International Accounting Standards and Their Implications for Accountants and U.S. Financial Statement Users.
The mission of the Financial Accounting Standards Board (FASB) -- the entity currently responsible for developing U.S. generally accepted accounting principles (GAAP) -- is to establish authoritative standards for U.S. financial accounting. Until recently, the FASB's development of GAAP has been mostly unfettered, except for the Securities and Exchange Commission's (SEC's) review. Recent developments in international accounting standards, however, suggest that things may soon change. U.S. firms should use this time to prepare for a worldwide shift toward uniform accounting standards, before such provisions become too onerous.
The need for international standards is clear. As businesses and trade barriers between nations become less restrictive (e.g., under the influence of the North American FreeTrade Agreement -- NAFTA), differences among national accounting and auditing standards become more troubling . International competition has forced many firms to look to new markets. It has also led investors to finance the expansion and modernization needed to keep pace and advance in world markets.
In 1992, foreign investors engaged in $149 billion of transactions in U.S. securities, which, by 1997, increased dramatically to a staggering $1.1 trillion . Between 1975 and 1997, cross-border transactions in bonds and equities as a percentage of Gross Domestic Product (GDP) grew from 4 percent to 213 percent in the U.S.; from 2 percent to 96 percent in Japan; from 5 percent to 253 percent in Germany; and, from 1 percent to 672 percent in Italy . This expansion greatly increases internationalized worldwide capital markets. In turn, it strengthens the need for internationally comparable financial statements and related accounting standards. As Fitzgerald says:
Accounting principles and reporting practices are forms of communication which, in theory, should move across national boundaries as freely as the business practices they are intended to reflect. In truth, however, these procedures mirror the disparate economic and social environments of their respective nations and regions .
Ideally, establishing international accounting standards should reduce the costs of doing business and raising capital across borders, streamline internal accounting and auditing functions for multinationals, increase the efficiency of market regulations, and decrease the costs of international financial statement analysis and investment.
In July 1995, the International Accounting Standards Committee (IASC) and the International Organization of Securities Commissions (IOSCO) agreed to a list of issues to address in a "core" set of international accounting standards. These standards would be used in offerings of U.S. securities by companies incorporated outside of this country (cross-border offerings), and listings of company securities in both domestic and international markets (multiple listings) . This article: (a) discusses the current state of international accounting standards; (b) suggests that no quick solution to this problem exists; and (c) assesses how U.S. firms can smoothly meet the challenges they will undoubtedly face in the area of international accounting.
Development of U.S. Financial Accounting Standards
Before 1900, the U.S. economy did not require sophisticated accounting systems since sole proprietors operated most businesses. Thus, accounting reports emphasized solvency and liquidity, and were intended for internal use or for banks' and other lending institutions' scrutiny. This century's growth of large corporations caused a demand for greater disclosure and shifted the concern from solvency to income-producing ability. Therefore, the SEC was established to insure full and fair disclosure of all material facts relating to publicly traded securities. The SEC was granted the power both to specify the form of documents filed with it and the accounting principles used to generate the financial data presented in the reports.
Since 1974, the FASB has had sole responsibility for establishing private sector accounting standards (subject to SEC approval for publicly traded firms). This full-time body, whose members come from practicing CPAs, government law, financial statement preparers and users and academe, replaced the American Institute of Certified Public Accountant's (AICPA's) part-time efforts to set financial standards. Given the importance of its work, the FASB always seeks to follow due process, so much so that it spent more than 11 years deliberating on such authoritative standards as SFAS Nos. 87, 109 and 133.
Most financial statement users believe present-day FASB standards provide adequate information to make informed investment decisions . The SEC has allowed the FASB and its predecessor, private sector bodies (e.g., the Committee on Accounting Procedure and Accounting Principles Board), to establish authoritative accounting standards. However, the SEC has occasionally overruled the FASB -- for example in its accounting standards for stock issued to employees, inflation, and oil and gas exploration.
Development of Standards by the IASC
International accounting is currently a collection of individual national authoritative pronouncements, making comparisons of companies across borders cumbersome and potentially confusing. That's why there have been more efforts recently to harmonize international standards. Such supranational groups as the International Federation of Accountants (IFAC), the IASC, the Organization for Economic Cooperation and Development (OECD) and the European Economic Community (EEC) have worked together more closely than ever before. The IFAC, for example, is one of the largest international accounting groups consisting of 114 professional accounting bodies that represent more than 1.2 million accountants from more than 83 countries. This huge entity has issued more than 442 guidelines on ethics, education and auditing practices .
