Select Committee on Treasury Fifth Report

4 Shortfalls

Asset allocation and poor investment returns

31. Unfortunately it has become plain in recent years that many endowment policies are unlikely to generate enough to pay off their target, the sum borrowed as a mortgage. In large part these shortfalls reflect problems in the asset allocation policies pursued by insurance companies. Section 2 highlighted the inherently risky nature of endowment mortgages. Whether they were aware of it or not, anyone taking out an endowment mortgage was essentially gambling that when it matured, their endowment policy—invested in relatively volatile assets such as equities—would generate enough funds to pay off the fixed liability represented by the mortgage. That gamble was a particularly large one because UK insurers have a much higher exposure to equities than their counterparts overseas. ONS data suggests that for much of the 1980s and 1990s life company portfolios typically had a 65%-70% weighting in equities. Witnesses told us that US life companies were not allowed to take equity weightings above 15%.[59]

32. UK life companies as a whole failed to take any action to trim their equity exposure as the equity bubble inflated through the latter half of the 1990s. Mr Bloomer of Prudential told us that his company began to respond towards the end of 1999, but that "we have a £55 billion/£60 billion fund so it does take us some time to rebalance the portfolio without causing real concern in equity markets. Over the period from late 1999 through to early 2001 we moved 40% of the fund out of equities."[60] Other major companies, however, seem to take a very different attitude to asset allocation. Mr Crombie of Standard Life, told us that "the Standard Life Group financial strategy for a very long time has been to hold the maximum amount of equity consistent with its financial strength and that policy has been held throughout. Clearly at times that will look to be the wrong policy and at other times it will look to be the right policy." [61]

33. It is clear that poor asset allocation policies have played a major role in creating many of the problems that have hit endowment policyholders. Both Mr Sandler and Mr Myners told us that this reflected a herd-like mentality towards asset allocation, an issue which received far too little attention, yet "there is no question that the ultimate outcome for consumers in their savings process is governed in the overwhelming majority by the asset allocation decision…. That is one of the reasons why the investment process in this country is not a very effective deliverer to consumers of the best possible result."[62] Mr Sandler went on to suggest that the failure to devote enough time and resource to the asset allocation decision owed much to the opaqueness with which the industry operates, with "no effective scrutiny of what the asset allocation should be. Most people do not know it; it is not publicised. It does not contribute in any way to the evaluation of the performance of the product provider, so, if it is out of kilter, it is certainly not because it has been driven that way by consumer pressure or advisory pressure."[63] Given the central role of asset allocation in determining investment returns, the FSA should make it a basic principle that all investors in long-term savings products are given regular information on the asset allocation policies of the product provider and how this has added to, or detracted from, the performance of the investment fund.

34. Mr Myners told us that the "long-term record of the industry in asset allocation is not terribly good. National economic statistics have shown that on the whole the industry tries to buy more equities at the peak of the [equity] market than it does at the bottom and buys more bonds at the peak of the bond market than it does at the bottom of the bear market [in bonds]."[64] That thesis is borne out by the recent track record of the insurance industry, which went into the peak of the equity market with relatively high weightings in equities, but then cut back equity weightings and bought bonds near the bottom of the equity market. Indeed it seems clear that across the industry a mix of changing investment views and prudential regulatory requirements have produced a shift from equities to bonds. Thus, Mr Cazalet told us that "broadly, across the with-profit sector, going back two years ago, the typical weighting in equities was 65%; it is now about 30%."[65]

35. The net result is that the shortfalls policyholders are now suffering only partially reflect the fall in the equity market between early 2000 and spring 2003. In many cases the major problem is rather that as the economy has settled into an era of low inflation and low nominal interest rates, it has become increasingly improbable that the underlying investments underpinning endowment policies will deliver the nominal returns assumed when the policies were written in the late 1980s and 1990s. This is particularly so given that many with-profits funds have now switched from risky, but potentially higher growth, equities into safer, but lower growth, bonds. Recent signs of an equity market revival thus do not herald the end of the problems for policyholders.

36. In several cases the recent switch in asset allocation reflects funds closing to new business. Mr Haste, Chief Executive of Royal & Sun Alliance, which has itself closed its with-profits fund to new business, told us he thought that therewere "over 20 closed funds in the industry."[66] We return to the issues posed by closed funds in greater detail later, but such funds typically now have very limited exposure to equities and are extremely unlikely to rebuild their equity weightings.

