How-to guide: The appointed representatives regime explained - what it means in practice (UK)

Updated as of: 04 February 2025

Introduction

This guide will assist in-house counsel and private practice lawyers understand the rules and practice with respect to the appointed representatives regime in chapter 12 of the FCA Handbook’s Supervision manual (SUP). Section 39 of the Financial Services and Markets Act 2000 (as amended) (FSMA) exempts an appointed representative (AR) from the need to be authorised themselves, as they instead rely upon authorised firms who they represent. This has the advantage of the authorised representative saving time and expense both initially and on an ongoing basis and avoids the regulatory capital requirements associated with authorisation.

This guide covers:

  1. Who is an appointed representative and what do they do?
  2. What due diligence needs to be done before appointing an appointed representative?
  3. The notification requirements to the FCA
  4. The contractual arrangements that need to be in place between the principal firm (the principal) and the appointed representative
  5. The continuing obligations of principals with appointed representatives
  6. The process for terminating the contract of an appointed representative

This guide can be used in conjunction with the following How-to guides: The general prohibition – beware the consequences of breach, Introduction to the UK financial services regulators and Checklists: Pre-appointment checks to consider when selecting an appointed representative, Preparing an application to the FCA or the PRA for a Part 4A permission, Preparing an application to vary a Part 4A permission at the request of a firm and Preparing an application to cancel a Part 4A permission at the request of a firm.

Section 1 – Who is an appointed representative and what do they do?

Section 19 FSMA provides that a person must not carry on a regulated activity in the UK, or purport to do so, unless they are an authorised or exempt person. This is known as the general prohibition. Examples of regulated activities include accepting deposits, effecting and carrying out insurance contracts or managing investments. These are set out in the Financial Services and Markets Act (Regulated Activities) Order 2001 (RAO). For a full list of regulated activities, specified investments and applicable exemptions please refer to the RAO. See How-to guide: The general prohibition – beware the consequences of breach.

Under section 39 FSMA, a person who is an AR is an exempt person – see section 1.1 below.

1.1 Understanding the role of an appointed representative

ARs act for authorised firms (ie, firms directly authorised by the Financial Conduct Authority (FCA) or the Prudential Regulation Authority (PRA)) and perform regulated activities. They can be individuals, companies or partnerships and are exempt from authorisation under section 39(1) FSMA where the AR:

  • has a contract with an authorised firm (known as the principal) which contains certain essential terms (see section 4 below);
  • performs a defined set of business activity under the contract; and
  • performs activities for which their principal has assumed responsibility (in writing).

However, under section 39(1ZA) FSMA an AR is not exempt where the principal is a firm or intermediary as listed below.

  • An investment firm, a qualifying credit institution, or a firm that has a Part 4A permission to carry on regulated activities as an exempt investment firm within the meaning of regulation 8 of the Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017 and so far as the business for which the principal has accepted responsibility is investment services business, unless the AR is entered on the applicable register.
  • An investment firm or a qualifying credit institution, and so far as the business for which the AR’s principal has accepted responsibility is selling, or advising clients on, structured deposits, unless the AR is entered on the applicable register.
  • A mortgage intermediary, and so far as the business for which the AR’s principal has accepted responsibility is of a kind specified in article 25A RAO (arranging regulated mortgage contracts), article 36A RAO (credit broking), article 53A RAO (advising on regulated mortgage contracts) or article 53DA RAO (advising on regulated credit agreements the purpose of which is to acquire land), and relates to mortgage agreements entered into, on or after 21 March 2016 (unless the AR meets the requirements of section 39 (1BB) FSMA (ie, is entered on the FCA record), the principal has the requisite Part 4A permission and is not a tied mortgage intermediary).

1.2 Activities that can be undertaken by the appointed representative

ARs may be exempt from the regulated activities listed in regulation 2 of the FSMA (Appointed Representative) Regulations 2001 (Appointed Representative Regulations) including:

  • arranging deals in investments where the arrangements are for, or with a view to, transactions relating to securities or contractually based investments (article 25 RAO);
  • safeguarding and administering investments, where the activity consists of arranging for one or more other persons to safeguard and administer assets (article 40 RAO);
  • advising on investments (article 53 RAO); or
  • agreeing to carry on the activities listed above.

