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Water Cooler Wisdom – First Quarter 2014

April 16th, 2014

Water Cooler Wisdom 1Q12Water Cooler Wisdom 1Q12A great deal happened in the world during the first quarter of 2014. The ECB may be pursuing quantitative easing, the Federal Reserve continues to send mixed messages about tapering, China is slowing down, the U.K. is set to grow the faster than any other advanced nation, and Gwyneth and Chris have split…or have they? According to the International Monetary Fund, the global growth outlook is positive, although the recovery is somewhat shaky and uneven. While there is a widespread fear of deflation worldwide, the hawks still stand by their position that uncontrolled inflation may still be in the future. In this economic environment, it is necessary to sift through a significant amount of noise to see the real economic picture.

The United States economy continues to grow but it is not going gangbusters. The polar vortex, along with the seemingly unending winter weather in the Eastern part of the United States, slowed economic growth during the first quarter of 2014. Regional economic indicators, including vehicle sales and employment, increased during the somewhat more temperate month of March, undoubtedly leaving residents and businesses looking forward to sunnier weather ahead. The unemployment rate remained unchanged at 6.7% and GDP increased by 2.6%. According to some analysts, the current inflation rate of 1.6% (see: Consumer Price Index) represents a lower bound to US inflation, The Federal Reserve continues to be committed to tapering but it seems somewhat reluctant to say ‘when’ due to continued concern about inflation. While the market will likely continue to experience spasms at every word Janet Yellen breathes, it may be more business as usual for the Fed in the near future.

Equities (see: Returns and Valuations by Style) have increased slightly but remain in what some would consider normal territory. It is important to note, however, that some sectors of the equities market have increased by 275.2% since the market low in March 2009. Overall, the market growth is not enough to risk substantial changes in inflation or interest rates but also not slow enough to decelerate overall growth. Essentially, it’s smooth-sailing.

As of April 9, 2014, the Office of the Comptroller of the Currency, the Federal Reserve and the FDIC approved a new rule requiring the eight largest U.S. banks to greatly increase their leverage ratio (essentially, they need to hold more capital). This rule is in response to the increased emphasis on macro-prudential regulation and the fact that many are still shaking in their boots from the aftershocks of the Global Financial Crisis. This rule will help to ensure that systemically important banks have the capital to lend in any economic environment, guarding against a credit contraction if market conditions were to negatively change. This may mean easier lending for smaller banks whose leverage ratio is not quite as high but since this rule does not take effect until 2018, the real results are yet to be seen.

Since the start of 2014, the discussion of unconventional monetary policies has been more, well, unconventional. The European Central Bank may be in the process of become policy bedfellows with the Federal Reserve, Bank of Japan and Bank of England by implementing quantitative easing as a monetary policy tool. The ECB has been considering this as well as negative interest rates to protect from decreasing inflation. These negative interest rates would affect deposits at the ECB since these banks would be required to actually pay to park their money. The monetary policy motive for this would be that these banks, avoiding the extra ‘tax,’ would rather lend out their money to the private sector. This would spur growth and ideally protect against the low inflation. Quantitative easing is a little trickier for the Eurozone. Whereas the US and UK can purchase bonds from their own individual markets, the ECB has 18 countries to choose from. Buying from France could give an unfair advantage, whereas purchasing bonds from Greece could throw Germany into an uproar. Some economists suggest that the ECB purchase Treasuries from the Fed to help unwind our rounds of quantitative easing. What a ‘taper tantrum’ that might cause.

While the economy is improving, there is still a long road ahead. However, given that holding cash yields a 0% return, it is still an attractive time to invest, regardless of the current interest rate climate (see: Asset Class Returns). So, go out, get invested, become diversified and have a wonderful spring.