Actions taken to keep customers informed

37. To reflect the shifts in likely investment returns the FSA told us that they had sought to ensure "that policyholders are well informed about any potential shortfalls on their investments and the options available to them."[67] With this objective in mind, "at the instigation of the FSA, the Association of British Insurers (ABI) adopted a code of practice in September 1999 under which its member firms carried out regular forecasts of the final value of mortgage endowment policies and communicated this information to all their policyholders. The resulting 'reprojection' letters told individual policyholders whether or not the policy was still on track to repay the mortgage. These are now sent out every two years. Individual reprojection letters began going out to consumers in April 2000. The letters outlined the need to take action if the policyholder faced a potential shortfall and also enclosed factsheets from the FSA."[68]

38. Within the industry the reprojection letters are referred to by colour codes, although we understand that in most cases the letter actually sent to clients has no colour printing on it to reflect the coding level. As a standard, policies needing annualised investment growth of over 8% during their remaining lifetime to meet the sum needed for repayment of the original mortgage receive what is known as a red letter, indicating a high probability that the endowment will not meet its target sum. 8% is in line with the upper boundary for illustrative projections set by the PIA in July 1999, but any policy bought prior to July 1999 will probably have had a higher upper boundary for potential returns in the marketing literature. Amber letters are sent to holders of policies which require an annualised return of 6% to 8%, with the view being that "the endowment is unlikely, on the balance of probabilities, to reach the target sum."[69] Green letters go to remaining policyholders. To help the process of alerting as many policyholders as possible to the shortfall problem, the Committee recommends that "red" reprojection letters, warning policyholders of a high probability that their endowment policy will fall short of its target, should always have the key section printed in red, analogous to the format used in overdue bills from utilities and others.

39. The FSA has complained that the industry generally failed to do anything on its own initiative to keep policyholders informed of the problems developing in endowment mortgages and it sees the problem as symptomatic of the industry often failing to pay due regard to customers' interests after the point of sale. As far back as 2001, the FSA stated that "even when it became clear that many customers' endowment polices might fail to pay off their mortgages, it still required intervention by the FSA before firms agreed to tell customers about the risk. Customers deserve better. If the financial services industry is to enjoy their trust it must treat customers fairly throughout the term of the commercial relationship and not just when making the sale."[70] There seems now, with a few exceptions, to be a widespread acceptance in the industry that initial consumer communications on the subject of possible shortfalls were deficient, a deficiency which has played a crucial role in worsening the problem. Standard Life told us that "the crux of the matter is that over a lengthy period interest rates fell, but providers and advisers failed to warn policyholders of the desirability of saving some of the reduction in their mortgage interest payments against the risk that policy returns would also fall."[71] Aviva plc also told us that "had early consumer awareness of any emerging shortfall been better managed, more policyholders may have exercised the option of using some or all of the savings they were realising through lower interest rates to offset the projected shortfall."[72] In essence, the first warning many consumers received of the problem was a red letter telling them the policy was already highly likely to show a shortfall. Prior to 2000 holders of "with-profits policies would normally have received annual bonus notices, but these usually focused only on the bonus for the year not the likely return over the lifetime of the policy."[73] The ABI told us that "post-sale communications to customers in the 1980s and 1990s could clearly have been better—a lesson the industry has now learned for all product ranges, not just endowments."[74]

40. The main voice dissenting from this view came from Mr Prosser, Chief Executive of Legal & General, who told us that the endowment mortgage issue was a "basic piece of maths"[75] which "consumers did grasp"[76] and that the company had done everything it could to advise its customers of what was happening.[77] Legal & General pointed out that their main endowment product "contained from the outset a five yearly review of premiums. This feature gave policy holders information at regular intervals on which to decide what action, if any, to take to ensure their mortgages would be paid off at maturity."[78] It is notable, however, that prior to the FSA's requirement to send out regular reprojection letters, the best policyholders could expect across the industry was to be told how their policies were doing every five years. The industry's track record ahead of FSA intervention in failing to keep the customer informed about the deepening problems surrounding endowment policies is a matter of serious concern. It is, to use the term employed by Standard Life in its submission to the Committee, the "crux" of the endowment mortgages issue, both because of the problems it subsequently caused as the shortfalls confronting policyholders spiralled, but also because of what it reveals about the industry's attitude to the post-sale care of its customers.

