Select Committee on Public Administration Second Report

4  A compensation scheme

(a) General principles

51. The Ombudsman reminded us that "a compensation scheme and the terms have not been developed, consulted on and settled."[80] Her report did, however, outline her proposals in relation to certain key features. In particular, she calls for the compensation scheme to be independent from Government, transparent both in the way that it operates and calculates compensation, and simple in its operation in particular by not imposing undue burdens (evidential or procedural) on those entitled to compensation.[81] She envisages the creation of a "tribunal or adjudication panel, with three members—one broadly representing the interests of citizens and one representing those of the relevant public bodies, with an independent chair".[82]

52. EMAG and Equitable Life have both offered their full assistance in aiding the design and operation of a compensation scheme.[83] Both they, and others, have understood that the Ombudsman's proposal will require the independent tribunal, as its first task, to develop the principles on which compensation will be paid. Equitable Life has offered its assistance in "coming to those principles" and "in applying those principles to the hundreds of thousands, possibly a million policyholders, that were affected".[84] ELTA put on the record its concern that compensation should not be paid to Equitable Life to distribute: "the idea that once again we are reliant on the Society for our future income would not be acceptable."[85]

53. We endorse the Ombudsman's proposal for a compensation scheme that is independent, transparent and simple. It is only fair that the difficult assessments which have to be made are carried out at arm's length from Government and based on principles that are publicly available. Like the Ombudsman and several of the witnesses who appeared before us, we believe that this will require an independent compensation tribunal to be established. The first task of the tribunal must be to determine and then publish the principles and procedures that will be used to calculate compensation. We welcome the commitment of the current board of Equitable Life to provide full and prompt assistance both in relation to this task and subsequently.

(b) Speed vs accuracy

54. An important factor in deciding how to compensate Equitable Life's members is whether to aim for a scheme that is fast and simple or, alternatively, to assess loss as accurately as possible even though this may involve a slow and potentially onerous process for the individuals concerned. The Ombudsman acknowledged that there may be an "inherent conflict" between these two aims.[86]

55. While she offered "no concluded view" on the design of a scheme, her report outlined two principal alternatives:

    "One method is that chosen by EMAG - the identification of quantifiable amounts which are then set at a global level, with the resulting amount shared out to those deemed eligible by some predetermined formula. Another is that used by the Financial Ombudsman Service which, on an individual level, makes a comparative assessment of the performance of the company in question against an average-performing competitor. I have no concluded view on the relative merits of such proposals, which are a matter for others to determine."[87]

56. EMAG has described its approach as "rough edged"; in other words, while it benefits from speed and simplicity the "pre-determined formula" would not necessarily reflect the detailed circumstances of each individual policyholder.[88] In particular, it would require compensation of every policyholder to be reduced by standard discounts. This could lead to some policyholders receiving more than their appropriate share of compensation, while others receive less. Although this would not increase the overall cost of compensation to the taxpayer, it does raise issues of fairness as between policyholders themselves. As Tom Winsor stated: "It is a question of the number of possible claimants. They could be grouped but justice really requires individual assessments."[89] ELTA agrees.[90] It is also questionable whether this feature of EMAG's proposal would comply with Treasury Guidance which states that compensation schemes should not allow individuals "to gain a financial advantage compared to what would have happened with no service failure".[91] A further complication concerns the way in which the "pre-determined formula" would be worked out. As Peter Scawen of ELTA stated: "If you are going to come in with a sum of money, we have to find a way of separating out the classes of claimant. Otherwise, I can see the investors and the annuitants at war with each other for the next thousand years."[92]

57. While the approach that is taken by the Financial Ombudsman Service does not attract these criticisms, EMAG argues that an "FSA style" compensation scheme may take another eight years to conclude,[93] a timescale which it views as unacceptable given that thousands more policyholders would be likely to die during this period.[94] Howard Davies stated:

    whatever solution is chosen should be faster rather than slower because it seems to me that nobody can be particularly satisfied by the length of time which this whole process has taken…. [The worst thing] is to have expectations raised and then find that another ten years go by before you get some cheque, so I would be inclined to say that if you are going to go down this route at all then go down it in as fast and as simply and potentially in as by-and-large a way as you can because I think that to create a further very complicated process would be unreasonable.[95]