Laurel Mazur is Castle Rock Investment Company’s Research Associate. Laurel Mazur is a graduate student at the University of Denver pursuing a dual Master’s degree in Economics and Global Finance, Trade, and Economic Integration. Most of her research and writing focuses on international monetary economics and central banking. She can be reached at


Water Cooler Wisdom – 4th Quarter

January 15th, 2014

Everyone should be delighted by the balances on their quarterly account statements and we hope the values hold steady throughout 2014. When including price changes and dividends:

  1. Standard & Poor’s 500 Index gained 32.39%.
  2. Nasdaq Composite Index gained 40.12% Russell 2000 Index gained 38.82%

As we know, the market runs ahead of the economy and most economists are optimistic for the coming year. In the J.P. Morgan charts that follow, you’ll see that the current price to earnings ratio for domestic stocks have exceeded the twenty-year average with the exception of large cap blend and growth. See “Returns and Valuations by Style.” Traders are looking for earnings growth to support last year’s market rise. See “Sources of Total Return.”
Consumers are positioned well if interest rates rise slowly and avoid dramatic shifts that affect home sales activity and overall consumer net worth. See “Consumer Finances.” Since there appears to be a consensus among experts, we have included Bob Doll’s predictions for the year ahead. He is the Chief Equity Strategist at Nuveen and former top strategist at BlackRock, the world’s largest asset manager.

  1. The U.S. economy grows 3% as housing starts surpass one million and private employment hits an all-time high
  2. 10-year Treasury yields move toward 3.5% as the Federal Reserve completes tapering and holds short-term rates near zero (see “Fixed Income Yields”)
  3. U.S. equities record another good year despite enduring a 10% correction
  4. Cyclical stocks outperform defensive stocks
  5. Dividends, stock buy-backs, capex, and M&A all increase at a double-digit rate
  6. The U.S. dollar appreciates as U.S. energy and manufacturing trends continue to improve (see “Manufacturing Momentum”)
  7. Gold falls for the second year and commodity prices languish
  8. Municipal bonds, led by high yield, outperform taxable bond counterparts
  9. Active managers outperform index funds
  10. Republicans increase their lead in the House but fall short of capturing the Senate

The risks to Mr. Doll’s predictions were highlighted in a January 6th, 2014 article in the Wall Street Journal posed as five questions:

  1. Will businesses finally shed their caution? (See “Corporate Profits and Leverage”)
  2. Will Washington’ s tentative truce continue?
  3. Will the Fed’s path out of bond buying get bumpy?
  4. Will the housing adjust easily to higher interest rates? 5. Will the rest of the world cooperate?

If you’ve watched the news over the past five years, it seems naïve to withhold doubt for 2014, but deep down…don’t you want to believe?

View Entire Document with Charts

Water Cooler Wisdom – Third Quarter 2013

October 23rd, 2013

During the last week in September, I was having another conversation about the economic ailments of the global economy with a long-time client. It seems that these conversations always turn depressing, so I promised him that I would write a cheerful commentary this quarter.

Then the U.S. government shut down.

Hmm, well that threw a wrench into the whole plan. We can’t talk about unemployment claims dropping because we’re not getting any government reports during the shutdown. We can’t talk about the projected GDP because we won’t know the impact until it’s over (forecasters are predicting a 0.1% drop in GDP for each week of the shutdown).

But then again, the day before the shutdown, the President signed a law that the 1.4 million active duty service members would continue to get paid. Then Hagel ordered back just under half of the 800,000 furloughed federal workers who are civilian workers for the Department of Defense while the House voted to provide back pay to furloughed workers once the now partial government shutdown ends. So, are we really shutdown or just giving a paid vacation to half a million Americans?

By the time you read this, we’ll have hopefully wrapped up the showdown on the debt ceiling and the budget impasse. If not, we have good news for wine drinkers. California is having a bumper crop of wine grapes this season.

If Congress was functional, we could celebrate the resiliency of the economy in the face of the sequester and end of the payroll tax holiday. During the third quarter, marginal revenue growth was strong, inflation low, the Fed accommodating, and personal net worth hit an all-time high. If we ignore for a moment the unwieldy Fed balance sheet and the eventual unwinding of one the largest financial experiments of our time, there would be enough good news to ring in the holidays with more cheer than we’ve had in over six years.

There still appears to be a big elephant in the room though…Obamacare. The time has come for the red headed step child of employee benefits, group healthcare insurance, to have her day. There are rising insurance rates, imploding exchanges, a new individual mandate, and questions about adverse selection. All of this is much more riveting than GDP growth and inflation hovering around 1.9% or the measly yields on cash. But then I regress…it’s still not cheerful.

So here is my top 5 list of reasons to be cheerful this holiday season:

  1. The return of Snooki and JWoww
  2. Thanksgiving, football, and beer
  3. We’re not Greece, yet.
  4. Tax on pot, unemployed stoners finally have to pay tax
  5. And yes….Denver has Peyton.