41. While the current reprojection exercises are standardised around the 4%, 6% and 8% target ranges laid down by the PIA in June 1999, Mr Tiner told us that "with the three years of bear markets and, more particularly, the changing asset allocation within portfolios away from equities and towards the bond markets" he had asked "firms now to review whether their projection rates of 4%, 6% and 8% were proper ones in the light of that change and to adjust them where appropriate. We have found that since our letter in June on that, a very large number of companies have reduced the projections, which will themselves increase the number of red letters."[79] At least one independent industry expert, Mr Cazalet, has argued that "the use of a 6% after tax projection rate by life companies looks highly unrealistic given that, in the case of with-profits contracts, the average underlying asset mix is dominated by bonds, which means that life offices may struggle to generate annual returns of 4% to 5% after tax."[80] Mr Tiner agreed there may be a problem, telling us that the FSA was "reviewing the whole concept of reprojection rates at the moment because I am not sure that the FSA should be responsible for setting the reprojections rates. I think that we might want to give it over to perhaps an academic body that can then, perhaps, look at them in a more dynamic way."[81] The assumed rates of returns being used in reprojection letters are central to the FSA strategy for warning policyholders about potential shortfalls. It is essential that the FSA closely monitors the assumptions used and ensures that they are realistic. While it may be useful to call in outside bodies in an advisory capacity in this process, the responsibility of setting the rates used and ensuring that they are realistic should rest ultimately with the relevant insurance company, which knows the nature of its own portfolio.

The current scale of the shortfall problem

42. The Committee was anxious to ascertain the scale of the endowment mortgage shortfall problem. The Association of British Insurers, for example, had told us that it estimated "that around 1.5 million people currently face a projected shortfall against their mortgage loan."[82] John Tiner, Chief Executive of the FSA, told us that he found that estimate "incredibly surprising; I thought that would be a bigger number, quite frankly"[83], but was unable initially to provide firm data on either the number of policies or the number of policyholders currently facing a projected shortfall. Mr Tiner did tell us that "the estimate of the number of red letters for this year's round of reprojection letters is going to be much higher than last time; the last time round it was quite high, about 50 per cent. I should think it will go to 70 per cent or so this year"[84] but the FSA was initially unable to give the Committee any estimate of the average projected shortfall for policies receiving red letters. The Committee put it to Mr Tiner that without hard figures on such issues the FSA would be unable to implement its product risk framework approach to regulation, which relies on matching the regulatory resources devoted to a problem to its likely size. Mr Tiner agreed.[85]

43. Given the sketchy nature of the initial information available from the FSA on endowment mortgage shortfalls, the Committee decided to approach five major insurance companies both to give general evidence on endowment mortgages but also to give us detailed data on the shortfalls issue. The companies approached were Aviva (whose UK life business trades as Norwich Union), Legal & General, Prudential (with endowment policies issued by both Prudential and Scottish Amicable), Royal & Sun Alliance and Standard Life. Between them these companies have 4,680,000 endowment policies still in force, 55% of the 8,500,000 policies estimates by the FSA to be still in force across the market. The percentage of policies attracting red letters in the last available reprojection exercise, indicating a high probability that the endowment will not meet its target sum, ranged from 39% in the case of Aviva to 81% in the case of Royal & Sun Alliance. Across the 4.68 million policies in force with our sample of five companies, 83%, or 3.88 million policies, attracted red or amber letters, indicating that, on balance, the policies were unlikely to generate enough funds to pay off the endowment mortgage. This compares with a 78% estimate[86] for the industry as a whole that the FSA was able to provide to the Committee. The FSA also estimated that the average shortfall per policy was £5,500, in line with the range of estimates we received from our sample of companies.[87] This suggests that at the time of the last reprojection mailing the total shortfall confronting policyholders was of the order of £37 billion, although the figure quoted to us by the FSA for the total shortfall was 'only' £30 billion because the FSA based its calculations simply on the 6.8 million policies in place it believes are still being relied upon to repay a mortgage, rather the 8.5 million total number of policies.[88]

