSD.
This Italian example should be followed by other Member States, avoiding the almost intolerable burden of issuing and signing new mandates for existing commercial relationships. Yet as an example, Germany is understood to be orientated towards a re-signing of old mandates. If the issue of migrating the old direct debit practices to the new situation is not dealt with in a harmonised manner, the end-result will be that some countries will require renewals and others not. This would not only lead to confusion but also to a large and unevenly distributed burden of SEPA implementation within the EU.
Even at this late stage, every NTA should be lobbying its government, Ministry of Finance, Central Bank, Banking Association or whoever is charged with drafting the transposition of the PSD. Again, the lack of central planning of the SEPA implementation is a severe impediment to successful execution.
Harmonisation of payment services and hence the success of SEPA depends on common mechanisms for identifying customer accounts and routing payment information. The EPC has decided to implement IBANs + BIC for all payments processed in the EU under the SEPA scheme. This is a major issue for the whole payments industry. Although the combination of the IBAN+BIC as the single account identifier is preferred by many banks, it is not a simple solution to be implemented. In addition, IBAN and BIC on their own as well as in combination with each other have been long debated by the financial industry and by corporate representatives. The decision by the EPC has been taken without agreement with corporate stakeholders and is not accompanied by an agreed resolution with regards to the issues that surround IBAN + BIC implementation.
Collecting multiple millions of IBANs from clients’ suppliers and employees is a nightmare for all corporations. Banking communities could devise standardised solutions to allow a file transfer of IBANs from banks to corporations under an agreed format and surrounded by the necessary controls to avoid erroneous payments. This type of solution is under consideration in some EU Member States, but should be available to corporates in all countries.
The use of BIC as part of the identifier holds a different problem for corporations. Corporations should not be forced to acquire and store BICs in their ERPs to facilitate banks in their routing of payment instructions. The inclusion of BICs also ties the bank account identifier to the relationship / registration of the beneficiary bank with the SWIFT payment network. Where the lack of portability of bank account identifiers is already a negative point of the current IBAN design, corporates should not be affected by another non-portable identifier that represents the relationship between banks and a network provider. The individual relationship between banks and SWIFT could change over time. In that situation, corporates should not be requested to change the BIC in the BIC + IBAN for their bank account identification as a result of a commercial decision of their bank with one of its suppliers.
A solution would be that Banks could automatically apply the BIC in their payment applications based on the IBAN of the payment order and a look-up table for the routing address of the beneficiary bank.
BIC + IBAN serves for bank account identification. In addition, the creation of a unique code identifying each corporate and each individual, which can be used in every electronic transaction, should be a goal of the payments industry. With the massive increase in on-line banking at an individual and corporate level this is becoming a pressing requirement .
The need for an international electronic identifier was recognised long time ago by the banks that adopted the BIC. For corporations the problem is more complex as there is no organisation like SWIFT that centrally issues identifier codes and operates a widely used secure network.
Italy has chosen the Tax ID for identification purposes and has made it freely accessible through a public database. Other EU states however, may choose a different UEI. An international standard should be developed and its application and accessibility mandated.
The use of the UEI would give enormous benefits in terms of simplification of internal procedures (e-certificates, e-reconciliation) and the security of transactions. The EACT has long advocated a UEI for corporates and, on many occasions, asked for a working group to decide a standard. In a “SEPA stakeholders meeting” organised earlier this year by the ECB, both BEUC (representing consumers) and UAPME (representing SMEs) came out strongly in favour of the EACT proposal and the need of a UEI to provide more protection / control on debits / credits to bank accounts.
The European Payments Council was asked by the European Central Bank to review if a more simple IBAN structure could be made available for corporates, public administrations and consumers. The EPC accepted to analyse / review the options with the remark that the identifiers of legal entities and of private persons are also part of the public sector.
In the meantime, the public sector initiated the BRITE project (Business Register Interoperability Throughout Europe), which is a EU project that aims to develop, implement and demonstrate an advanced, innovative interoperability model, ICT service platform and management instrument for Business Registers (BRs) to interact across the EU. BRITE aims to address cross-border Business Register interoperability at all levels: abstract, organisational, technical, legal, strategic and managerial. The project is co-ordinated by The European Business Register, which is a network of business registers kept by the registration authorities in most of the European countries. Their BRITE project aims to address interoperability across ‘domains’, i.e. interoperability between the BRs and the public agencies that operate in the selected sub-domains of e-Government.