Hope you have wonderful holiday season!

Castle Rock Investment Company Participates in PLANSPONSOR National Conference Panel

September 13th, 2013

Michele Suriano, President of Castle Rock, recently participated in a panel at the PLANSPONSOR National Conference in Chicago, “Metric Taking: Going beyond the participation rate when gauging retirement plan success.” The panel encompassed the following topics:

  • Leading Indicators: Suriano uses the following leading indicators: median deferral rate broken down by HCE and NHCEs, percent using auto-escalate, percent using catch-up, percent maximizing company match, percent of assets in auto-diversified options and percent using auto-rebalancing.
  • Benchmarking: Suriano uses the Plan Design Optimization Report from Fiduciary Benchmarks, Inc. to benchmark retirement readiness. She also recommends creating a median-participant “avatar” to measure plan success, which is a composite representative of a particular plan, taking into account the median age, salary, deferral rate and account balance of that specific population. Suriano then compares the avatar against the National Savings Rate Guidelines for Individuals.
  • Fees: Suriano stressed that fees have become a huge issue, although they have very little impact on participant outcome, compared to deferral rate. She recommends using the 401K Averages Book to evaluate plan fees. She has done conducted RFIs with price requests for her clients as an educational tool, which may reveal advancements in the marketplace that aren’t being provided by the current provider. She stressed the importance of researching fees because, “What gets measured gets improved.”
  • Goals and Objectves: Suriano determines her clients’ goals and objectives upfront and includes it on the first page of their quarterly report. She recommends writing down the plan’s goals and objectives since there is turnover on committees.

Click Here to Listen to the Full Panel

For more information, please contact Castle Rock Investment Company at 303-725-7086.

Uncertainty Creates Volatility…and we’re in for more than a fair share

July 14th, 2013

Federal Reserve Chairman Bernanke can’t say anything right these days. The Fed’s attempt to communicate their QE3 exit strategy led to a market overreaction, which eventually normalized but not without sparking new fear in investors.

To provide context, the Federal Reserve has been purchasing $40 billion per month of agency mortgage-backed securities and $45 billion per month of U.S. Treasury securities. “Tapering” refers to a reduction in the pace of purchases and Bernanke hinted that it might begin later this year if job growth and inflation showed “substantial” progress toward their goals (6.5% unemployment with 2% inflation). They expect to reduce the pace of purchases through the first half of 2014 and end purchases around midyear with unemployment projected around 7% at that time. Note that they will continue to reinvest principal payments and proceeds from maturing holdings. They believe holding all of those securities off of the market will continue to put downward pressure on interest rates.

“And so, between our commitments to a low federal funds rate and the large portfolio, we will still be producing a very large amount of stimulus-in our view, enough to bring the economy smoothly towards full employment without incurring unnecessary costs or risks.” (Chairman Bernanke’s Press Conference June 19, 2013). In a few years we’ll be able to weigh in on that statement but I’m just glad I’m not the author or messenger. The imminent issue is that prices for Treasuries and agency mortgage-backed securities have been inflated from QE3 and the potential for capital losses is real when the central bank stops purchasing them.

Bernanke also noted in the press conference that private payroll employment has been averaging about 200,000 jobs per month over the past six months and the unemployment rate was unchanged at 7.6% but underemployment (quality versus quantity of new jobs) has become a concern. The U6 rate, which includes part-time for economic reasons as well as marginally attached, discouraged, and the unemployed jumped from 13.8% to 14.3%. There is speculation that the Affordable Care Act’s six month “look back” rule has encouraged some employers to adjust the hours of their workforce so fewer employees qualify for full-time employee medical insurance requirement.

Data supports the argument that the ACA is a headwind to full employment. The industries adding workers in June are in categories where companies have been shifting from a FT to a PT employment model. Respondents to a survey by the International Foundation of Employee Benefit Plans showed that 20% of small employers (0-50 employees) and 15% of large employers (>50 employees) have or plan to adjust hours so fewer employees qualify for full-time employee medical insurance requirements. No big surprise then on July 2, 2013, the administration informally announced in a blog post on that it will delay for one year new mandatory reporting requirements for employers and health insurers-as well as related employer shared-responsibility penalties– under the Affordable Care Act.