Note too that the FCA’s Perimeter Guidance Manual (PERG) 5.13.3G sets out business for which an AR is exempt in relation to insurance distribution activities, and SUP12.2.7G provides further clarification as to the full list of specified activities from which an AR may be exempt.

Regulated claims management activity is not a type of business for which an AR may be exempt (see SUP 12.2.7G(4)).

Section 2 – What due diligence needs to be done before appointing an appointed representative?

As principals are responsible for the regulated activities of their ARs, it is important that a principal has sufficient oversight of them. Principals are responsible for conducting pre-appointment checks and due diligence prior to appointment and are expected to keep records of each of their ARs (including the name of the AR and a copy of the original contract). See SUP 12.9.

2.1 Checks to undertake before the appointment

Before appointing an AR, the principal must conduct the following checks on them in line with SUP 12.4.

  • Ensure that the regulated activities to be performed by the AR under the terms of its appointment are amongst those the principal itself is authorised to perform or are excluded from being regulated activities when performed by the principal and keep this under periodic review, for example because:
    • they fall within an exclusion such as article 28, RAO (Arranging transactions to which the arranger is a party); or
    • they constitute consumer buy-to-let (CBTL) business and the principal is a CBTL firm.
  • Ensure that the appointment does not prevent the principal from meeting and continuing to meet the threshold conditions.
  • Ensure that the AR:
  • Make sure that the directors, partners, owners and managers of the AR are competent, capable and have:
    • appropriate experience, knowledge, skills and training in relation to the activities and business carried out, or to be carried out, on behalf of the principal; and
    • the necessary time to properly perform the tasks and functions for which they are, or will be, responsible.
  • Check that the principal has adequate systems and controls over the AR’s regulated activities for which it is responsible along with the resources to monitor and enforce compliance with the relevant requirements.
  • Make an assessment against the principal’s risk management framework that the AR’s activities won’t result in undue risk of harm to consumers or market integrity considering the nature of those risks and the likely impact should those risks materialise (in line with SUP 12.4.4CG).

See Checklist: Pre-appointment checks to consider when selecting an appointed representative.

2.2 Consumer Duty and appointed representatives

The Consumer Duty (which came into force on 31 July 2023) for existing products and services requires firms to deliver good outcomes for retail customers and provide evidence that these outcomes are being met. The Consumer Duty sets a higher standard of care (in principle 12) that firms should give to consumers in retail financial services markets in line with principle 6 (to act in best interests of customers and treat them fairly) and complements and enhances the ‘treat customers fairly’ (TCF) regime. In PS22/11, the FCA noted that the Consumer Duty directly impacts the AR regime. The Consumer Duty Finalised Guidance states principals are required to oversee the actions of their ARs, and principals should keep the Consumer Duty and related rules and guidance in mind. They must be able to demonstrate they are consistently able to meet their regulatory requirements so that customers who receive products and services from the AR are afforded appropriate protection (eg, being treated fairly and buying products appropriate to their needs). Where an AR is acting under the authority of its principal and within scope of the AR agreement, the FCA will treat failure to comply with the Duty as a breach of the Duty by the principal. See How-to guide: The FCA’s Consumer Duty: putting the needs of customers first and Checklist: Embedding the Consumer Duty: practical considerations.

Section 3 – The notification requirements to the FCA

A principal’s notification requirements to the FCA are contained in SUP 12.7 and include notification in the following circumstances:

  • appointment of an AR;
  • a change in the information previously provided to the FCA (eg, change in AR details);
  • if a principal intends to start acting as a regulatory host;
  • termination of an AR appointment; or
  • in the event of a significant failure of the firm’s systems and controls for overseeing its ARs.
  • the AR’s name and any trading name under which it carries on a regulated activity;
  • if the AR is a company, its company registration number;
  • a description of the nature of the regulated activities that the AR will be permitted or required to carry on and that the principal intends to accept responsibility for them;
  • any restrictions imposed on the regulated activities for which the principal intends to accept responsibility;
  • if the AR is not an individual, the names of the individuals responsible for managing the AR’s business, so far as it relates to insurance distribution activity;
  • if the AR will carry on insurance distribution activities, the name of the individual to be named as the AR’s primary point of contact on the Financial Services Register;
  • an estimate of the AR’s expected level of revenue during the first year of its appointment by reference to its regulated activities and non-regulated activities;
  • information on the nature of any non-regulated activities of the AR;
  • any group eg, a parent or subsidiary undertaking of which the AR is a part;
  • the principal reason for the appointment;
  • information about the financial relationship between the principal and the AR;
  • whether the AR will provide services to retail clients;
  • whether the AR was previously an AR of a different principal; and
  • information on any arrangements for seconding or contracting individuals from the AR to the principal for the purposes of conducting portfolio management or dealing activities.