58. The Chief Executive of Equitable Life, Charles Thomson, has suggested that speed and accuracy can be reconciled:

    what I have in mind is broadly what I think the Parliamentary Ombudsman had in mind, that the Commission in its first six months would investigate the issues, would define how relative loss is calculated and you would then be able to set up a scheme which worked on a limited number of parameters, like the class of policy, the date or dates money was paid in, the dates money was taken out, and work out a matrix on the basis of those parameters what the loss was related to those and you would then have something that you could build in a computer model and push through for the very large number of people affected. It would be both individual and fair and relatively simple once you had constructed it."[96] He described his model as an "individual approach case-by-case but the brush is not so broad that it would give compensation where compensation was not deemed to be due.[97]

59. We are concerned that there is an inherent tension between speed and accuracy in the way that a compensation scheme can measure loss. In ordinary circumstances it would, in our view, be inappropriate to depart from the basic presumption that loss must be accurately assessed. But the main priority must be prompt redress given that policyholders have already been waiting for almost a decade and substantial numbers have either died or are advancing in years. Justice further delayed will mean justice denied to even more people. Where possible, we urge the compensation tribunal to reconcile the twin goals of speed and accuracy; we take comfort from Equitable Life's belief that a sensible compromise can be achieved.

(c) Reliance upon misleading information

60. A number of the regulatory failures identified by the Ombudsman caused injustice only to individuals who relied upon misleading information that was in the public domain as a result. For instance, the Ombudsman has stated:

61. This raises the issue of whether individuals must prove their reliance on misleading information as part of recovering compensation. EMAG is strongly opposed, preferring to apply a substantial discount to every policyholder's compensation instead: "the alternative is to get very elderly people to dig out some very old documents to try to prove or not prove that they would or would not have done something many years ago and argue about it for years and years. By the time they all get paid half of them will be dead."[99] Colin Slater of EMAG stated that his recommended discount was based on "a reasonable estimate of the sort of number of people who would have moved their money had they known."[100] It would, in effect, lead to some policyholders (i.e. those who could prove reliance) subsidising the recovery of those who are unable (i.e. either due to the lapse of time or because they did not rely at all). While, as above, a discount at the right level would not increase the overall bill faced by taxpayers, it again raises an issue of fairness as between individual policyholders.

62. The Ombudsman has stated: "By reliance I do not mean that it should be expected that an individual policyholder or annuitant should now, perhaps twenty years after the relevant events, be expected to produce copies of the information or advice on which they relied."[101] Equitable Life maintains that the compensation tribunal is best placed to resolve the way in which the issue of reliance is approached:

    It seems unreasonable to expect policyholders to produce information that they are likely to have discarded many years ago. The delay is primarily a result of the Government's reluctance to accept regulatory maladministration - a delay which the Ombudsman has roundly criticised. Consequently it seems unreasonable for policyholders to be disadvantaged by that delay. Perhaps policyholders could be asked to declare their reliance where that is critical to compensation. More detail could be sought in cases where the amounts involved were especially large.[102]

63. An accurate assessment of loss would require policyholders to establish whether they relied upon misleading information or advice. This causes obvious difficulties; the relevant events may have taken place many years ago and substantial numbers of policyholders are either ill, infirm or deceased. A number of alternative approaches have been suggested, which we urge the Compensation Tribunal to consider before placing onerous requirements on policyholders. In our view the circumstances of the policyholders and the delays of recent years require the compensation scheme to avoid placing a burden on individual policyholders wherever this is possible.

(d) Consequences of regulatory failure

64. There are three key factors that have contributed to the losses sustained by Equitable Life's members: mismanagement by Equitable Life's former directors; the historically poor performance of the stock market between the late 1990's and early 2000's; and the regulatory failure that has been identified by the Ombudsman. The Ombudsman states that the main aim of compensation should be to restore individuals to "the position that they would have been in had maladministration not occurred."[103] As outlined above, we agree, but this makes it necessary to consider the extent to which loss should be attributed to regulatory failure.

65. The fairness of requiring taxpayers to compensate Equitable Life's policyholders firmly depends upon making sure that public funds do not pay for loss that is fairly attributable to the poor performance of the stock market or to the mismanagement of Equitable Life's former directors that could not have been prevented by adequate regulation. The aim should be to restore individuals to the position they would have been in had maladministration not occurred.