Although the two organizations work closely together, the IASC issues its standards for presenting audited financial information independent of the IFAC's standards. And recently, it has become obvious that acceptance of IASC standards is spreading. The London and Hong Kong Stock Exchanges now require all foreign listed companies to comply with IASC standards . Indeed, the IASC states that only three major U.S. organizations -- Microsoft, FMC and the AICPA -- refer to complying with IASC standards in their financial statements. (Actually there are now four, General Electric should be added.) In Canada the number is 43, in Kuwait 49, in Germany 62, in Switzerland 97 and in China 105 .
Another example of the influence and acceptance of IASC standards is the recently announced FASB decision to eliminate pooling of interest as a method of accounting for business combinations . This brings U.S. standards into line with international practice. As FASB Chairman Edmund L Jenkins conceded in an FASB news release, "The Board decided that it is hard for investors to make sound decisions about combining companies when two different accounting treatments exist for what is essentially the same transaction" .
IAS 22 concerns the methods of accounting for mergers approved by the IASC. It does not allow pooling of interest, except in rare circumstances in which the acquirer cannot be identified . For years, United Kingdom and Canadian companies have complained about the ability of U.S. companies to use pooling, when the standards of their countries prohibited such use. This new standard was expected to be issued late in year 2001.
In another show of support for international standards, the G7 Finance Ministers published a ringing endorsement of the effort following their summit meeting in Cologne, June 18-20, 1999: "We welcome the completion by the International Accounting Standards Committee of its core set of international accounting standards, and we look forward to IOSCO, IAIS and the Basle Committee completing their reviews. We urge all those involved in setting accounting standards to work together so that high-quality accounting standards can continue to be developed and agreed-upon internationally" . There are currently 143 professional accountancy organizations in 104 countries claiming membership in IASC .
Yet another major step toward the realization of international standards occurred in April 1999, when the AICPA, in a letter to IASC Secretary-General Sir Bryan Carsberg, endorsed the effort to establish international accounting standards through the agency of "an independent standard-setting body unaffiliated with any professional organization, country, or national standards setter. Its members would be highly skilled, experienced professionals with varied backgrounds. The body would be overseen by a Board of Trustees that would appoint its members, develop fundraising strategies, and provide general oversight and direction" . The work of such a body would provide immediate benefits: "Prior to the harmonization measures... administrative costs caused by differing auditing and fiscal systems was estimated to be from 10 percent to 30 percent of the costs of the departments involved" .
One way to illustrate the need for international standards is to look at the way five major countries adapt their local GAAPs to use local/native language and/or currency to measure financial income for international transactions (sales) to foreign countries. This is shown in Exhibit 1. Some, like the U.S. and France, retain both the native language and currency; some, like Germany and Switzerland, use local principles but translate these principles into another language; some, like Japan, use local principles but translate these principles and monetary amounts into another language. Some, like the U.S., provide footnote disclosures to reconcile home and local currencies' GAAP income measurements; and, some, like Japan, provide primary statements using both the local, native language and method to measure GAAP but develop secondary, translated financial statements for use in foreign countries. The variations demonstrate the need for a body like the IASC.
It's no wonder, then, that the IASC has become a leading international accounting standards-setting body. But the premise is not new. As many as 11 years ago, Wallace anticipated that the IASC would be influential and attributed its expected success to the:
1. Increasing internationalization of business and finance, which makes global harmonization of accounting and disclosure practices desirable (an example of some of the problems faced is shown in Exhibit 1, which summarizes a few major accounting standards for five major countries);
2. Composite nature of its standards, and its preoccupation with topics of a general nature and its evolutionary strategy; and
3. Absence of a rival organization with keen and prolonged interest in the development and marketing of global accounting standards .
The IASC was, in fact, established back in 1973. The organization received support from the IOSCO (of which the SEC is a member) in 1987  and the World Trade Organization in 1996  to create acceptable standards for multinational securities and other international offerings. In December 1998, after decades of considering the feasibility of global accounting standards, the IASC published a set of core international standards that constitute a comprehensive, generally accepted basis of international accounting. This project's completion is forcing earnest debate over whether the SEC should allow non-U.S. companies to follow international accounting standards (rather than U.S. GAAP), which is an issue that has significant implications for almost everyone involved in U.S. business. As a business is reported, so is it perceived.