To notify the FCA you should complete and submit the documents referred to below via the FCA’s online notification and application system known as the Connect system. Further reporting requirements are set out in section 5 (see continuing obligations) below.

3.1 Appointment of appointed representative

The principal must notify the FCA upon recruitment of a new AR no later than 30 days before the AR starts performing regulated activities for the principal. They must also notify any changes to the ARs activities at least 10 days before these take effect.

SUP 12.7.2G provides that the following details are required:

The principal must also complete and submit an accompanying Form A, individual application (CF1) or (CF30) (as applicable) simultaneously. This enables the FCA to conduct checks on the prospective AR appointment and to assess the suitability of the individual.

Upon receipt of notification the FCA will update the principal’s financial services register details with respect to the AR and confirm this by email.

3.2 A change in the information previously provided to the FCA

For most changes of information provided to the FCA regarding AR appointments, the principal must complete and submit the form in SUP 12 Annex 4R within 10 business days of that change being made or, if later, as soon as the principal becomes aware of that change (SUP 12.7.7R). However, if the category of regulated activities that the AR is permitted or required to carry on and for which the principal accepts responsibility is the change, then the above form must be submitted at least 10 days before the change takes effect.

Examples of changes that should be notified to the FCA include those in relation to insurance distribution activities. These changes must be notified in writing to the FCA by the principal where:

  • the scope of the AR’s appointment is extended to cover insurance distribution activities for the first time; and
  • the AR is not included on the Financial Services Register as carrying on insurance distribution activities in another capacity; or
  • the scope of appointment ceases to include insurance distribution activity.

In addition, a firm must also notify the FCA as soon as the principal has reasonable grounds to believe that any of the following conditions are not satisfied, or are likely not to be satisfied, in relation to any of its ARs:

  • the conditions in SUP 12.4.2R relating to matters including the threshold conditions, close links, suitability and solvency;
  • the conditions in SUP 12.4.6R relating to the suitability of an introducer AR (IAR) – IARs carry on activities solely for the purpose of promoting, and introducing consumers to their principal (or other members of the principal’s group); for example, a dentist may act as an IAR to inform a patient about dental insurance policies available from an authorised insurance firm;
  • the conditions in SUP 12.4.8AR relating to an AR carrying on insurance distribution activities;
  • the conditions in SUP 12.4.10AR or SUP 12.4.10BR relating to ARs carrying on MCD credit intermediation activity.

In the event of the need to notify the FCA with respect to any of the above points, a firm must complete and submit to the FCA the form in SUP 12 Annex 4R and state:

  • the steps it proposes to take to rectify the matter; or
  • the date of termination of its contract with the AR (SUP 12.7.8).

3.3 Intention to start acting as a regulatory host

A principal must notify the FCA if it intends to begin acting as a regulatory host (SUP 12.7.9AR) at least 60 days before it begins to offer such services.

A regulatory host (as per the FCA Glossary) is a principal that offers or provides a service:

  • by which unauthorised persons, whether or not in the same group as the principal, may become ARs of the principal;
  • for remuneration with a view to profit; and
    either
  • the principal does not carry on any regulated activities other than through its ARs; or
  • the regulated activities carried on by one or more of the principal’s ARs are not connected to any regulated activity undertaken by the principal other than through its ARs.

When notifying the FCA, the principal may include information about the service that it intends to offer.

See Regulatory hosting services which provides guidance from the FCA for principal firms operating as regulatory hosts.

