Place holder node for 1995
National Office Instruction
amending General Orders (1993 edition)
Instruction No. 46
Date of Effect: 11 December 1995
TRANSFERS
JOINT TENANTS to TENANTS IN COMMON
Purpose
The purpose of this Instruction is to clarify the application of section 22 of the DSH Act in those cases where existing clients who hold title as joint tenants wish to rearrange the manner of their holding to tenants in common.
Background
A discussion of a recent case with Westpac on the application of section 22 has highlighted the need for an Instruction to clarify certain aspects.
A Transfer of Ownership Application was received by a State Office with a request from the clients to transfer their existing joint tenancy into a tenancy in common. The clients' proposal was consistent with the changes introduced in the 1995 Budget and the application was approved. Subsequently, the Bank sought advice in respect of another client who wished to transfer from joint tenancy to tenants in common.
The 1995 Budget introduced changes to the DSH Act which now permit the Secretary to issue a Certificate of Entitlement for a subsidised advance to an eligible person who wishes to hold the property as a tenant in common. The co-tenant may be the eligible person's spouse, another eligible person (using pooled entitlements), or any other person. Section 17A sets out the requirements that have to be met if a Certificate of Entitlement is to be issued if the right or interest is in the form of a tenancy in common.
Section 22 is in Part III of the Act which includes section 17A. Accordingly, the requirements of section 17A apply to applications for a Certificate of Entitlement in respect of transfers of ownership. This is particularly critical when the application is to transfer the right or interest into the form of a tenancy in common.
Policy to be applied
In any case of a transfer to tenants in common, an application under section 22 must be made to determine:
Should an application be lodged by an ineligible spouse, it should be refused in accordance with subsection 22(3) of the Act. However, if the application is from the eligible person and the proposed value of the eligible person's share or interest is less than the amount of the subsidised loan, the application should be refused in accordance with paragraph 22(2)(a) because, in all the circumstances, it is not reasonable to approve the issue of a Certificate of Entitlement. The circumstance which is unreasonable is the non-compliance with subsection 17A(2) of the Act.
General Orders
The relevant Chapters of the Entitlement General Orders will be amended in the forthcoming update of the General Orders which takes into account the 1995 Budget changes.
Effect on previously issued NOIs (formerly COIs)
This Instruction further refines the policy enunciated in COI 31 and replaces that COI.
G E FITZGERALD
General Manager
4 December 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 25 September 1995
RELEASE OF STANDARD LETTERS
PRACTICE AND PROCEDURAL MATTERS VOLUME
Purpose
The purpose of this Instruction is to formally release the Standard Letters part of the new General Orders. This part is for inclusion in the Practice and Procedural Matters Volume.
Background
As part of our ongoing commitment to provide a quality client service a project was commenced in 1993 to investigate and develop a standard letters system. The project team comprised representatives from National Office, New South Wales, Queensland and Victoria. The aims of the development were:
(a) provide a more consistent approach nationally to the preparation of routine correspondence;
(b) improve the quality and effectiveness of routine correspondence to assist communication with our clients;
(c) improve resource management by utilising enhanced technology; and
(d) provide staff with a greater degree of job satisfaction.
The DSH Standard Letters System is derived from the Benefits Program Standard Letters System, and provides operators with greater flexibility within each letter. Where the Benefits System uses a multitude of base letters which are fairly complete apart from client variables, the DSH System has fewer letters. However, each DSH base letter requires user manipulation to import the required paragraph variables in order to construct the desired letter. This is mainly achieved using glossaries.
The standard letters are based on document templates; there are three groups of letters each with their own template and glossaries. Users are able to access each of these groups from toolbar buttons, the File Menu or by using keyboard commands.
The Standard Letters System is contained within Word for Windows allowing users to have the full capabilities of the word processor available to tailor the letter they select.
The Standard Letters issued to all States in March 1994 comprised letters used in processing approved applications for Notices of Eligibility and Certificates of Entitlement (restricted to applications for Initial, Further (Portable), and Additional Advances).
These letters have now been re-issued as part of this NOI and their content has been updated in line with the New Policy Proposals brought in by the 1995 Budget. In addition, the System has been linked to CELS allowing the importing of certain data (file number, client name, address, salutation and approx. limit); and the font size has been amended.
Policy to be applied
The Standard Letters System is an important part of our shared commitment to providing a quality client service. In addition, the use of these letters underpins some of the quality assurance aspects.