66. The Ombudsman's report states that it is necessary to take into account the fact that losses were suffered across the "with-profits industry" during the period under investigation. There appears to be general agreement that market based losses of this type should be excluded. For instance, Ian Cowie, who supports the case for compensation, told us: "It is important, I think, to distinguish between investment losses in the market, for which there is no claim for compensation. Nobody claims that the taxpayer should pick up the tab when an investment does not work out."[104] The Ombudsman proposes to achieve this by requiring an assessment of "relative loss", which involves comparing each individual's return on their investment against what they would have achieved by investing in a comparable with-profits fund: "the individual circumstances of each complainant and other people similarly affected are key to establishing whether those people are in the category of those who have suffered relative loss. Accordingly, whether relative loss in a particular case has been sustained has to be determined at an individual level."[105]

67. The Ombudsman's approach mirrors that adopted by the Financial Ombudsman Service (FOS), who has also used it to assess loss in relation to those claims that he has resolved between Equitable Life and its policyholders. A further benefit of the Ombudsman's approach is that it automatically takes into account the benefit of any compensation that policyholders have already received from Equitable Life, as this compensation would reduce the difference between their current circumstances compared with the circumstances they would be in had they invested with an average competitor.

68. In the past, the FOS approach has revealed that approximately 60% of policyholders suffered a relative loss; although it is unclear whether a similar percentage of policyholders would benefit under a broader compensation scheme, the Ombudsman notes that in many respects "[t]hose who have complained to me are in substantially the same circumstances".[106] A great deal, however, depends upon the way in which relative loss is assessed. Equitable Life and others highlight a variety of ways in which it could be done.[107] Charles Thomson told us:

    The Parliamentary Ombudsman spent years on it and has not produced a definition. I do not think it is appropriate for us to try to speculate what that should be. It involves different groups of policy types, different dates coming in, different dates going out, but I do believe that if these parameters are set down and relative loss is looked at in a handful of cases it would then be possible to expand that across the entire population in order to get a figure, but that is the job for a Commission, not for us.[108]

69. We agree with the Ombudsman that any element of loss that is accountable to general market underperformance during the period under investigation should be discounted by assessing each individual's relative loss. This would be by comparing the performance of Equitable Life against an appropriate competitor or group of competitors. The compensation tribunal will need carefully but promptly to decide in which of the many possible ways this should be done.


70. EMAG has considered the impact of mismanagement in some detail:

EMAG proposes that compensation payments should be discounted by 10% "on leading Counsel's advice" to reflect their view that the directors were "primarily responsible".[110]

71. The Chair of Equitable Life stated that he does not "recognise" this figure; while he wouldn't be drawn into allocating blame in percentage terms he stated that his "visceral feeling is that our responsibility was much greater than that".[111] But he argued that any discount was "illogical" on the basis of his Chief Executive's statement that "the company has accepted responsibility for what it got wrong and has done its best to try to put that right between policyholders and in general terms. We do not take responsibility for the maladministration of the regulator and therefore we would see the regulator as 100% responsible for that maladministration and the consequential losses that flow from it".[112] They stated that Equitable Life has paid out around £1.5 billion in compensation, while reminding us that "moving money from one group to another is all a mutual could ever achieve".[113]

72. Peter Scawen of ELTA also opposed any discount based on mismanagement, on grounds that many policyholders might not have suffered any loss at all if it had not been for regulatory failure: "The regulator got it wrong for between 10 and 12 years. I think I speak for many of my members. I would not have bought my with profits annuity with Equitable Life, had I understood the financial situation of the company. That was known from almost 1990 onwards. It was in a difficult situation. It was known to the company. It was known to the regulator and it was known to the industry."[114]

73. The Ombudsman has also emphasised: "I think it is really important to remember that the wrongs done here and the injustice here in describing this report is the wrong done to these people by the regulators; it is not the wrongs done by the company, it is not the wrongs done by the auditors. It is the wrongs done by the regulators and the remedy is very specifically addressing those failings."[115]

74. Others have argued that responsibility could be apportioned between the regulators and Equitable Life through the general principles of "contribution" that are well known within the legal system. For instance, Tom Winsor stated "a thorough judicial process would be able to allocate responsibility among the various players who have failed in some respect".[116] Equitable Life accepted this could have been achieved as part of "an overarching assessment had [that] been carried out from the start" but argued "[t]hat did not happen".[117]

