1.
Background
Government has been trying to bring in different techniques
of better cash flow and treasury management. Public Financial Management System
was developed as a tool to achieve this objective apart from other goals set
for the same. Government of India has made consistent efforts for complete
implementation of PFMS in all its schemes both; Central Sector as well as
Centrally Sponsored Schemes. All agencies operating government schemes
are expected to be registered on PFMS with their dedicated bank account meant
for the transactions of government business of the concerned scheme. Data of
the unspent balances for the registered agencies is available on the PFMS
system. Though are gaps in data and it may not be termed as comprehensive, it
indicates that a huge amount of funds is lying in the bank accounts. There may
further balance lying in term deposits and bank accounts not registered in
PFMS. Further, there are accounts with bank balances, which are not in the
radar of even the senior state officials. These funds may be brought back to
the treasury account and put to better use. The country is already facing
recourse crunch and such idle funds not getting leveraged is very disappointing
and reflects poorly on the financial management. All efforts need to be made to
identify idle funds, bring back to the treasury of concerned government and use
it most effective manner.
2.
Objective
To ascertain the gravity of the matter and find back accounts
as well as idle funds resting with them, a study was conducted
in Ghazipur, Uttar Pradesh. This study is aimed to identify the accounts,
suggest methods of getting the idle accounts closed by suitably withdrawing
funds from there and suggest process through which funds are to be moved to State
Treasury and Government of India accounts. It has focused on Government
Accounts in Public Sector Banks related to various State and
Central schemes.
3.
Methodology
Ghazipur, UP was chosen as pilot district being one of the
backward districts of the country and may be considered as it is a reasonably
representative district for rural India. State government officers were
contacted and briefed about the objective. District Magistrate and all
concerned District officials of Ghazipur and the respective bank
representatives were interviewed regarding the status of the government
accounts and the related issues. State officials were requested to provide
information on the Government Accounts related to various State and Central
Schemes in Ghazipur. Every district in India has a Lead Bank Manager (LDM)
to coordinate the banking operation of the public sector banks in the district.
LDM of the district was requested to get the list of all government bank
accounts maintained by the banks. All departments were also asked to confirm
the bank accounts maintained as per their records. All bank
accounts registered in PFMS were also extracted through reports
available in PFMS. Banks also maintain central subsidy sundry account and state
subsidy sundry accounts. Banks were approached to confirm any government funds
lying there in these accounts and common sundry account maintained by the
banks.
4.
Process
State and district level officers were requested to follow a
systematic approach to identify the accounts, agencies and idle funds under
different schemes. Status of agencies handling government schemes/programs in
Ghazipur was identified and scheme-wise bank accounts were
listed. Reports as per PFMS were generated consisting of agency details, bank
accounts and funds lying in them as per PFMS were prepared. The list was shared
with the State and agencies and accounts were validated. The state was
requested to provide further information related to Government Accounts of
various State and central schemes implemented in the districts (Proforma A).
Chief
Development Officer (CDO) is in charge of the development schemes in the
District. He was requested to prepare the list of all the departments (as per
Proforma B) and the list of concerned officers (as per Proforma C) and share it
with LDM. All the officers in charge of respective schemes were informed and
requested to provide the details. A list of closed and currently active schemes
implemented in the district (as per Proforma D) with the respective bank
accounts was prepared and shared with LDM. Based on the inputs from the scheme
in charge and banks in the district, LDM prepared the department-wise
government accounts. These accounts were checked and confirmed by the scheme in
charge and gaps were filled. Headquarters or regional offices of the banks
concerned were requested to confirm the details provided by the local branch in
Ghazipur.
Out of the list of accounts, dormant and
inactive accounts were identified and confirmed. All identified bank accounts
had some balances and these balances were confirmed along with the Government
Sundry account balances and any other sundry balances lying with the concerned bank.
In the process, it emerged that amounts are lying in the sundry accounts of the
banks also. Further, there were accounts which were closed but still reflected
as active in the records. Similarly, there were accounts which are inactive or
dormant for a long time and there is no transaction taking place from them.
Sundry account balances were confirmed from the regional headquarters of the
bank concerned.
5.
Analysis and Observations
Through the
efforts of the banks and the state officials, bank accounts dealing with
government transactions were identified.