3.4 Termination of the appointment

If either the principal or the AR wishes to terminate the appointment (or to amend it so that it no longer meets the requirements contained or referred to in SUP 12.5), the principal must complete and submit to the FCA the form in SUP 12 Annex 5 R (Appointed representative termination form) in accordance with the instructions on the form and no more than 10 business days after the date of the decision to terminate or so amend the contract or, if later, as soon as it becomes aware that the contract is to be or has been terminated or amended (SUP12.8.1R). Principals should ensure adequate record-keeping procedures are in place to have a clear audit trail of all decisions taken and forms filed. In accordance with SUP 12.9.2, a firm must retail records for at least three years from the date of termination or the amendment of the contract with the AR (other than in respect of tied agents, when the records must be retained for five years).

A principal should consider terminating their contract with an AR in line with SUP 12.6.1R if any of the following scenarios occur.

  • There are issues with the AR that have not been resolved satisfactorily or within a reasonable period. This may include where the AR has agreed to resolve known issues, but it has not met the principal’s standards or expectations for remediation or where the principal considers the proposed remediation would risk the firm breaching applicable rules.
  • The AR is unable to satisfactorily explain unusually high rates of senior management turnover.
  • The principal becomes aware that the AR is carrying on regulated activities beyond its regulatory permissions.
  • The AR is found to have intentionally misled clients or potential clients in any way.
  • Any of the AR’s senior management with responsibility for, or involvement in, activities carried on within the scope of the AR’s appointment are dismissed based on gross misconduct.

More generally, SUP 15 .3 provides a number of scenarios where a principal must notify the FCA immediately if certain events occur, such as a significant breach of any FCA principles or any matter which could have a significant adverse impact on the principal’s reputation (eg, the AR has engaged in criminal activity). In particular, SUP 15.3.8G(2) sets out the FCA’s expectation that a principal will notify the FCA in accordance with PRIN 11 (ie, to ensure that matters are properly and clearly communicated to the regulator) in the event of a significant failure of the principal’s systems and controls for overseeing its ARs.

Section 4 – The contractual arrangements that need to be in place between the principal and the appointed representative

To comply with section 39 FSMA, principals must sign a written agreement – containing certain required terms – with their ARs. The requirements are set out in SUP 12.5 in line with those of the Appointed Representatives Regulations 2001. These require the contract to contain a provision enabling the principal to clarify the scope of the AR’s activities under the agreement. It is good practice to keep these terms under review to ensure the AR is acting within scope of what the principal intended and to ensure compliance with their regulatory responsibility.

4.1 Contractual arrangements in writing

A principal must state in writing that it takes responsibility for the actions of its ARs. The principal is responsible, to the same extent as if it had expressly permitted it, for anything done or omitted by the AR in carrying on the business for which it has accepted responsibility (section 39(3) FSMA). Anything that an AR has done or omitted regarding business for which the principal has accepted responsibility is to be treated as having been done or omitted by the principal (section 39(4) FSMA). However, in determining whether the principal has committed an offence, the knowledge and intentions of an AR are not attributable to the principal, unless in all the circumstances it is reasonable for them to be so attributed (section 39(6) FSMA).

4.2 Prescribed content of the agreement

SUP 12.5.3 – 12.5.6 sets out more details of the prescribed content of the agreement such as clauses:

  • to ensure the AR’s activities don’t go beyond those for which the principal itself has authorisation to undertake;
  • to ensure the AR cooperates with the FCA;
  • to ensure the AR complies with the FCA’s rules and the requirements of FSMA;
  • to require the AR to provide the principal’s auditors with access rights; and
  • to require the AR to provide the principal with information enabling the principal to properly oversee the activities of the AR.

4.3 Ability to terminate

A principal should have the ability to terminate the contract with its AR in the circumstances set out in SUP 12.6.1R(2). See also section 3.4 above. However, such a termination provision should not be automatic ( SUP 12.8.3R(1)) and SUP 12.5.4G also require that the principal can terminate the contract if the principal determines that it can no longer effectively oversee the activities of the AR.

Section 5 – The continuing obligations of principals with appointed representatives

5.1 Supervision and monitoring compliance

Acting as a principal for an AR is burdensome on the principal and requires the principal to supervise and monitor the activities of the AR. The principal takes regulatory responsibility for the AR and must ensure that it meets all regulatory requirements. The level of monitoring should be reflective of the level of business risk posed by having an AR. The responsibility for the control and monitoring of the activities of ARs rests with the principal’s senior management (SUP 12.6.7G). The monitoring requirements for ARs are set out in SUP 12.6. In summary these include those listed below.