IASC vs. FASB
Despite the benefits, achieving worldwide, uniformly accepted international counting standards is difficult -- especially in reconciling the business, professional and regulatory systems, and interests of different cultures. For example, the IASC's and FASB's distinct missions, standard-setting processes and structures can impair their full cooperation, particularly if the IASC is not structured as a self-sustaining and independent decision-making body . Still, the SEC Commissioner believes that the United States should "provide public support for the IASC's efforts to develop acceptable international standards and participate constructively in these efforts, and be prepared to recognize foreign company financial statements prepared in accordance with or reconciled to IASC standards" .
The FASB's domestic focus tends to be fairly detailed when responding to U.S. economic environmental complexities and to sophisticated financial statement users' demands for reliable, high-quality financial information. Since IASC standards are not developed to focus on any particular economic environment, they tend - at least at this stage of development - to be more general. As noted in Exhibit 2, IASC's core standards are actually less restrictive than U.S. GAAP in some cases.
While some elements of this table are of greater importance than others (e.g., "Accounting for Business Combinations" compared to "Classify Interest in the Statement of Cash Flows"), the results show that some fundamental, albeit reconcilable, differences in the two sets of standards persist. Overall, while the two standards are quite similar, the existing differences can generate significantly different financial statements. Nonetheless, if the more specific FASB regulations simply fleshed out more general IASC standards, there might be no problem. Wyatt and Yospe note: "[f] or IASC standards to become acceptable broadly in the world capital markets, they will have to possess a credibility and transparency similar to what U.S. GAAP has achieved" .
Some IASC members argue that the disparity in standards is less than the U.S. supposes. For example, Paul Pacter compared IAS 39 with FASB in the June 1999 Accountancy International and found them "quite similar," an understatement in light of the detailed comparison in the article .
Why IASC Standards Are Far Off
The bottom line is that before achieving all the benefits of international standards, the IASC has much work to do - especially in proving that its standards are written with the same independence, robustness and rigor that are committed to developing U.S. GAAP . In this regard, the SEC has offered three conditions for accepting international standards:
* IASC standards should include a core set of accounting pronouncements that constitute a comprehensive, generally accepted basis of accounting.
* IASC standards should be of high quality; they must result in comparability and transparency, and they must provide for full disclosure.
* IASC standards should be rigorously interpreted and applied .
In other words, IASC standards are acceptable only under the same conditions as FASB standards. This quite understandable, rigorous attitude suggests that acceptance is a long way off. Here are some more reasons why:
1. IASC- and FASB-developed accounting standards differ, despite basic similarities (as shown in Exhibit 2). To help investors, accountants and other accounting professionals differentiate between IASC and U.S. GAAP accounting standards (and perhaps to emphasize the differences), the FASB has prepared a report detailing the standards' similarities and differences. Like other IOSCO members, the SEC can withhold the unanimous support required to implement international standards or any other IASC standard.
2. IASC standards have not yet been mandated, as Wyatt and Yospe note: "Even though the IASC has issued 31 standards since its inception in 1973, as well as a Framework for the Preparation and Presentation of Financial Statements, adherence to these pronouncements is purely voluntary and no provision yet exists for enforcement of the requirements" .
3. The FASB's immediate concern with IASC international accounting standards seems focused more on the procedures used to establish the standards than on the standards themselves. This emphasis on building a foundation for developing standards, step by step, gained impetus in the AICPA response to the IASC Strategy Working Party's invitation to comment. While the AICPA endorsed the intent of the IASC, it counseled slow, orderly development of a structure for creating standards - and a structure functioning somewhat differently from what the IASC envisioned. The AICPA, for example, wants full authority for final approval of standards vested in the developing council, not in the Board. Ironing out these differences of opinion about structure can take a long time.
4. If an accounting standard must satisfy the demand for information in the environment for its intended use, the IASC will have to be structured such that all countries adopting its standards are reasonably assured that the standards established were issued free of bias or favoritism. This is a time-consuming process.