44. The FSA pointed out to us that its estimate of a £30 billion aggregate shortfall is subject to "major uncertainties relating to future investment performance. It also fails to take into account the 'time-value' of money—that is, £1 in ten years' time is worth less than £1 today. So we would caution against placing too much reliance on any estimate."[89] At the same time however, the FSA, told us that the "current projection data suggests that the larger shortfalls will arise on policies with a maturity date more than five years hence (i.e. after 2008) as the fall in returns in more recent years works through."[90] In addition the FSA noted that "a recovery in equity markets and higher investment returns more generally would help to reduce the proportion of policies likely to see a shortfall at maturity. However, this 'upside potential' will be constrained by the fact that in recent years most funds have substantially reduced their exposure to equities. Many funds have also maintained payments above asset share as part of the 'smoothing' of returns provided by with-profits funds, but this implies some 'catching up' will be required in the coming years to restore an equilibrium. As a result, our analysis suggests that the balance of risks is weighted towards a further increase in the numbers of policies falling short."[91]

45. Independent experts are similarly gloomy. Mr Cazalet, of Cazalet Consulting, expects the mortgage endowment failure rate "to increase over the next few years to the point where practically all mortgage endowments maturing will fall short."[92] In the absence of remedial action, it is also likely that the absolute number of endowment policies maturing and failing to produce enough to pay off the mortgage to which they are linked is likely to grow steadily between now and 2013, 25 years after the share of the mortgage market taken by endowments peaked at 83% in 1988.[93] Mr Cazalet has also argued that the generally assumed rate of return on investments of 6% may be too high. If a more cautious, but still plausible, assumption of future post-tax investment returns of 4% is employed he suggested that this could boost the aggregate shortfall confronting policyholders to £95 billion. This view was dismissed as too gloomy by both major insurance companies and the FSA[94]. Mr Harvey of Aviva told us that he thought "Mr Cazalet's numbers exaggerate the problem by a factor of more than two."[95] The FSA has nevertheless acknowledged the sensitivity of the size of projected shortfalls to the future projections rates used, noting that on its own analysis assuming net returns of 4% would produce an average shortfall per policy of £9,600. This would an imply an aggregate shortfall across all endowment policies of over £65 billion. The situation is therefore uncertain, but on all available estimates endowment mortgage shortfalls are a major problem that is likely to grow over time.

46. The Committee concludes that the best available evidence suggests that mortgage endowment policies are currently showing a collective shortfall of around £40 billion. Looking just at policies still being relied upon to repay a mortgage, the collective shortfall is at least £30 billion. Around 80% of policies are currently unlikely to generate enough funds to pay off the mortgage they were originally sold to meet and the average shortfall is currently around £5,500. The balance of probabilities is that both the percentage of policies showing a shortfall and the average size of the shortfall per policy will worsen over the coming years. Without remedial action endowment policies maturing but failing to meet their targets are likely to be an increasingly common problem until 2013, 25 years after the peak in endowment policy sales in 1988.

47. Members of the insurance industry have at times seemed to suggest that the shortfall picture was being portrayed in an overly dramatic fashion. The Association of British Insurers (ABI), for example, suggested that one mitigating factor is that many policyholders "will have accumulated substantial housing equity as a result of rising house prices."[96] It is apparent, however, that releasing any equity would involve policyholders selling their home and moving to a smaller property, not always a palatable or realistic option. The ABI also pointed out that "those with repayment mortgages have seen their total mortgage payments fall as interest rates have come down. Those with endowment mortgages have benefited more from lower interest rates since (in contrast to repayment mortgages) they pay interest on the full loan throughout, not on a declining sum." This observation would carry more weight if policyholders had been better informed at an early stage and advised of the need to use the benefit of lower interest rates to bolster their mortgage repayments. The ABI acknowledges that "for many endowment holders, the lower actual and predicted investment returns mean they need to save or invest more each month to avoid a shortfall at the end of their mortgage term."[97]

48. While there are indeed various offsets to the mortgage endowment shortfall problem, it is equally clear that there are some households for which it could prove a major difficulty. Citizens Advice, for example, told us that "because many of our clients are poor they do not have the resources to repay projected endowment shortfalls. This is a particularly acute problem for people who are approaching retirement or who have already retired."[98] Citizens Advice also told us "that particularly acute financial difficulties are experienced by homeowners who are notified of an endowment shortfall towards the end of their mortgage term."[99] Ms Foster of the Financial Services Consumer Panel agreed that "there is a real problem about people approaching retirement age facing a shortfall, and [the Financial Services Consumer Panel] did recommend that the FSA should ask the whole industry, not just the problem firms but the whole industry, to look at that particular category of policyholder right across the industry, and they did not see it as necessary to do so."[100] Indeed Mr Tiner told us that the FSA had no information on particular parts of the community that may be more than usually vulnerable to problems with endowment shortfalls and that if it was anyone's responsibility to explore this issue it was "probably the [insurance] companies."[101]