75. A key reason it could not happen was that neither the Ombudsman's investigation, nor any of the other investigations that have taken place, benefited from a sufficiently broad remit to look at regulatory failure and mismanagement at the same time. The Ombudsman's report accepts that regulatory failure contributed to policy value cuts, but stated that it was "impossible" for her to determine to what extent: "I have not investigated the Equitable Life Insurance Society and I would be ultra vires if I did."[118] And as Lord Penrose stated in his report: "The jurisdiction to adjudicate on regulatory failure in duty is not mine."[119] Thus no-one is ideally placed to apportion responsibility between the company and the regulators.

76. ELTA has stated: "Where two wrongdoers are responsible for an individual's loss, the individual should be compensated in full and it is a matter between those wrongdoers as to any apportionment between them".[120] This refers back to the principle of "joint and several liability"[121] under which one wrongdoer must pay full compensation but can then seek a "contribution", as referred to above, from the other wrongdoer. The Law Commission has recently reconsidered this state of affairs in relation to circumstances where one of the wrongdoers is a public body. The preliminary conclusion in its consultation is that there is a "strong case" for altering the rule so that (at a judge's discretion) the public body only pays that share of the compensation that is fairly attributable to their degree of responsibility. The Law Commission refers to a growing number of jurisdictions where this is already the law, including in France and certain states in the United States of America. In France, "this has had a significant impact in cases concerning regulatory and supervisory failure. In [the case of] Kechichian, for example, the state regulator was found to be negligent in its supervision of a bank but was held liable for only 10% of the claimants' total loss, the primary cause being the fraudulent activities of the directors".[122]

77. One of the most difficult tasks is determining the best way to take into account the principal responsibility of Equitable Life's former management. We have already concluded that this should not be a reason for refusing compensation. It is, however, clear that some of the policyholders suffered loss that was caused both by regulatory failure and mismanagement. We commend Equitable Members' Action Group for accepting that compensation payments should be discounted to reflect this issue, primarily due to the amount of taxpayers money at stake. Yet we remain unconvinced that their proposal for a 10% discount represents either a fair or a principled approach. The core difficulty is that neither the Ombudsman nor any other investigation has had a sufficiently broad remit to apportion responsibility between the regulators and Equitable Life's former managers and advisors. In other words, no one is ideally placed to achieve fairness to the taxpayer by apportioning blame (and therefore requiring it pay) for that share of loss that is fairly attributable to regulatory failure (taking into account all compensation paid by Equitable Life to date).

78. At this late stage, we believe the pragmatic response is to require the compensation tribunal to make a determination on the appropriate share of blame. While this is not an easy role for a new tribunal to assume, the outcome would at the very least benefit from being independent and transparent. We emphasise that this issue is not about regulators being able to escape responsibility. On the contrary, it is about ensuring that the taxpayer provides compensation that fairly represents the extent to which regulatory failure was to blame for any losses suffered.

79. We should acknowledge that there are three likely consequences to following this course:

a)  that the tribunal will need to exercise a degree of judgment rather than exact science in apportioning blame—a similar degree of judgment to that exercised by the courts;

b)  that the tribunal will need to decide whether to apply an 'across-the-board' discount, or to apply different discounts to different Equitable members according to their circumstances, and

c)  that many individual Equitable members will be unable to recover a portion of their loss.

(e) Timetable

80. The Ombudsman has called on the Government to ensure that a compensation scheme is established within six months of a decision to pay compensation, and that the scheme should then complete its work within a further two years.[123] There is no doubt that this will be challenging in light of EMAG's suggestions that an "FSA" style scheme could take up to another eight years to achieve, and ELTA's assessment that it would take "51 man years of actuarial effort" to assess the loss of the annuitants alone.[124] But the Ombudsman stated that her proposed timetable was based on "realism"[125]. This has been confirmed by Equitable Life.[126] And as we have noted above, EMAG has also emphasised the importance of speed in light of the circumstances of policyholders. Tom Winsor re-iterated the adage "Justice delayed is justice denied."[127]

81. We are not in a position to gauge whether the Ombudsman's two year timetable to implement the compensation scheme is viable or is setting the Government up to fail. There is, however, a grave danger that any further delay will turn the last decade of regulatory failure into this decade's even greater failure to provide adequate redress. Regulation is never an easy job and mistakes, even serious ones, will occasionally be made, but the real test for government is how it then responds. In this case the Government must treat the smooth and rapid progress of the compensation scheme as a matter of high priority. We intend to monitor this progress carefully.