Bayless et al. note other complications of this kind:
(a) Industrial countries' capital markets are far less important as a source of finance than in others, making the relationship of accounting to the efficient functioning of the markets relatively unimportant;
(b) Countries view "full disclosure" as strongly anti-competitive and, as a result, there is great resistance to moving toward a system that emphasizes full disclosure;
(c) Directly tying accounting requirements to income tax laws or other statutes makes change difficult to achieve;
(d) If prudence predominates as an overriding notion, others would view that notion as unduly conservative and too permissive of "managed" earnings;
(e) Countries differ significantly in their attitudes about the extent of management flexibility desirable in financial reporting; and
(f) Some countries have stronger feelings than others about the desirability of retaining their existing policies and/or not being willing to accept policies identified with certain other countries or blocks of countries .
The task of the AICPA's recent response to the IASC is reasonable but daunting:
We believe the IASC should work closely with national standard setters to bring about convergence of national standards and international accounting standards. That effort should focus on identifying areas of accounting and reporting in which significant differences exist between national standards and international accounting standards, and then working with national standard sellers to develop a consistent, high-quality accounting standard that would be issued as both the international standard and the national standard. In developing those standards, convergence should not be interpreted to suggest that national standard setters will simply conform their standards to international accounting standards. Rather, the development of high-quality standards requires an independent process involving all parties to ensure the best accounting and reporting result for both international and national standard sellers .
To require (a) the working out of all differences between national and international standards, and (b) the adoption of identical national and international standards is to set a very long course.
The Future for U.S. GAAP
In the immediate future, the FASB's sole authority to set U.S. GAAP seems safe. According to SEC Chairman Levitt, "The SEC would not jettison U.S. generally accepted accounting principles in favor of international standards" .
On the other hand, there are reasons to try to get on board the IASC train. If the IOSCO allows the use of international accounting standards for cross-border securities listings (which undoubtedly will take considerable time) , foreign firms raising capital in the U.S. will have a clear advantage over domestic firms. That's because these foreign firms compete for resources with the domestic firms, yet they often need to follow less stringent accounting standards. "If the SEC allows foreign registrants to file securities offerings in accordance with IASC's, it will be extremely difficult to require U.S. companies to follow different accounting requirements" . Depending on the SEC's actions, U.S. companies may be afforded the opportunity to follow international accounting standards for securities offerings to avoid placing them at a disadvantage .
Wyatt and Yospe note that U.S. disclosure and filing requirements have made it "less competitive" in the international competition for capital . While the disclosure system for foreign companies seeking entry into U.S. markets is similar to those for domestic companies, the SEC requires foreign registrants to comply with or reconcile to U.S. GAAP. About 850 foreign companies are currently registered with the SEC, and many more probably would follow if they no longer needed to adhere to U.S. GAAP.
Until recently, German companies, for example, did not seek capital in U.S. markets. "No German company is listed on any U.S. stock exchange because of German companies' unwillingness to conform to U.S. accounting standards they believe are too costly and burdensome to follow" . Daimler Benz sought entry into U.S. markets in 1994, which was approved after the company agreed to reconcile its financial statements and schedules prepared in accordance with German accounting principles into U.S. standards . Unlike the U.S. stock exchanges, many foreign countries' securities markets do not have the controlling check of their own rigorous accounting and reporting requirements. For example, third-world countries like Sri Lanka cannot afford to establish costly rule-making bodies and, therefore, will simply make international accounting and auditing standards their "law."
To level the playing field, many firms will want to reduce U.S. financial reporting requirements or increase those that foreign firms use. As shown by its recent announcement about pooling of interest accounting, the FASB may yet yield to such pressures. Part of the dilemma arises from the fact that U.S. capital markets are among the world's most sophisticated, with many owners providing needed capital to finance publicly traded companies. This broad base of investors demands strong financial accounting standards. Less developed economies generally rely on fewer numbers of larger investors (e.g., banks and pension funds) who can obtain obscure information without using such strong financial standards.
Currently, foreign registrants that raise capital in U.S. markets using proposed international standards must reconcile these statements to U.S. GAAP. Otherwise, U.S. investors must incur additional costs to convert the foreign registrants' statements -- and still could make some errors in performing the necessary reconciliations. The system, as it exists, is costly. But the solution - one set of international standards - will also be costly and seems to be far, far away.