Standard letters are designed to improve the quality and effectiveness of routine correspondence and to assist in communicating with our clients. In order to provide a more consistent approach nationally in the preparation of correspondence, these letters should be used at all times where it is appropriate to so do. The extensive use of glossaries and wide consultation with State Offices provides the System with sufficient flexibility to meet most demands of routine processing. Subsequent releases will provide letters for Widows/Widowers Advances, Essential Repairs, Transfers and Instalment Relief; and statements of reasons for applications that are declined.
Maintenance of the Standard Letters System will be the responsibility of the Victorian State Office. Updating of text, either as the result of Budget changes or suggestions from the State Offices, will be carried out by Victoria in conjunction with National Office.
General Orders
Copies of Part 2 of the "Practice and Procedural Matters" volume of the General Orders covering "Use of Standard Letters" are enclosed. They are to be added to the GO folders provided in October 1993.
A J P GUNNING
Atg General Manager
19 September 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 11 September 1995
SECTION 19 of the DSH ACT
PURCHASERS & BORROWERS after 9 DECEMBER 1987
Purpose
The purpose of this Instruction is to clarify when a person ceases to be a purchaser or borrower for the purposes of section 19 of the Defence Service Homes Act 1918.
Background
A recent case offered a different interpretation on the application of section 19 and has highlighted the need for an instruction clarifying this issue.
A client enquired about his entitlement to a further advance, advising that his initial loan was repaid on 2 December 1987. A search of the relevant property title revealed that the discharge of the DSH mortgage was registered on 14 December 1987. The current practice is to advise the client that, since his loan was discharged before 9 December 1987, he fails to meet the requirements of section 19 in that he was not a borrower on that date.
Section 19 requires a person to be a purchaser or borrower in relation to a Corporation advance, a subsidised advance or a contract of sale on or after 9 December 1987. This is interpreted by Entitlement GO 3.7.2 as meaning that a person who discharged his/her liability prior to 9 December 1987 is not entitled to further assistance.
The line of investigation adopted focussed on the definition of "borrower" which is described in the DSH Act as "... a person who is liable to pay the outstanding amount:...". Research along this line included reference to the authoritative legal text "Mortgages and Securities" by Francis & Thomas (3rd ed.). At page 356 under the heading Effect of a Discharge is the following:
"In the absence of an express agreement to the contrary, the registration under the Torrens statutes of a discharge of mortgage will operate to discharge the mortgagor from his personal obligations as well as to release the land from the encumbrance."
The standard forms of Discharge of Mortgage used in Corporation offices in each State were basic forms, with sufficient detail for their purpose. There were no words in these forms expressing a continuing obligation by the outgoing mortgagor nor any reservation of powers on behalf of the Corporation once the mortgage was discharged. Therefore, according to the legal reference, Corporation clients were only relieved of the obligation to pay under the mortgage when the Discharge of Mortgage was registered.
The following example, using the facts from the initiating case, demonstrates the logic involved:
On this basis, those clients who paid off their loans just before 9 December 1987 but whose discharge of mortgage was not registered until on or after that date may still have a DSH entitlement to a further advance (subject to the 25 year rule). This group of clients is not expected to be large having regard to anecdotal evidence from the Data Capture Exercise. However, in most cases, determining the date the Discharge of Mortgage was registered will require a search of title. Where the Corporation actually lodged the documents, State Offices may have access to other sources, e.g. lodging books, etc.
Staff will be aware of the need for sensitivity in handling entitlement queries from clients who discharged their previous loans in the weeks leading up to 9 December 1987. It is suggested that a "cut-off" date be determined to simplify administration. This date would be based on local conveyancing practice in each State, that is, what is a reasonable time to lodge documents at the Titles Office following settlement? If a reasonable time is one week, then clients who discharged prior to 1 December 1987 will be assumed to have had a discharge of mortgage registered before 9 December 1987.
The initiating case and the new interpretation have been predicated on the title being held under the Torrens system. Similar cases involving General Law title will be unchanged since the effective date for the transfer of an interest is the date of the deed. Unlike the Torrens system, the date of lodgement at the Titles Office is not an imperative in determining priority. The majority of Corporation securities were held under the Torrens system, and therefore the number of cases involving the General Law system of title affected by this new interpretation will be negligible.