  • The principal should ensure that if, at any time, the principal has reasonable grounds to believe that the conditions for the appointment of an AR relating to certain matters (including complying with the threshold conditions) are not satisfied, or not likely to be satisfied, it takes immediate steps to rectify the matter or terminate its contract with the AR (SUP 12.6.1R).
  • The principal must review, at least annually, the financial position of its ARs to ensure they don’t experience financial problems and take necessary action such as suspending or terminating the appointment if required (SUP 12.6.2-4G).
  • The principal must ensure that the ARs don’t hold client money, unless the AR is aninsurance intermediaryin which case the money must be held in accordance with the FCA’s Client Asset Sourcebook (CASS) rules – CASS 5.5.18 R to CASS 5.5.23 R (which include provision for periodic segregation and reconciliation) and (SUP 12.6.5R);
  • The principal should ensure that the ARs do not go beyond the scope of their appointment (SUP 12.6.6R).
  • The principal must ensure that if a principal delegates tasks to an AR, it applies appropriate safeguards for reasons including to avoid conflicts of interest and applies enhanced monitoring to the task including discharging oversight obligations in SYSC 3.2.3G (SUP 12.6.5BG).
  • The principal is required to submit applications for the approval as an approved person of any AR who is an individual performing a controlled function or any person who performs a controlled function under an arrangement entered into by any of the principal’s ARs (SUP 12.6.9G).
  • The principal must ensure that its ARs meet training and competence requirements (SUP 12.6.10G). These ensure that the AR and those employed or appointed by them meet the rules and guidance in the FCA’s Senior Management Arrangements, Systems and Controls (SYSC) see SYSC 3 and SYSC 5 as well as the Training and Competence sourcebook of the FCA Handbook.
  • The principal should monitor compliance with the terms of the contract between the principal and the AR (SUP 12.6.11AR).
  • In line with a principal’s obligations under SUP 12.4.2R to ensure it puts adequate controls and resources in place to oversee an AR it has appointed, SUP 12.6A.2 requires a principal to undertake an annual written review (retained for six years) to record how it is meeting the requirements in SUP 12.6A. The review will cover items such as:
    • whether the AR remains solvent and suitable;
    • the fitness and propriety of the AR’s controllers, directors, partners, proprietors and managers and their ability to carry out the regulated activities under the contract with the principal; or
    • the adequacy of the principal’s controls over, and resources for monitoring and enforcing compliance of, the AR.
  • A principal must also under SUP 12.6A.3R carry out a written review (retained for six years) of the matters covered in the annual review on an AR when:
    • the AR changes its business model (including its target market);
    • the scope of the AR’s appointment is expanded to include one or more additional regulated activities;
    • the AR changes, more than once in a 12-month period, any of its senior management in a particular role with responsibility for, or involved with, the activities being carried on within the scope of its appointment;
    • the AR is appointed by an additional principal; or
    • the principal identifies a significant increase in the number of complaints it receives about the AR.
  • In carrying out the reviews set out above the principal should have regard to the guidance on assessing the matters covered by the review in SUP 12.4. Each review should be undertaken by one or more individuals with an appropriate level of knowledge and experience at the principal’s firm. The principal should ensure that any significant issues that arise because of a review are escalated for consideration by its governing body where appropriate. In particular, if the issues give rise to risks of harm to consumers or market integrity (SUP 12.6A.5G).
  • Annually, a principal must conduct a written review (retaining it for six years) of the way it meets its SUP 12 obligations and the material deficiencies or concerns it has with a view to remedying them (SUP 12.6A.6R).
  • There are three main reporting requirements applicable to principals:
    • annual reporting of complaints and revenue attributed to each of the principal’s ARs using form REP025 within 60 business days of their accounting reference date (ARD). The FCA has provided a set of FAQs to help completing form REP025.
    • Check, amend and confirm principal firm details annually. From 1 December 2023, you also need to confirm details for ARs (and IARs) within 60 business days of your ARD. This is completed via the Connect portal by selecting ‘start new application’ and then ‘update or attest to your firm details.’
    • Principals must also notify the FCA if they recruit a new AR within certain timeframes – see section 3.1 above.
    • The FCA may also make ad hoc data requests such as those under s165 rules as part of their wider supervisory work.

See FCA webpage How to report Appointed Representatives Data – information for principal firms.