The result? To harmonize these divergent principles, the IASC asked its member bodies to see that published financial statements comply with these issues, or disclose the extent to which they do not comply. It also asked members to persuade governments, authorities controlling securities markets, and the industrial and business community that published financial statements to comply with these standards. For example, General Electric Company's Statement of Financial Responsibility section of its 1998 annual report mentions using accounting principles that are consistent with standards issued by the IASC. The FASB could ease the way for international standards by taking IASC standards into serious consideration when setting U.S. standards.
In the long run, since the IASC and the FASB seem to be demanding more rigorous standards, having both entities perform the same function seems counterproductive. At some point, assuming a reconciliation of different business, professional and regulatory interests (which will not be easy), one of these organizations will perhaps be replaced or combined with the other.
(1.) AICPA, Homepage, June 1999.
(2.) Bayless, R., J. Cochrane, T. Harris, J. Leisenring, J. McLaughlin and J.P. Wirtz. "Commentary: International Access to U.S. Capital Markets - An American Accounting Association Forum on Accounting Policy," Accounting Horizons, March 1996, 75-94.
(3.) Bloomer, C. "International Accounting: A Comparison of IASC and U.S. GAAP Standards," The Journal of Lending & Credit Risk Management, March 1997, 23-27.
(4.) Craig, J.L. "An Interview with Arthur R Wyatt," The CPA Journal, December 1996, 26-33.
(5.) Danaher, M. and T. Harris. "Changing the Rules," Financial Executive, March/April 1999, 28-34.
(6.) Duncan, J.R. and R.L. Carleton. "Will Pooling Survive?" CPA Journal, January 1999, 22-27.
(7.) FASB News Release http://www.rutgers.edu/Accounting/fasb/news/nr42199.html.
(8.) Financial Accounting Standards Board, "FASB To Eliminate Pooling of Interest Accounting," FASB News Release, April 21, 1999.
(9.) Fitzgerald, R.D. "International Accounting and Reporting: Where in the World Are We Headed?" Price Waterhouse Review, Spring 1983, 16.
(10.) Freund, W.C. 'That Trade Obstacle, The SEC," The Wall Street Journal, August 27, 1993, A2.
(11.) Frost, CA and F. Chu. "Do U.S. Firms Benefit from Listing on Overseas Equity Markets?" Dartmouth College and Boston University working paper, July 1, 1998.
(12.) Gould, J.D. "A Second Opinion on International Accounting Standards," The CPA Journal, January 1995, 50-52.
(13.) Hegarty, J. "Accounting for the Global Economy: Is National Regulation Doomed To Disappear?" Accounting Horizons, December 1997, 75-90.
(14.) IASC, Homepage, June 1999.
(15.) Jayson, S. "IFAC's Traveling Salesmen," Management Accounting, October 1986,22.
(16.) "Calls Heard for More Independent IASC," Journal of Accountancy, June 1999, 11-12.
(17.) "SEC and FASB Remain Cautious About International Standards," Journal of Accountancy, March 1997, 16.
(18.) Lochner, P.R. "The Role of U.S. Standard Setters in International Harmonization of Accounting Standards," Journal of Accountancy, September 1991, 108-109.
(19.) Moulin, DJ. and M.B. Solomon. "Practical Means of Promoting Common International Standards," The CPA Journal, December 1989, 38-43.
(20.) Multinational Business Review, 7(1), Spring 1999,1-12.
(21.) Pacter, P. "International Accounting Standards: The World's Standards by 2002," CPA Journal, July 1998, 14-21.
(22.) Sutton, M.H. "Financial Reporting in U.S. Capital Markets: International Dimensions," Accounting Horizons, June 1997, 96-102.
(23.) Wallace, R.S.O. "Survival Strategies of a Global Organization: The Case of the International Accounting Standards Committee," Accounting Horizons, June 1990, 1-22.