(f) Hardship

82. It has been suggested that policyholders should only receive compensation in the event that they are suffering financial hardship.[128] This was strongly opposed by groups representing policyholders both for reasons of principle and practice. For instance, EMAG has stated that compensation payments are necessary to redress injustice to policyholders and that hardship payments alone would fail to achieve this purpose.[129] The Ombudsman also strongly opposed, describing the proposal as a "novel and worrying development".[130] ELTA added: "It smacks of injustice. Why should any one individual receive less because by chance they happen to be better off than someone else?".[131] Paul Braithwaite questioned whether "steelworkers" would face the same proposal as Equitable Life's largely "white collar" policyholders.[132] EMAG questioned whether individuals would be willing to put themselves forward for hardship payments, while ELTA considered that it might be difficult to set a dividing line between those who should receive something and those who get nothing at all.[133]

83. There was, however, broader support for interim hardship payments to support policyholders on their "beam end".[134] The Chair of Equitable Life stated: "I have enormous sympathy… with the suggestion that there be a hardship fund in the interim because we do know that many of our policyholders are in dire straits… [with] payments to be made on account of the eventual payments by the taxpayer."[135] Tom Winsor stated means testing would allow for such payments to be workable in practice: "the legal system provides for interim damages to be awarded in deserving cases before the full determination has been finished and that is something that could be worked out in this case."[136] Although Ian Cowie added: "it is equally true that the Government does it very badly, according to Age Concern, for example. They estimate that something like £5 billion worth of means-tested tax credits are not claimed by people who are eligible for them, so going down that route surely is a recipe for further delay?"[137] However, the Ombudsman believed interim payments would be "perfectly viable and, given the passage of time since the complaints of those affected arose, entirely reasonable".[138]

84. It would not be appropriate to compensate only those policyholders and annuitants who are experiencing financial hardship; the payment of compensation is not a matter of charity but a requirement of justice to redress a wrong. However, we consider that there is scope to reduce the financial pressure on those who are struggling the most, including the eldest and those in ill-health. Specifically, we recommend that priority or interim payments are made to individuals in those circumstances. We hope that the representatives of Equitable Life's members will be able to assist in identifying those most in need; in any event, hardship payments must not delay the payment of compensation to all those who are eligible.

(g) Capping costs

85. Some witnesses have suggested a cap on the total amount of compensation that is available as a way of preventing the sums involved creeping higher. For instance EMAG proposes that: "Parliament decides what the aggregate sum of compensation should be and pays it to the compensation tribunal and lets them get on with distributing it. That puts a stop to the creeping additional cost and it also means that the compensation tribunal has the money to get on with doing it."[139] Equitable Life has stated: "Obviously, it is the prerogative of Parliament to consider a cap",[140] while its Chair, Vanni Treves, added: "If the Government can make a judgment eventually when the Commission reports, and if at that stage it says, 'We cannot afford it', or, 'We can only afford it over a period of time', so be it."[141]

86. Others have highlighted the disadvantages of imposing a cap, based on reasons of both principle and practicality. For instance, Tom Winsor stated: "I would not put a cap on it because the citizen has a contract with the State and the regulators are emanations of the State. If the contract is broken, there should be redress and that redress should not be diminished by the willingness, the inclination, of the person against whom the redress is determined."[142] The Board of Equitable Life added: "Unless it is certain that the amount given exceeds the amount due (plus expenses), it seems likely that the Commission would either risk paying nothing to those who were assessed after the funds ran out, or complicate the process considerably by having to make all the assessments before deciding that it had only enough funds to pay all policyholders X% of their losses. (This would also mean no cases would be closed until very late in the process)."[143]

87. The main advantage of a cap on the total amount of compensation to be paid would be that it would limit the taxpayer's liability, particularly in a circumstance where the potential costs are very high. However, it would pre-empt the findings of an independent tribunal. It would also make it very difficult to achieve any speed in the distribution of the money available, without running the risk that there would be none remaining for those identified and assessed late in the process.