In the July 2007 report on the issues of e-Invoicing by the EU Commission e-Invoicing Task Force, it is recommended that the EPC collaborates with the BRITE project and with CEN to ensure consistency and alignment in developing and propagating “good practices” in e-invoicing. Whereas the EPC does not focus itself on e-invoicing, a collaborative effort on the specification of a cross-domain Unique Entity Identifier could ensure that such a UEI could be used for e-procurement, e-invoicing as well as e-payments. The EU Commission plans to co-ordinate such an effort by the establishment of the aforementioned EEI Steering Committee.
SEPA will struggle to achieve its objectives until improvements are made to existing Rulebooks and additional instruments are recognised and standardised across the board, based on the SEPA XML format as defined under UNIFI ISO 20022.
The banking communities in Italy, Spain, France and Portugal are studying national AOS for the same instrument (e.g. Riba, Lcr, Recibos, all “non pre-authorised direct debit instruments”).
Instead of developing national versions of AOS, these countries should unite and present only one multi-community AOS, that banking communities in other countries or other individual banks can use if they want. Such collaboration would enhance predictability and clarity and would at least produce momentum towards a EU-wide solution.
The NTAs can put pressure on their banks , especially in countries like France, Italy, and the UK, where they directly engage with banking associations or government bodies in SEPA Migration Plans. This engagement however has started at a dangerously late stage to achieve successful SEPA implementation.
There is still much uncertainty about what constitutes an acceptable AOS. Specific proposals would clarify this point for everyone affected by SEPA. A mapping of the desired instruments to the existing Rulebook is required, using the same format and data sets, showing differences and similarities, and identifying additional data fields where required.
The EPC has decided not to play a proactive role in the area of AOS (arbiter or filter). This however creates a situation where there is no central point of information and coordination.
This vacuum must be filled in order to avoid that AOS proliferate out of control.
The issue of Balance of Payment (BOP) Reporting is a recurrent issue. Many times the ECB and the EC have advocated the elimination of BOP Reporting in its current form, and the introduction of more standardisation among countries and a solution that would facilitate STP. However, this has not yet happened.
9: Multilateral Interchange Fees ( MIF )
Multilateral Interchange Fees (MIF) are considered a problem by merchants for the use of card-based payment services. Such fees are also an issue for payments in a four-corner model, where payer and payee use different banks for their respective instruction and receipt of payments.
The MIF are also a matter for discussion in the processing of Direct Debits and of other payments that share a common inter-bank platform. Under the SEPA schemes, corporates are not enabled to choose the inter-bank platform that will be used by their banks.
No serious discussions on MIF have been held between corporate representatives and banks at the European level. In some countries these discussions do take place. For example in Italy this happened when MIFs were set unilaterally by the banks at a very high level. Since this type of price fixing represents an exception to the Italian laws on competition, the banks in Italy must be granted by the authorities a special renewable permission. On the occasion of the latest renewal, the Italian ACT, AITI, and the Italian Industry Association, Confindustria, took exception and asked the Italian Authority of Competition not to renew the convention automatically without a proper investigation on the method used to fix the MIF and the level of the fees. The result of the dispute was that the Italian Banking Association, ABI, substantially reduced the MIF. Yet AITI and Confindustria did not obtain the clarification they asked for. An interesting fact in this discussion was that large Italian Direct Debit issuers were not necessarily against the concept of MIF. They perceived MIF as a practical way to facilitate price negotiations with banks, provided the calculation was based solely on costs of transmission and of inter-bank platforms and would not include internal costs of the banks and of any services that were not requested. The background for this is that in a “shared” type of environment the debtor banks may charge their internal costs to their clients. Yet the creditor may, based on commercial considerations, negotiate with his creditor banks an all-in fee for the collection service, inclusive of fees that should be paid by the debtor to his bank. Here the transparent MIF would enable such creditors to agree deals with its banks for collection of funds via Direct Debit, leaving the debtor to pay the internal costs of the debiting bank.