- There
were 1850 accounts with the balance of Rs.2.83 billion identified
which are related to various State and
Central schemes implemented in Ghazipur (Bank-wise summary
is attached as Annex 1).
- Out
of 1850 accounts, 1442 accounts with a balance of Rs.943.5 million are
related to Central Schemes. Further analysis showed that 8 accounts
with a balance of Rs.199.2 million are related to Department
of Drinking Water and Sanitation (DoDWS) and Ministry of Panchayati
Raj (Local Government) (MoPR) (Annex 2).
- A list
of agencies and respective accounts registered for the Central
schemes of Ministry of Rural Development (MoRD), DoDWS and MoPR
implemented in Ghazipur were extracted from the PFMS reports. There
were 66 accounts with a balance of 846.7 million which
are related to the central schemes
of MoRD, MoDWS and MoPR (Annex 3).
- Further
analysis revealed that there are gaps in both the lists of accounts
generates through PFMS and sourced locally from the field through the
state officials and banks.
- It
was also noticed that there were 15 inactive accounts, 155 dormant accounts out of the list provided by State. A summary of account status is attached as Annex 4.
6.
Findings and Way Forward
From the analysis, it is clear that a huge amount of funds
are lying idle in the bank accounts. In one district alone an amount of Rs.2.83
billion is lying primarily in idle or transitory accounts. In India, there are
more than 700 similarly placed districts. Thus it is estimated that about Rs.2
trillion is lying in either in an idle or unproductive manner.
Same may be put to use
by bringing it to the nodal treasury account of the State. In the cases where
schemes are already closed, such funds may be remitted back to the treasury of
the State and central government by following a systematic approach to identify
and get the funds back to the treasury account. Government of India
officers of the Ministry of Finance may identify the district-wise bank
accounts and funds lying in them as per PFMS. PFMS team will
extract the list of accounts registered in PFMS for all districts with agency
and scheme-wise details. The list may be shared with the States and agencies
and accounts may be validated. States may be requested to provide the
information related to Government Accounts of various State and central schemes
implemented in the districts.
States may initiate the process of idle fund
reversal as per the guidelines of the Government to make the funds usable. In this regard guidleines of RBI to handle idle and dormant accounts may also be of some use (Annex-6).
Proforma
A: Government Account Details
S.No
|
Filed
Name
|
Details
|
1
|
Bank
Name
|
|
2
|
Branch
Name
|
|
3
|
IFSC
|
|
4
|
Account
Number
|
|
5
|
Account
Type
|
|
6
|
Account
Status
|
|
7
|
Active
from
|
|
8
|
Last
Transaction Date
|
|
9
|
Last
Transaction Amount
|
|
10
|
Available
Balance (Actuals)
|
|
11
|
Scheme
Type
|
|
12
|
Scheme
Name
|
|
13
|
Account
Holder Name
|
|
14
|
Department
Name
|
|
15
|
Account
Registered in PFMS (Yes/No)
|
|
16
|
PFMS
Agency Unique Code
|
|
Proforma
B: List of Government Departments
S.No
|
Field
Name
|
Details
|
1
|
Department
Name
|
|
2
|
Heard
of the Department Name
|
|
3
|
Mobile
Number
|
|
4
|
Office
Land Line
|
|
5
|
Office
Address
|
|
Proforma
C: Department-wise list of concerned officers
Sl.No
|
Field
Name
|
Details
|
1
|
Officer
Name
|
|
2
|
Designation
|
|
3
|
Department/Organization
|
|
4
|
Mobile
Number
|
|
5
|
Email
ID
|
|
6
|
Reporting
Officer Name
|
|
7
|
Phone/Office
Number
|
|
8
|
Email
ID
|
|
Proforma
D: List of State or Central Government Schemes implemented in
the District
S.No
|
Field
Name
|
Details
|
1
|
Scheme
Name
|
|
2
|
Scheme
Type (State or Central)
|
|
3
|
Scheme
status (Active or Closed)
|
|
4
|
Scheme
launch Year
|
|
5
|
State
Share
|
|
6
|
Centre
Share
|
|
Annex 1
Bank-wise no of Govt. Accounts in Ghazipur and
Balances
|
||
Name of the Bank
|
No of Accounts
|
BALANCE (in millions)
|
Union Bank of
India
|
805
|
20,25.64
|
Punjab National
Bank
|
42
|
5,03,17
|
ALLAHABAD BANK
|
98
|
84.78
|
Oriental Bank of
Commerce
|
8
|
5.3
|
State Bank of
India
|
398
|
4.0
|
IDBI Bank
|
45
|
4.3
|
Bank of Baroda
|
20
|
6.6
|
Bank of India
|
40
|
5.5
|
Kashi Gomti Samyut
Gramin Bank
|
383
|
8.0
|
HDFC BANK
|
1
|
0
|
ICICI
|
2
|
4.0
|
AXIS BANK
|
1
|
7.8
|
BANDHAN BANK LTD
|
4
|
4.6
|
INDIAN BANK
|
1
|
2.7
|
Development
Credit Bank Ltd.