88. A cap on individual payments is a separate possibility. Paul Braithwaite of EMAG told us that this would be an issue "for Parliament to decide".[144] There is an ethical case to be made for such a cap, but, to ensure a reasonable retirement income for all those involved without requiring a hardship test, it would need to be set at a level well above that of the average Equitable member's investment, which, as already mentioned, was modest. Thus, although a cap would ensure that the taxpayer was not liable for paying a very large amount of compensation to any one individual, it might have very little impact on reducing the overall cost of compensation. There is also a risk that such a cap could penalise those who depend mainly or entirely on Equitable Life for their pension provision, as against those who have a mix of investments. It would be reasonable for the compensation tribunal to consider a cap on compensation, as a way of limiting the impact on the public purse. We doubt, however, that a cap on the total amount of compensation to be paid could be applied without causing either significant unfairness to some of those who might benefit, or delay to the majority. We would be particularly concerned if a cap of any kind penalised those with modest investments or those worst affected.

89. We have not attempted to, nor would it be possible for us, to deal with all of the issues that a compensation tribunal is likely to need to address. These include, for example, the tax status of compensation payments, and whether to treat payments to the estates of those policyholders who have died in the same way as payments to policyholders who are still alive. For us, the important step to be taken is the establishment of an independent compensation tribunal, with the freedom to take into account whatever factors it believes are relevant.

80   Q26 Back

81   Ombudsman's report, Summary, para 9.33 Back

82   Ombudsman's report, Part 1, Chapter 14, para 149 Back

83   Q122; Q163 Back

84   Q150 (Vanni Treves) Back

85   EQL 28 Back

86   Ombudsman's report, Part 1, para 143 Back

87   Ombudsman's report, Part 1, Chapter 14, para 22 Back

88   Qq 59, 69, 143 Back

89   Q270 Back

90   EQL 28 Back

91   HM Treasury, Managing Public Money, Annex 4.14.9, available at  Back

92   Q73 Back

93   EMAG, Comments and Proposals for Redress, page 59, available at Back

94   It's an Inequitable Life: Icesave v Equitable, Retirement & Pensions, 13 October 2008, Malcolm Wheatley, available at Back

95   Q270 Back

96   Q227 Back

97   Q228 Back

98   Ombudsman's report, Chapter 12, para 100; see also para 168.  Back

99   Q70 (Colin Slater) Back

100   Q71 Back

101   Ombudsman's report, Part 1, Chapter 12, para 96 Back

102   EQL 24 Back

103   Ombudsman's report, Summary, para 9.27 Back

104   Q240 Back

105   Ombudsman's report, Summary, paras 9.12 to 919 Back

106   Ombudsman's report, Summary, para 9.16 Back

107   EQL 24; Q173 Back

108   Q159 Back

109   EQL 04 Back

110   EQL 04 Back

111   Q167 Back

112   Q167 Back

113   EQL 24 Back

114   Q87 Back

115   Q40 Back

116   Q263.  Back

117   EQL 24 Back

118   Q16; The Ombudsman's report, Part 1, Chapter 12, paras 185 -186 Back

119   Penrose Report, p 746 Back

120   EQL 28 Back

121   The Law Commission explain the meaning of joint and several liability as follows: "where two or more persons acting independently contribute to the same loss, the claimant can sue any of them for the entire loss irrespective of their actual 'share' in the overall blame. The defendant who is in fact sued then has a right to seek contribution from the other wrongdoer(s) in respect of their pro rata share in the blame", Administrative Redress: Public Bodies and the Citizen, para 3.176 Back

122   As above, para 4.91 Back

123   Ombudsman's report, Summary, para 9.31 and 9.36 Back

124   EMAG, Comments and Proposals for Redress, page 59, available at; EQL 05 Back

125   Q27 Back

126   Q164 Back

127   Q272 Back

128   Q267 (John Kay) Back

129   Q64 (Paul Braithwaite) Back

130   EQL 21 Back

131   Q62 Back

132   Q79 Back

133   Q79 (Mr Braithwaite); Q61 (Mr Scawen) Back

134   Q65 (Mr Scawen) Back

135   Q219 Back

136   Q265 Back

137   Q268 Back

138   EQL 21 Back

139   Q67 Back

140   EQL 04 Back

141   Q185 Back

142   Q248 Back

143   EQL 24 Back

144   Q 81 Back

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