Policy to be applied
Further advance enquiries by clients whose previous loan was discharged in the period immediately before 9 December 1987, and whose loan term has not exceeded 25 years, should be investigated to determine the date of registration of the Discharge of Mortgage. The period immediately before 9 December 1987 will be determined locally by each State Office having regard to their conveyancing practices. Investigation can include a search of title, where necessary, although evidence from other sources should be considered first.
In Torrens title cases, where investigation reveals that the discharge of the DSHC mortgage was registered on or after 9 December 1987, the client should be advised that there is access to a further advance entitlement, subject to our usual requirements. Clients whose previous loan was secured under the General Law will still need the date of the reconveyance/statutory receipt to be 9 December 1987 or later in order to gain access to a further advance entitlement.
General Orders
A new sentence is to be added to Entitlement GO 3.7.2:
Where the previous liability was discharged in the period immediately prior to 9 December 1987, the date of registration of the discharge of mortgage should be ascertained to determine when the person ceased to be a borrower for the purposes of section 19. [NOI 42 of 6 September 1995 also refers.]
Attached are amended pages 23-26 for the Entitlement General Orders. Please replace the existing pages with the amended version.
Effect on previously issued NOIs
This Instruction has no effect on any previously issued operative NOI.
A J P GUNNING
Atg General Manager
6 September 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 11 September 1995
RELEASE FROM PERSONAL COVENANTS
TRANSFERS TO INELIGIBLE SPOUSE
Purpose
The purpose of this Instruction is to clarify the policy relating to the release of an eligible person from the personal covenants of a mortgage.
Background
A number of cases discussed during the Subsidy Managers' Conference in May 1995 has highlighted the need to issue an instruction clarifying the current policy.
With the advent of portability, the question that has arisen in cases where the current loan is serviced by an ineligible ex-spouse is; 'does the eligible person have access to a portable loan entitlement?'
Transfers to the ineligible spouse were not a rarity, especially in the period following the promulgation of the Family Law Act 1975, and it was quite common for the property to be transferred subject to the existing Defence Service Homes (DSH) mortgage. This left the eligible person tied to the mortgage as a mortgagor notwithstanding the fact they were no longer a registered proprietor of the mortgaged land. This practice ceased with the 1990 amendment to section 22 which prohibits a transfer of any land which is subject to a subsidised advance to a person who is not an eligible person. Legislative changes which provided for portability did not permit the eligible person to access the continuing entitlement because the original loan was still current. Paragraph (b) of the definition of "further advance" in section 4 refers.
The link between the eligible person and the ongoing mortgage was, of course, the personal covenants contained in that mortgage. As a lending organisation, the general policy of the Defence Service Homes Corporation required that, in cases such as these, the outgoing mortgagor was not released from the obligations contained in the personal covenants. As part of a streamlining exercise, the Corporation issued an Instruction in 1987 (COI 1987/130) which reversed the policy, providing for a general release.
In considering whether the eligible person was entitled to a further loan in these cases, the consensus was that because they were still bound to a current mortgage by the personal covenants, they could not be assisted. However, the interplay of the general release from the personal covenants in March 1987 meant that the eligible person was severed from the mortgage before the critical date of 9 December 1987.
The difficulty for staff in processing those cases where there had been a matrimonial breakdown with the property being transferred to an ineligible spouse, centred on the question of whether the eligible person was still tied to the loan until 9 December 1987 and whether they could be released after that date and thereby be entitled to a further advance.
Policy to be applied
A new approach, which relies on the DSH legislation, State property law and the facts of each case, rather than the policy surrounding the personal covenant concept, is to be taken.
Prior to the amending legislation of 1988, the definition of "borrower" in section 4 of the Defence Service Homes Act read:
"Borrower" means a person who has received an advance or executed a mortgage or other security to the Corporation and, for the purposes of sections 30A, 31 and 36 includes -
(a) a transferee under section 35 of an estate or interest in the land or land and dwelling-house that was formerly the estate or interest of a borrower in relation to the land or land and dwelling-house; and
(b) the personal representative of a person who was, immediately before his death, a borrower in relation to the land or land and dwelling-house;
However, the Defence Service Homes Amendment Act 1988 (which came into force on 19 December 1988) changed the definition of "borrower" to
"borrower" means a person who is liable to pay the outstanding amount:
(a) of a subsidised advance in respect of which subsidy is payable; or
(b) secured by a specified portfolio asset (other than a contract of sale) which vests in the Bank under section 6B and in respect of which subsidy is payable;
Accordingly, a "borrower" is, until 19 December 1988, one who has received an advance or executed a mortgage. This means that this particular class of eligible people are tied to the DSH mortgage until 19 December 1988 by the definition of "borrower" rather than the personal covenants, thereby satisfying section 19 of the DSH Act. After 19 December 1988, the eligible person is released from the burden of the mortgage if:
(a) the property settlement contains a clause whereby the eligible person is indemnified against any demands made for principal or interest under the mortgage; or
(b) the relevant State property legislation contains a statutory indemnity for the benefit of the outgoing transferor against any demands made for principal or interest under the mortgage.