|
2
|
0.3
|
Grand Total
|
1850
|
28,22.73
|
Source: List of accounts as per UP State
Annex 2
Details of bank accounts related to GoI Schemes
of DoDWS and MoPR implemented in Ghazipur
Name
of Bank
|
Account
Number
|
IFSC
|
SCHEME
NAME
|
SCHEME
TYPE (State/Central)
|
STATUS
OF ACCOUNT
|
BALANCE
in million
|
Punjab National Bank
|
4483000100037462
|
PUNB0992600
|
Swachh Bharat Mision
|
Central and State
|
Active
|
7.514
|
United Bank of India
|
441502010064163
|
UBIN0544159
|
RKVY
|
CENTRAL
|
ACTIVE
|
0.063
|
United Bank of India
|
441502010064164
|
UBIN0544159
|
RKVY
|
CENTRAL
|
ACTIVE
|
0.028
|
United Bank of India
|
441502010064165
|
UBIN0544159
|
RKVY
|
CENTRAL
|
ACTIVE
|
0.043
|
United Bank of India
|
441502010064166
|
UBIN0544159
|
RKVY
|
CENTRAL
|
ACTIVE
|
0.074
|
United Bank of India
|
392702010337077
|
UBIN0539279
|
SBM-G EXTRA BUDGETARY
RESOURCES
|
CENTRAL
|
ACTIVE
|
9.802
|
United Bank of India
|
392702010337436
|
UBIN0539279
|
PERFORMANCE INCENTIVE GRANT
FUND SBM G
|
CENTRAL
|
ACTIVE
|
107.027
|
United Bank of India
|
392702010337704
|
UBIN0539279
|
GANGA ACTION PLAN
|
CENTRAL
|
ACTIVE
|
74.725
|
Source: List of accounts as per UP State
Annex 3
Bank-wise Summary of accounts registered in PFMS
for GoI schemes of MoRD, DoDWS and MoPR implemented in Ghazipur
S.No
|
Bank Name
|
No of Accounts
|
Unspent Balance
(Rs. In Actuals)
|
1
|
UNION BANK OF
INDIA
|
45
|
79,75,55,273.96
|
2
|
ORIENTAL BANK OF
COMMERCE
|
6
|
2,48,27,186.00
|
3
|
PUNJAB NATIONAL
BANK
|
5
|
2,19,63,925.15
|
4
|
STATE BANK OF
INDIA
|
2
|
18,31,876.30
|
5
|
BANK OF BARODA
|
4
|
4,61,206.00
|
6
|
ALLAHABAD BANK
|
3
|
1,49,123.00
|
7
|
BANK OF INDIA
|
1
|
12
|
|
Grand Total
|
66
|
84,67,88,609.53
|
Source: PFMS
Annex 4
Account Status-wise summary of Govt accounts in
Ghazipur
Account Status
|
CENTRAL
|
Central
and State
|
State
|
Not
Specified
|
Total
No of A/c
|
Total
Balance in million
|
||||
No of
A/c
|
Balance
in million
|
No of
A/c
|
Balance
in million
|
No of
A/c
|
Balance
in million
|
No of
A/c
|
Balance
in million
|
|||
ACTIVE
|
1431
|
4
|
1
|
7.5
|
144
|
9.3
|
103
|
1.0
|
1679
|
1.8
|
Inactive
|
2
|
0
|
|
|
13
|
9.1
|
|
|
15
|
9.1
|
DORMANT
|
8
|
2
|
|
|
73
|
1.8
|
74
|
8.0
|
155
|
1.8
|
Closed
|
|
|
|
|
1
|
|
|
|
1
|
|
Grand
Total
|
1441
|
9.359
|
1
|
0.75
|
231
|
14.003
|
177
|
4.790
|
1850
|
28.227
|
Source: List of accounts provided by UP State
Annex
6
GUIDELINES TO HANDLE DORMANT / INACTIVE ACCOUNTS
– SCHEDULED
COMMERCIAL
BANKS
As per RBI guidelines vide circular no. Circular
DBOD.No.Leg.BC.34/09.07.005/2008-09 dated August 22, 2008, paragraph 2(iv) of
on Unclaimed Deposits/Inoperative Accounts in Banks in terms of which savings,
as well as current account, should be treated as inoperative/dormant if
there are no transactions in the account for over two years. Further,
in terms of paragraph 2(vi), to classify an account as inoperative, both the
types of transactions i.e. debit, as well as credit transactions induced at the
instance of customers as well as third party, should be considered. (Copy of
circular is attached).