(24.) Wyatt, AR and J.F. Yospe. "Wake-Up Call to American Business: International Accounting Standards Are on the Way," Journal of Accountancy, July 1993, 80-85
EXHIBIT 1. COMPARING GENERAL GAAP CRITERIA AMONG FIVE COUNTRIES * U.S. Japan Germany France Financial Statements retain native language and currency. X X Financial Statements prepared using local principles but underlying principles translated into another language. X Financial Statements prepared using local principles but underlying principles and monetary amounts translated into another language. X Financial Statements include footnote on basis of GAAP of borne country to GAAP of audience of interest. X Primary Financial Statements prepared for local audiences in native language and using local principles. Secondary financial statements prepared for audiences in other countries to include underlying principles, language and monetary translations of the other country. X Switzerland Financial Statements retain native language and currency. Financial Statements prepared using local principles but underlying principles translated into another language. X Financial Statements prepared using local principles but underlying principles and monetary amounts translated into another language. Financial Statements include footnote on basis of GAAP of borne country to GAAP of audience of interest. Primary Financial Statements prepared for local audiences in native language and using local principles. Secondary financial statements prepared for audiences in other countries to include underlying principles, language and monetary translations of the other country. (*)Adapted from such sources as: Gray, S.J. and G.K. Meek. "Globalization of stock Markets and Foreign Listing Requirements: Voluntary Disclosured by Continental European Companies Listed on the London Stock Exchange." Journal of International Business Studies, Summer 1989, 315-336; and Financial Accounting Standards Board (FASB). "The IASC - U.S. Comparison Project: A Report on the Similarities and Differences Between IASC Standards and U.S. GAPP." Edited Carrie Bloomer, 1996, 5. EXHIBIT 2. SOME DIFFERENCES BETWEEN U.S. GAAP AND IASC ACCOUNTING STANDARDS Accounting Issue U.S. GAAP Accounting for Leases Capitalization requires transfer of substantially all risks and rewards of ownership to lessee. Accounting for Development Costs Expense Research and Development costs as incurred. Valuation: Property, Plant Record assets at historical costs, and Equipment ignoring market value. Classify Interest in Statement of Cash Flows Classify interest paid and received as operating cash flows. Inventory Pricing Must write down the carrying amount of inventory to the lower of cost or market; cannot reverse prior write- downs. Disclosing Risks and Provide explicit guidance and examples Contingencies to make such disclosures. Changes in Foreign Exchange Rates Requires accounting for forward exchange contracts and hedging of foreign exchange risks. Accounting for Business Can use purchase or pooling method, but Combinations must amortize goodwill over a period up 40 years. (Note: The FASB may soon prohibit using the pooling method). Financial Instruments: Recognition and Measurement SFAS No. 133 requires firms to report all derivatives at their fair market value as assets or liabilities on their balance sheets. Segment Reporting SFAS 131 requires publicly traded firms to report segment information by distinct geographic area and reliance on major customers, generally using a 10% "materiality" threshold. Accounting Issue IASC Accounting for Leases Determination of capital or operating leases is more subjective depending on the transaction's "substance." Accounting for Development Costs Expense research costs us incurred; however, development costs are capitalizable if certain criteria are met. Valuation: Property, Plant Entities can periodically choose to and Equipment revalue their property, plant and Classify Interest in equipment to their fair market value. Statement of Cash Flows Classify interest and dividends paid as financing cash flows, and classify dividends received as investing cash flows. Inventory Pricing Write down book value of inventory when events indicate that its value/utility is less than cost; must reverse prior written-down amounts when new circumstances emerge. Disclosing Risks and Does not address unasserted claims and Contingencies assessments; provides no guidance on the content of disclosures. Changes in Foreign Exchange Rates Does not address accounting for forward exchange contracts, but hedge accounting is allowed. Accounting for Business Places more restrictions on using the Combinations pooling method; must amortize goodwill over a 5-to 20-year period. Financial Instruments: IAS 39 requires recording derivatives at Recognition and Measurement cost and subsequently re-measuring them value, except for loans and receivables not held for trading; other, fixed maturity instruments (e.g., debt securities) that it plans to hold to maturity; and financial assets with no "reliable" market price - all of which are measured at amoritzed cost. Segment Reporting IAS 14 requires public entities to report information along product/service and geographical lines, generally defining segments as organizational units reported separately to the corporate board and CEO. (*)References to all international accouting standards shown were obtained on-line from the Web Site for the IASC: www.iasc.org.uk. Comparable standards for U.S. GAAP were obtained using applicable opinions and statements.
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|Author:||Houston, Melvin; Reinstein, Alan|
|Publication:||Review of Business|
|Date:||Mar 22, 2001|
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