Instead of pointing to the ACA, Bernanke blamed federal fiscal policy as the main headwind to growth, estimated by the CBO to approximate 1.5%. It is important to remember that some sequestration cuts are just beginning in the third quarter so we haven’t felt the full impact yet. Despite all this, GDP growth was 1.8% in the first quarter and an estimated 1.3% in the second quarter with forecasts of 2.4% for the year. The fact that the economy absorbed the end of the payroll tax holiday with a dysfunctional Congress and continued to grow is what I would call “substantial” progress.

U.S. Supreme Court Decisions on Same-Sex Marriages Impact Employee Benefits

July 10th, 2013

Given the recent Supreme Court rulings regarding same-sex marriages, Castle Rock Investment Company wanted to shed some light on the impact it will have employee benefits. So, we turned to the experts. Thank you to Brownstein Hyatt Farber Schreck, LLP for the informative information below:

On June 26, 2013, the U.S. Supreme Court (the “Court”) issued two decisions, finding that federal and California laws on same-sex marriages are unconstitutional. These decisions will have far-reaching and wide-ranging consequences on employee benefits programs. This Alert highlights some of the benefits-related issues employers will need to address in the very near future in light of the Court’s decisions.


  • Section 3 of DOMA Is Unconstitutional. In U.S. v. Windsor, the Court ruled that section 3 of the federal Defense of Marriage Act of 1996 (“DOMA”) is unconstitutional because it does not provide equal protection rights under the Fifth Amendment to the U.S. Constitution. Section 3 of DOMA amended federal law to exclude same-sex partners from the terms “marriage” and “spouse” as used in over 1,000 federal laws and related regulations.
  • The Court’s decision did not address section 2 of DOMA because it was not a part of this case. Section 2 allows each state to decide whether to recognize same-sex marriages performed under the laws of other jurisdictions.  Some members of Congress already are seeking to repeal Section 2.
  • California’s Proposition 8 Is Unconstitutional. In Hollingsworth v. Perry, the Court ruled only on the procedural issue of whether the proponents of California’s Proposition 8 (“Prop 8”) had “standing” to appeal in federal court a California state court’s decision finding Prop 8 to be unconstitutional. Prop 8, a state ballot initiative, had amended California’s constitution to define marriage as a union between a man and a woman. The proponents of Prop 8 took over defending Prop 8 when California state officials refused to do so following the district court’s decision. The Court held that the proponents of Prop 8 did not have standing to litigate the issues in federal court.
  • The Court did not address whether Prop 8 was constitutional. However, the Court’s decision means that the California district court decision, which had found Prop 8 to be unconstitutional, will be the controlling decision.


  • The Court’s decisions mean that employers must take numerous actions with regard to the benefits available to their employees. Many of the actions are prospective, while some may be retroactive. In addition, some of the ramifications of the Court’s decisions are unclear, and more guidance will be needed before employers can act. A number of federal agencies already have indicated that they will be expediting the issuance of guidance to address the impact of DOMA following the Court’s decision.

As an initial course of action, employers should consider the following:

  • Determine Which Employees Are In Same-Sex Marriages. Employers should begin to administer employee benefits plans, programs and policies in a manner that recognizes the same-sex marriages of employees who (i) were married in a state that recognizes same-sex marriages and live in that state or (ii) were married in one jurisdiction but live in another jurisdiction that recognizes same-sex marriages performed in other jurisdictions. This will not necessarily be an easy task. Only 12 states (California, Connecticut, Delaware, Iowa, Maine, Maryland, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont, and Washington) and the District of Columbia currently recognize same-sex marriages. Where a same-sex couple is married in a state that recognizes same-sex marriages and lives in that state, we would expect the same verification procedures that are applied to opposite-sex marriages would apply. However, because DOMA section 2 remains in effect for now, employers will need to develop administrative procedures for determining whether an employee’s same-sex marriage should be recognized when the marriage occurred in a jurisdiction other than that in which the employee currently resides. Administrative procedures will need to take into account the laws of the state governing the benefit plans, the laws of the states where employees were married, the laws of the states where employees reside, and the terms of the benefit plans. Without doubt, more guidance is needed to assist employers in dealing with these multijurisdictional issues.  Brownstein Comment: Many other states have approved civil unions. We do not expect that civil unions generally will be recognized as same-sex marriages, but this will depend on whether applicable state law considers civil unions to be the same as marriage. For example, Colorado’s Civil Union Act specifically states that it is not granting same-sex couples the right to marry.
  • Plan Administration Changes. Changes in benefit plan administration certainly will be required.  Examples of administrative changes needed in benefit plans include the following:

Retirement Plans (such as 401(k) and defined benefit pension plans):

  • An employee’s same-sex spouse will have to consent to the participant’s naming of a nonspouse beneficiary.
  • An employee’s same-sex spouse will have to consent to the participant’s distribution elections — including hardship distributions, loans, and the selection of the form of benefit distribution upon retirement, if the participant wants to be paid in a form other than a joint and survivor annuity with the spouse as the surviving annuitant.
  • An employee’s same-sex spouse must be treated as an alternate payee under a QDRO.
  • Health and Welfare Plans (such as medical, dental, vision, life insurance, cafeteria, flexible spending accounts, health savings accounts, etc.):
  • Employees can now pay for their share of the cost of providing health coverage to their same-sex spouses on a pre-tax basis. No longer must an employer’s share of the cost of providing health coverage to an employee’s same-sex spouse be imputed as income to the employee. (Note: we believe that this does not result in changes for domestic partners.)
  • The Court’s decisions likely are a status change event, which could allow employees to make mid-year changes to their health FSA elections to take into account health expenses of their same-sex spouses.
  • Same-sex spouses are now entitled to elect COBRA health care continuation coverage.
  • Employees can elect dependent life coverage for same-sex spouses.

Other Benefits Programs:

  • Employees have the right to take FMLA leave to care for a sick same-sex spouse.
  • Same-sex spouses should be required to give consent to employee-spouses’ exercise to purchase stock under the employer’s stock option or other equity ownership programs.
  • These administrative changes will require changes in plan documents, employee communications, administrative forms and procedures.
  • Brownstein Comment: Employers should work with their third party administrators and legal counsel to ensure that their benefit plans become fully-compliant with the law.
  • Plan Design Considerations. Since the provision of benefits to employees and their dependents is largely discretionary, subject only to certain nondiscrimination and other regulatory constraints, employers will need to consider whether any benefits program revisions are necessary or desired in response to the Court’s decisions.Plan Amendments. Both the administrative and design changes mentioned above may require plan amendments. For example:
    • Employee Communications. Employers can expect many questions from employees who are in, or may be entering into, same-sex marriages and should consider preparing an initial communication to tell employees that the impact of the Court’s decisions on the employer’s benefit programs will be addressed. Employers should ask for employees’ patience while employers work through all of the implications and explain that additional guidance may be needed from governmental entities because there are many unanswered questions at this time. We think that communications regarding the details of changes implemented in response to the Court’s decisions should be prepared and distributed only after employers have fully considered the broad range of implications of the Court’s decisions and after reviewing the anticipated government guidance.
  • Respond to Future Statutory Changes and Regulatory Guidance. Employers must be prepared to react to future changes. We can expect that proponents, both for and against same-sex marriage, will be active in trying to change their state’s marriage laws. As indicated above, regulatory guidance will be forthcoming. As laws change and guidance is issued, employers will need to make coordinating changes in their benefits programs.


Since DOMA section 3 has been found to be unconstitutional, it is as if the law never existed. This raises numerous plan administration issues. For example, do participants and their same-sex spouses have the right to make claims for benefits on a retroactive basis? Will plan administrators have to invalidate distribution elections made by participants without same-sex spousal consent? If these types of actions are required, how must they be accomplished? Future guidance may provide some direction on these and other issues but such guidance will take time. Employers and plan administrators will need to determine what this retroactive invalidation of DOMA means for their benefit plans and what actions may be required to undo or redo prior administrative decisions and actions.

If you have any questions about, or would like assistance in analyzing the impact of, the Court’s decisions on your benefit plans, please contact one of the Brownstein benefits group members, including Nancy Strelau, via e-mail at, or call her at 303.223.1151.

Water Cooler Wisdom – First Quarter 2013

April 22nd, 2013

Click the link below to read our musings on the economy for fodder at your next water cooler conversation.