Further, as per para vii of the circular, the
segregation of the inoperative accounts is from reducing the risk of frauds
etc. However, the customer should not be inconvenienced in any way, just
because his account has been rendered inoperative. The classification is there
only to bring to the attention of dealing staff, the increased risk in the
account. The transaction may be monitored at a higher level both from
preventing fraud and making a Suspicious Transactions Report. However, the
entire process should remain un-noticeable by the customer.
Para viii of the circular suggests that operation
in such accounts may be allowed after due diligence as per risk category of the
customer. Due diligence would mean ensuring the genuineness of the
transaction, verification of the signature and identity etc. However,
it has to be ensured that the customer is not inconvenienced as a result of the
extra care taken by the bank
Customer Due Diligence
RBI has given its master directions vide their
circular RBI/DBR/2015-16/18 Master Direction DBR.AML.BC.No.81/14.01.001/
2015-16 Master Direction - Know Your Customer (KYC)
Direction, 2016 (Updated as on July 12, 2018) Copy attached).
RBI/2016-17/173 DBR.AML.BC.No.44/14.01.001/2016-17
dated December 06, 2016 - Requirement of customer due diligence and need for
maintenance of records.
As per these guidelines, RBI has referred Banks
to two of its earlier circulars for reactivation of dormant accounts. It is
referred paragraph 24.2 (ix) of the Master Circular on ‘Customer Services
in Banks’ dated July 1, 2015, requiring that operation in dormant accounts with
banks may be allowed after due diligence as per risk category of the customer.
As stated therein, ‘due diligence’ would mean ensuring the genuineness of the
transaction, verification of the signature and identity etc.
RBI has also invited attention to Chapters VI and
VII of their Master Direction on KYC dated February 25, 2016, addressed to
all Regulated Entities (REs) in terms of which
- as
part of the Customer Due Diligence Procedure, certified copies of
officially valid documents for proof of identity and address are to be
obtained while establishing an account-based relationship;
- REs
shall, among others, take steps for preserving the customer account
information including preservation of records of the identification of the
customers and their addresses obtained while opening the account, for at
least five years after the business relationship is ended.
Inoperative Accounts
|
|
|
Unclaimed Deposits /
Inoperative Accounts in Banks
|
|
|
Requirement of customer due diligence and need
for maintenance of records
|
|
|
DBR-Master Circular on Customer Service in Banks
2015 dt 01.07.2015
24. Unclaimed Deposits /
Inoperative Accounts in banks
24.1 Section 26 of the Banking Regulation Act,
1949 provides, inter alia, that every banking company shall, within 30 days
after close of each calendar year submit a return in the prescribed form and
manner to the Reserve Bank of India as at the end of each calendar year (i.e.,
31st December) of all accounts in India which have not been operated upon for
10 years.
24.2 In view of the increase in the amount of
the unclaimed deposits with banks year after year and the inherent risk
associated with such deposits, banks should play a more pro-active role in
finding the whereabouts of the account holders whose accounts have remained
inoperative. Further several complaints were received in respect of
difficulties faced by the customers on account of their accounts having been
classified as inoperative. Moreover, there is a feeling that banks are
undeservedly enjoying the unclaimed deposits, while paying no interest on it.