49. The Committee has expressed concern in the past that there are no clear lines of responsibility in monitoring potentially destabilising financial issues. In our Report on the Chancellor's recent Pre-Budget Report, for example, we highlighted the potential dangers surrounding high levels of consumer credit and recommended that "A greater degree of coordination is needed between the Treasury and the Bank in assessing how policies should address the potential risks to both the economy and individual households flowing from high levels of household debt."[102] There seem to be similar gaps in the lines of responsibility between the FSA, the industry and Government in terms off who takes the lead in monitoring the risks to the economy and individual sections of society flowing from endowment mortgages. Mortgage endowment shortfalls are a multi-billion pound problem. The shortfalls are a problem that could have a particularly serious impact on the elderly and some of the more vulnerable sections of society. It is particularly important that these individuals get timely and accurate advice on how to tackle this problem.

The position of policyholders in closed funds

50. We noted earlier (Section 2) that the position of with-profits policyholders generally seemed unsatisfactory but the treatment of with-profits policyholders who have taken out endowment or other policies through insurance companies that have closed to new business seems to be particularly unfair. We have been told that there are now over 20 closed funds in the industry.[103] An insurance company can close a with-profits fund to new business, but the rest of the company will continue to trade as normal. Thus, for example, Royal & Sun Alliance told us that it had closed its with-profits funds to new business, but that it remained "one of the UK's leading general insurance groups, employing around 12,000 people in the UK."[104] On closing to new business, a with-profits fund will typically switch a substantial proportion of the investment portfolio out of equities into bonds in an attempt to reduce the volatility of the fund and minimise the capital the insurance company may need to support the fund. Thus Royal & Sun Alliance, which closed its funds to new business in 2002, told us that the equity weighting of its two main life funds had fallen in one case from 59% in 1998 to 21% in 2003 and in the other case from 41% to 10%.[105] The result is that an investor who bought a policy offering strong exposure to equities and therefore potentially high growth prospects suddenly finds that their policy is now invested in a low growth, bond dominated fund.

51. The switch in asset allocation can have a significant impact on likely returns. The Committee, for example, has been told that on standard actuarial assumptions someone with a £50,000 with-profits pension policy and 10 years to retirement is likely to find their fund reduced by £6000 on retirement if their insurer closes to new business.[106] A similar reduction in returns is likely to apply to endowment policy holders in closed funds and Royal & Sun Alliance told us that it had considered it prudent to reduce its projected returns to endowment policyholders to "reflect the lower proportion of equities held in the investment portfolio."[107] For its traditional with-profits funds it now used reprojection rates of 4%, 4.75% and 5.5% and this had "inevitably placed more policies in the red category."[108] 81% of Royal & Sun Alliance endowment policyholders are currently receiving red reprojection letters, the highest figure among the major insurers we asked for data. While Royal & Sun Alliance told us that they had written to their clients on the closure of the fund and explained the implications, policyholders were given no particular opportunity to leave the fund and if they chose to do so normal exit penalties would apply.[109] We have asked several experts[110] and the FSA[111] if they can think of any other industry that sells its customers one product, such as an equity based with-profits endowment policy and then unilaterally switches the customer into another product, such as a bond-oriented closed fund. No one has yet been able to name another industry which treats its customers in an equivalent fashion. The treatment of policyholders in closed funds is unfair. The insurance industry seems to be unique in preserving to itself the right to sell a customer one product and then substitute it with another product which is inferior in key respects. The FSA should examine the case for a regulatory requirement that solvent companies[112] closing the with-profits elements of their operations to new business should, on request, transfer their customers without penalty to another supplier offering a product broadly similar to the one the customer originally bought.