Read About Current Market Conditions

For more information, please contact Michele Suriano at 303-725-7086.

2013 Compliance Calendar

February 3rd, 2013

We realize that the onset of a new year means many deadlines for our industry. To help you, Castle Rock Investment Company has compiled a compliance calendar to help you keep track of all of the important 2012 compliance dates!

Click Here to View the 2013 Compliance Calendar

For more information, please contact us at 303-725-7086, or via e-mail at Have a great 2013!



Water Cooler Wisdom – Fourth Quarter 2012

February 3rd, 2013

Click the link below to read our musings on the economy for fodder at your next water cooler conversation.

Read About Current Market Conditions

For more information, please contact Michele Suriano at 303-725-7086.

Water Cooler Wisdom: 2nd Quarter 2012

September 6th, 2012

Castle Rock Investment Company conducts a thorough market analysis each quarter. We have put together few highlights on why it was a long hot summer with languishing markets

Supreme Court decision upheld the individual mandate:
On June 29th reported a “Reaction Survey” completed the previous day by the International Foundation of Employee Benefit Plans with responses from 1,122 plan administrators, trustees, and organizational representatives. “Despite the differing reactions among U.S. business sectors to the Affordable Care Act (ACA) Supreme Court ruling, 77% of surveyed organizations are very likely to provide health coverage in 2014. Only 2% indicated they will not provide coverage in 2014”.

As a result of the Court’s decision, insurance companies that spent less than 80% of premiums on medical care and quality for coverage provided in 2011 will be  rebating the difference back to their customers impacting 12.8 million Americans and totaling more than $1.1 billion. The notifications and rebates are due before August 1st and can be paid by check or applied to future premiums or to the account it was paid by. Employers can pass through the rebates in the same manner or in a manner that benefits its employees.

Presidential election on November 6th:
Now that ACA has been upheld, the majority of employers from the survey cited above are waiting to implement significant initiatives until the next President is elected.

Fiscal Cliff and Congressional Gridlock:
The Budget Control Act of 2011 requires the Office of Management and Budget (OMB) to conduct a sequester on January 2, 2013 (and every year after through 2021) to achieve the $1.2 trillion in deficit reduction that the Super Committee did not. The expiration of the Bush tax cuts and payroll tax holiday, and the reduction in federal spending is referred to as the “fiscal cliff” that make most politicians wary due to the weak economic recovery. Using the current laws in place, the CBO projects the economy to contract at an annual rate of 1.3% in the first half of the year and expand at an annual rate of 2.3% in the second half, providing growth in real (inflation-adjusted) GDP in the calendar year 2013 of just 0.5%. Without the fiscal cliff the growth of real GDP in 2013 would “lie in a broad range around 4.4%”.

European Sovereign Debt Crisis:
European leaders have been unwilling to take the steps necessary to avoid a catastrophic sovereign default by Greece with Italy, Portugal, and Spain facing the risk of spiraling borrowing costs that are unsustainable. Their economies are currently contracting and the deepening recession is impacting stronger countries in the Eurozone and, to a lesser extent, export-driven BRIC economies.

GSAB change in public pension accounting rules:
On June 25th the Governmental Accounting Standards Board voted to approve Statements No. 67 and 68 which revise existing guidance for the financial reports of most pension plans and establishes new financial reporting requirements. In particular, governments will be required to recognize their long-term obligation for pension benefits as a liability for the first time as a net pension liability (the difference between the present value of projected benefit payments to employees based on their past service ) and the assets reported at fair value. The impact of the increased transparency is expected to have a dramatic effect with total liabilities for fiscal 2010 more than three times the amount reported by local governments. Moody’s issued a public request for comment on four major changes it plans to make in how it treats pension liabilities. The negative impact of the modifications-which will start taking effect in the fall—will hit local governments such as counties, cities and town, as well as school districts most heavily. The Center for Retirement Research at Boston College determined using its public pension database that as of 2010 those plans would have reported 57 cents on hand for every dollar they must pay retirees in the future (instead of 76 cents). Moody’s Managing Director Timothy Blake said in a statement that cities and counties are likely to see downgrades.

Maybe Wal-Mart should put out their holiday decorations now just to cheer us all up.

If you have any questions, please contact Castle Rock Investment Company at 303-725-7086.

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