Keeping these factors in view, the instructions issued by RBI have been
reviewed and banks are advised to follow the instructions detailed below while
dealing with inoperative accounts:
(i) Banks should make an annual review of
accounts in which there are no operations (i.e., no credit or debit other than
crediting of periodic interest or debiting of service charges) for more than
one year. The banks may approach the customers and inform them in writing that
there has been no operation in their accounts and ascertain the reasons for the
same. In case the non- operation in the account is due to shifting of the
customers from the locality, they may be asked to provide the details of the
new bank accounts to which the balance in the existing account could be
transferred.
(ii) If the letters are returned undelivered,
they may immediately be put on enquiry to find out the whereabouts of customers
or their legal heirs in case they are deceased.
(iii) In case the whereabouts of the customers
are not traceable, banks should consider contacting the persons who had
introduced the account holder. They could also consider contacting the employer
/ or any other person whose details are available with them. They could also
consider contacting the account holder telephonically in case his Telephone
number / Cell number has been furnished to the bank. In case of Non Resident
accounts, the bank may also contact the account holders through e-mail and
obtain their confirmation of the details of the account.
(iv) A savings as well as current account should
be treated as inoperative / dormant if there are no transactions in the account
for over a period of two years.
(v) In case any reply is given by the account
holder giving the reasons for not operating the account, banks should continue
classifying the same as an operative account for one more year within which
period the account holder may be requested to operate the account. However, in
case the account holder still does not operate the same during the extended
period, banks should classify the same as inoperative account after the expiry
of the extended period.
(vi) For the purpose of classifying an account
as ‘inoperative’ both the type of transactions i.e., debit as well as credit
transactions induced at the instance of customers as well as third party should
be considered. However, the service charges levied by the bank or interest
credited by the bank should not be considered.
(vii) There may be instances where the customer
has given a mandate for crediting the interest on Fixed Deposit account and/or
crediting dividend on shares to the Savings Bank account and there are no other
operations in the Savings Bank account. Since the interest on Fixed Deposit
account and/or dividend on shares is credited to the Savings Bank accounts as
per the mandate of the customer, the same should be treated as a customer
induced transaction. As such, the account should be treated as operative
account as long as the interest on Fixed Deposit account and/or dividend on
shares is credited to the Savings Bank account. The Savings Bank account can be
treated as inoperative account only after two years from the date of the last
credit entry of the interest on Fixed Deposit account and/or dividend on
shares, whichever is later, provided there is no other customer induced
transaction.
(viii) Further, the segregation of the
inoperative accounts is from the point of view of reducing risk of frauds etc.
However, the customer should not be inconvenienced in any way, just because his
account has been rendered inoperative. The classification is there only to
bring to the attention of dealing staff, the increased risk in the account. The
transaction may be monitored at a higher level both from the point of view of
preventing fraud and making a Suspicious Transactions Report. However, the
entire process should remain un-noticeable by the customer.
(ix) Operation in such accounts may be allowed
after due diligence as per risk category of the customer. Due diligence would
mean ensuring genuineness of the transaction, verification of the signature and
identity etc. However, it has to be ensured that the customer is not
inconvenienced as a result of extra care taken by the bank.
(x) There should not be any charge for
activation of inoperative account.
(xi) Banks are also advised to ensure that the
amounts lying in inoperative accounts ledger are properly audited by the
internal auditors / statutory auditors of the bank.
(xii) Interest on savings bank accounts should
be credited on regular basis whether the account is operative or not. If a
Fixed Deposit Receipt matures and proceeds are unpaid, the amount left
unclaimed with the bank will attract savings bank rate of interest.
24.3 Banks may also consider launching a special
drive for finding the whereabouts of the customers / legal heirs in respect of
existing accounts which have already been transferred to the separate ledger of
‘inoperative accounts’.
24.4 Display list of
Inoperative Accounts: Banks should, in addition to the instructions contained
above, play a more pro-active role in finding the whereabouts of the
accountholders of unclaimed deposits/ inoperative accounts. Banks are,
therefore, advised that they should display the list of unclaimed
deposits/inoperative accounts which are inactive / inoperative for ten
years or more on their respective websites. The list so displayed on
the websites must contain only the names of the account
holder(s) and his/her address in respect of unclaimed deposits/inoperative
accounts. In case such accounts are not in the name of individuals, the names
of individuals authorized to operate the accounts should also be indicated.