Improving oversight of AR is a key priority for the FCA in their 2024/5 Business Plan and the FCA will continue to target its resources through deeper analysis of existing data and using improved data covering all ARs and continue to strengthen scrutiny and engagement with principal firms as they appoint ARs. The FCA reminds firms that it will continue its assertive supervision of high-risk principals through its regulatory tools and by taking appropriate enforcement action.

On 6 September 2024, the FCA published a review of how principals are embedding the new oversight rules for ARs. The analysis involved a telephone survey with 251 principals and in-depth assessments of 23 firms. The findings provided examples of good practice together with areas for improvement on:

  • completing self-assessments and annual reviews
  • AR monitoring and oversight
  • AR onboarding and termination

This guidance is relevant for firms with ARs or for those considering the appointment of an AR.

See also FCA webpage – Principal firms who have Credit Broking permissions: Good practice and areas for improvements. This guidance could also be used by other firms with ARs conducting other types of regulatory activity for reference.

Firms with overseas appointed representatives (OARs) should refer to the FCA webpage which provides information on the challenges, expectations and practical considerations for principal firms.

The importance of robust supervision of ARs and ensuring that AR agreements are clearly drafted has been highlighted recently when the Court of Appeal refused a principal to escape liability for the conduct of their AR in the case of KVB Consultants Limited v Jacob Hopkins McKenze Limited (2024) EWCA Civ. 765. An appeal to the Supreme Court is expected.

Principals should ensure that AR agreements are clearly drafted from the outset considering the risks of ‘how’ an AR carries out regulated activities and not just ‘what’ activities are being performed. Consider the level of professional indemnity insurance coverage (for the respective parties) and put practical systems and controls in place to monitor, supervise and audit AR activity. Keep records and document all processes.

In a letter dated 6 December 2024, Nikhil Rathi, FCA Chief Executive, reiterated the risks of harm arising when principals fail to properly oversee their AR. Addressing the House of Commons Treasury Committee in relation to the December regulatory perimeter report, he noted that the FCA is prepared to engage further with the Treasury on appropriate next steps.

Section 6 - The process for terminating the contract of an appointed representative

If either the principal or the AR notifies the other that it proposes to terminate the AR contract (or to amend it so that it no longer meets the required terms of the contract under SUP 12.5), the principal must complete and submit the appointed representative termination form in Annex 5 to SUP 12to the FCA using the FCA’s Connect system, no more than 10 business days after the date of the decision to terminate or so amend the contract or, if later, as soon as it becomes aware that the contract is to be or has been terminated or amended (SUP 12.8.1R).

Further details of the FCA notification requirements are set out in section 3.4 above.

6.1 Steps to be taken upon termination

If a contract with an AR is terminated, or if it is amended in a way which gives rise to a requirement to notify the FCA under SUP 12.8.1R, the principal must take all reasonable steps to ensure that:

  • if the termination is by the principal, the AR is notified in writing before, or if not possible, immediately on, the termination of the contract and informed that it will no longer be an exempt person for the purpose of FSMA.
  • outstanding regulated activities and obligations to customers are properly completed and fulfilled either by itself or another of its ARs;
  • where appropriate, clients are informed of any relevant changes;
  • all the other principals of the AR of which the principal is aware are notified; and
  • if the termination results in the wind down of relevant business, this is, or will be, undertaken in an orderly way. See SUP 12.8.3R.

The principal must also notify the FCA of any approved person who no longer performs a controlled function under an arrangement entered into by the principal or its AR (SUP 12.8.4G).

Additional resources

FCA webpage:

Improving the Appointed Representatives regime through greater use of data
Principals and appointed representatives
How to report Appointed Representatives data – information for principal firms
Overseas appointed representatives
Appointed Representatives help: Connect
Considerations for Principals who have Appointed Representatives or Introducer Appointed Representatives (ARs) – FCA news alert (November 2017)

Related Lexology Pro content

How-to guides:

The general prohibition – beware the consequences of breach
Introduction to the UK financial services regulators

Checklists:

Pre-appointment checks to consider when selecting an appointed representative
Preparing an application to the FCA or the PRA for a Part 4A permission
Preparing an application to vary a Part 4A permission at the request of a firm
Preparing an application to cancel a Part 4A permission at the request of a firm

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