The pricing of SEPA products is one of the greatest uncertainties holding back corporations from a commitment to adopting SEPA and is indicative of a lack of communication by banks with their corporate customers.
The pricing of SEPA products that banks will offer from January 28th 2008 is a well-guarded secret. It is hard to understand why, when the corporations need this information as part of their decision making process with respect to the implementation of SEPA. This unnecessary impediment may very well have been caused by competitive pressure.
There does seem to be a trend however towards “à la carte” pricing, with a minimum base service and everything else being considered an extra (AOS).
As mentioned earlier, it is not clear yet what will be covered by these AOS. It is further obvious that corporations are not likely to invest in SEPA and then accept to pay more for SEPA-enabled services delivered by banks. The sum of “basic SEPA services” + AOS + the investment of SEPA implementation should not exceed the cost of current payment services as long as the value added of the SEPA implementations for corporates is not clear and hence can not be quantified by individual corporate users. This should be a basic principle and objective of SEPA: the EC and ECB should clearly state that “SEPA payment services should be at least equal to existing payment services in quality and should not cost more for the same level of service”.
Pricing is a competitive issue for banks but must also be within the specifications of PSD. Although the EC does not like to interfere in commercial pricing, it did intervene on cross-border payments with Regulation 2560 /2001 (“ […] must not cost more than domestic […]”). The PSD further mandates that a minimum set of information should be given free of charge.
The solution should not call for a legislative act. The desire of competitiveness in the roll-out of SEPA-enabled products is a key requirement. But the size of the task in rolling out SEPA is enormous. A rapid roll-out of SEPA is of paramount importance to individual banks, large and small, given the cost of maintaining multiple payment services and the implications of a network-based industry. Within this context, we feel the EC and the ECB should make some pronouncement on SEPA pricing calling for voluntary constraint by the banks, in particular where the costs of migrating from one bank to another bank are high for individual customers due to the lack of portability of bank relationships, before and after SEPA.
The EACT (European Associations of Corporate Treasurers) is a non-profit organization, incorporated under French Law with its headquarters located at 20 Rue d’Athènes F-75009 Paris. The EACT includes the National Treasurers Associations in 16 European countries, representing almost 7,000 members in 4,000 corporations.
The EACT’s purpose is:
- to develop and strengthen relations with European Authorities and institutions
- to share experiences, express common points of views, undertake joint actions on financial and treasury matters as well as relationships with financial partners
- to carry out and publish common surveys and working papers
With the advent of the SEPA, one of the EACT’s most important tasks, working with the National Treasurers Associations (NTA’s), has become the elaboration and expression of EU corporates’ requirements of in the payment and financial supply chain areas, participation in the standardisation process and representation of corporates’ position vis-à-vis the European Authorities and institutions. The representative function of the EACT is acknowledged by the European Commission (“EC”), the European Central Bank (“ECB”) and the European Payments Council (“EPC”).
For more information, please contact:
Coordinator of EACT Payment Commission
+39 (335) 255 401
The Transaction Workflow Innovation Standards Team (TWIST) is a not-for-profit industry group of corporate treasurers, fund managers, banks, system suppliers, electronic trading platforms, market infrastructures and professional services firms.
The primary aim of TWIST is to develop new and rationalise existing XML standards that connect the financial and physical supply chains, releasing the enormous value locked up in disjointed paper-based processes.
TWIST has developed standards covering payments and cash management, financial supply chain (ordering, e-invoicing and financing), billing of bank services, opening and administration of bank accounts and wholesale financial market transaction processing, all with identity management and security. TWIST also participates in the management of the ISO 20022 standards for financial markets aiming to make this the umbrella for its comprehensive suite of standards.
TWIST published in May 2006 another White Paper named “Realising SEPA Benefits – Corporate Requirements and Key Elements of the Business Solution”. This White Paper provides a more detailed background on the EU Single Market in Payments and the corporate requirements, of which key bottlenecks are presented here. See www.TWISTstandards.org
For more information, please contact:
Brand & Communications Manager
+44 70 1718 9478
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