However, the account number, its type and the name of the branch shall not be
disclosed on the bank’s website. The list so published by the banks should also
provide a “Find” option to enable the public to search the list of accounts
by name of the account holder.
Banks should also give on the same website, the
information on the process of claiming the unclaimed deposit/activating the
inoperative account and the necessary forms and documents for claiming the
same. Banks are required to have adequate operational safeguards to ensure that
the claimants are genuine.
24.5 Strengthening the
Regulatory Framework for Unclaimed Deposits
With a view to further strengthen the regulatory
framework for inoperative accounts and unclaimed deposits, banks are advised to
put in place a Board approved policy on classification of unclaimed deposits;
grievance redressal mechanism for quick resolution of complaints; record
keeping; and periodic review of such accounts. The first periodic review of
unclaimed deposits/inoperative accounts should be put up to their respective
bank Boards by September 30, 2012.
24.6 Treatment of
certain savings bank accounts opened for credit of Scholarship amounts and
credit of Direct Benefit Transfer under Government Schemes
State and Central Governments have expressed
difficulties in crediting cheques/Direct Benefit Transfer/Electronic Benefit
Transfer/Scholarships for students, etc. into accounts/Accounts with zero
balance opened for the beneficiaries under various Central/State Government
schemes but had been classified as dormant/inoperative due to non-operation of
the account for over two years.
Keeping the above in view, banks are advised
that they may allot a different “product code” in their CBS to all such
accounts opened by banks so that the stipulation of inoperative/dormant account
due to non-operation does not apply while crediting proceeds as mentioned above.
In order to reduce the risk of fraud etc., in
such accounts, while allowing operations in these accounts, due diligence
should be exercised by ensuring the genuineness of transactions, verification
of signature and identity, etc. However, it has to be ensured that the customer
is not inconvenienced in any manner.
24.7 Treatment of
accounts opened for credit of Scholarship Amounts under Government Schemes
Bombay High Court has brought to our notice that
banks fix a limit on total credits in zero balance accounts opened for students
studying in primary, secondary / higher secondary schools and technical
institutions. Resultantly, in cases where scholarship amounts exceed the credit
limit, banks do not allow the credit and return the amount to the disbursement
account of the Government. Further, in some cases banks are reported to have
closed zero balance accounts unilaterally without intimating student
beneficiaries concerned. Instances of banks refusing to open zero balance
account for students have also been brought to our notice.
As directed by the Bombay High Court, banks are
advised to ensure that accounts of all student beneficiaries under the various
Central/State Government Scholarship Schemes are free from restrictions of
‘minimum balance’ and ‘total credit limit’.
SUNDRY ACCOUNTS IN BANKS
SUNDRY ACCOUNT is an account where miscellaneous items are recorded, e.g. infrequent
transactions involving customers or suppliers that are not tracked in the
normal course of business.
In most of the
Banks, transactions in such accounts are to be monitored on day to day basis
and got adjusted daily except in certain cases when there is a need to keep
such balances in Sundry Accounts. Banks also keep some of the amounts in
Imprest Accounts where there is a need to hold balances but these are also
monitored on day to day basis and entries adjusted except for certain cases.
These are Non
Personal or Impersonal Accounts.
Ways to prevent Banks to not to place
Implementing Agency’s funds into their Sundry Account
- IAs not to give any debit authority to Banks for
keeping their funds aside, without which they cannot debit their accounts.
- Banks in turn provide information about transactions of
IA accounts on daily basis in terms of PFMS KPIs.
- Controllers to strictly have a watch on IAs’ accounts
for any such debits.
- In case, controllers find any such transaction, they
may ask for Utilization Certificate from IA.
- Controllers to develop mechanism to check such events
in second or subsequent level IA accounts.
- On certain occasions, IAs authorize Banks to keep Sweep
facility into their accounts, whereby CBS system automatically transfers
excess balances into FDRs. This may show lesser balances in their
accounts.
- On certain other occasions, IAs invest money in FDRs
which may not be shown in their running accounts (SB/CA),
- There can be an occasion when Bank has debited IA
account and is keeping amount into Bank’s pool account for further
remittance to NPCI until the window is open.
Usually, such
entries are adjusted by Banks themselves as explained above. In case, there is
any long pending entry, IA can always take up with the Bank for its credit to
their account.
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