Aligning company and consumer interests

52. Many consumers are currently suffering large losses from the shortfalls surfacing on endowment policies. The insurance companies that sold them the policies are suffering no direct losses or costs at all from the shortfalls. Indeed the companies are still able to levy their full fees on the underlying funds, regardless of the performance of the fund. This suggests a fundamental mismatch between the companies' interests and the interests of policyholders. Most of the endowment mortgages sold were "low cost" endowments, with no guaranteed maturity value and industry executives confirmed to us that all of the shortfall fell on the policyholder.[113] Because of this, some witnesses have suggested that companies had an incentive to sell the product cheaply by setting premiums below those which gave the policy a reasonable chance of hitting its target. Companies also had an incentive to employ a high risk, but possibly high return, asset allocation strategy to try and make the potential returns for the policy look more attractive at the time of the sale.[114]

53. Industry executives denied these accusations. Mr Harvey, Group Chief Executive of Aviva plc, told us that "the company has no interest in selling too small a policy. In general we illustrated mortgage endowments at three rates of interest and it was normal for the central rate of interest to be that which the customer chose as being their target."[115] Mr Crombie of Standard Life also told the Committee that "In the specific case of mortgage endowments in the year 2000, we issued an endowment promise to make up some of the gap that existed at that time on forward projections. It was a move made voluntarily to try to reduce the level of discomfort that our policyholders who were using this product for the original purpose were experiencing. I think we have tried hard."[116] There is an urgent need to align the interests of savers and product providers more closely, not just in areas such as endowment mortgages but in other areas such as the forthcoming Sandler suite of products. From the consumer's perspective, it is perverse that most companies are still charging their full fees on endowment policies when 80% of policies will fail to meet the product's original objective of paying off the mortgage. A structure in which the fees charged by product providers were tied to the product meeting set investment targets would serve the consumer better, and we recommend that the FSA together with the industry investigate this issue, with a view to developing proposals for reform.

59   Q 46 Back

60   Q 497 Back

61   ibid Back

62   Q 317 Back

63   Q 319 Back

64   Q 317 Back

65   Q 39  Back

66   Q 481 Back

67   Ev 95 paragraph 3 (HC 275) Back

68   Ev 95 paragraphs 6 & 7 (HC 275)  Back

69   Ev 108 paragraph 7 (HC 275)  Back

70   DP7: Treating customers fairly after the point of sale, FSA press release, 27 June 2001 Back

71   Ev 185 paragraph 27 (HC 275) Back

72   Ev 65 paragraph (HC 275) Back

73   Ev 5 paragraph 11 (HC 275) Back

74   ibid paragraph 12  Back

75   Ev 155 paragraph 7.12 (HC 275) Back

76   Q 389 Back

77   Qq 396, 397 Back

78   Ev 157 (HC 275) Back

79   Q 216 Back

80   Caught Short-Mortgage Endowment Shortfalls, Cazalet Consulting, September 2003, page 3  Back

81   Q 218 Back

82   Ev 8 (HC 275) Back

83   Q 193 Back

84   Q 220 Back

85   Q 195 Back

86   Ev 111 paragraph 27 (HC 275) Back

87   Qq 361-366 Back

88   Ev 111 paragraph 27 (HC 275) Back

89   ibid Back

90   Ev 109 paragraph 18 (HC 275) Back

91   ibid paragraph 19 Back

92   Caught Short-Mortgage Endowment Shortfalls, Cazalet Consulting, September 2003, page 3  Back

93   ibid page 12  Back

94   Q 250 Back

95   Q 562 Back

96   ibid paragraph 21 Back

97   Ev 6 (HC 275) Back

98   Ev 75 paragraph 2.2 (HC 275)  Back

99   ibid paragraph 2.4 Back

100   Q 134 Back

101   Q 249 Back

102   Third Report of Session 2003-04, The 2003 Pre-Budget Report, HC 136, paragraph 13 Back

103   Q 481 Back

104   Ev 175 paragraph 1.2 (HC 275) Back

105   Ev 177 paragraph 3.3.3 (HC 275) Back

106   Q 58 Back

107   Ev 177 paragraph 4.2.3 (HC 275) Back

108   ibid paragraph 4.2.4 Back

109   Q 493 Back

110   Q 61 Back

111   Q 142 [HC (2002-03) 1211-i] Back

112   i.e. excluding mutuals Back

113   Q 350 Back

114   Q 183 Back

115   Q 358 Back

116   Q 356 Back

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