Either of these provisions (a) and (b) will exclude the eligible person from the current definition of "borrower", and allow them access to a portable loan entitlement. In those cases where a property settlement was not entered into and the relevant State legislation does not contain a statutory indemnity (this is the case in at least one State, namely Queensland), then, as a matter of last resort, reliance will need to be placed on formal release from the personal covenants.
However, it should be noted that there are instances of property settlements containing specific clauses which compel the eligible person to continue making the repayments required by the DSH mortgage. In such cases the statutory indemnity does not apply, and delegates will have to take notice of these types of clauses in their decision-making.
In considering this new approach, the relevance of the general release from the personal covenants promulgated in COI 1987/131 is questioned. This COI was issued on the basis of generally streamlining the administration of the mortgage management aspects of the DSH Act. The impact of the COI on portability, given subsequent legislative changes, could not be foretold. In view of this, the principles embodied in COI 1987/131 are no longer to be applied. This will place all of this particular class of client in the same position. If the mortgage commenced before the relevant Vesting Date in a State, then for the period from commencement to Vesting, you will be able to deem the eligible person transferor released from the personal covenants if required. Mortgages commencing after the Vesting Date are of Westpac origin and full responsibility for release lies with the Bank. Therefore, Westpac will need to be approached for a formal release; the mortgage having been given to the Bank.
In those cases where there is a property settlement between the parties, or there is a statutory indemnity in the State legislation, the date from which portability arises will be 19 December 1988 for term and liability unless the mortgage was discharged between 9 December 1987 and 19 December 1988. In those cases, the date from which portability arises will be the date of discharge. For those cases which cannot rely on a property settlement or a statutory indemnity, the operative date will be the date a release from the personal covenants is obtained.
The provisions of section 66 of Schedule 1 to the Veterans' Affairs (1995-96 Budget Measures) Legislation Amendment Bill 1995 will continue to be applied in accordance with the Secretary's Direction for administrative implementation. These provisions do not alter the effect of this change in policy. As a general guideline, an initial loan which was taken out before 9 May 1970 and on which subsidy ceased to be payable before 9 May 1995 is not capable of being the vehicle for a further advance because of the prescribed period exceeding 25 years.
Applications from the client group whose previous DSH subsidised loans have been transferred to their ex-spouses will now be processed with the prime focus on the facts of each case and the applicability of State property legislation rather than the previous concerns with the personal covenants in the mortgage.
In processing these applications, delegates will need to satisfy themselves regarding the appropriateness of the terms of any property settlement, and the relevance of State property legislation, within the framework of the beneficial DSH legislation.
Delegates should be guided by the following in determining the balance of term and the amount of sudsidised loan to be made available to transferor eligible persons:
(a) the amended rules governing the term of a further advance set out in section 66 of Schedule 1 to the Veterans' Affairs (1995-96 Budget Measures) Legislation Amendment Bill 1995 will apply;
(b) in cases where the transferred loan is discharged between 9 December 1987 and 19 December 1988, the operative date for balance of term and liability is the date of discharge;
(c) in cases where the transferred loan remains current or is discharged after 19 December 1988, the operative date for balance of term and liability is 19 December 1988;
(d) in cases where the transferred loan is not subject to a property settlement between the parties and the relevant State property legislation does not contain a statutory indemnity against demand made for principal and interest under the mortgage, the operative date for balance of term and liability will be the date of release from the personal covenants.
General Orders
No changes are required to General Orders.
Effect on previously issued NOIs (formerly COIs)
The principles embodied in COI 1987/131 are no longer to be applied.
ARTHUR GUNNING
Atg General Manager
6 September 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 1 June 1995
RELEASE OF NEW GENERAL ORDERS
QUALITY ASSURANCE STANDARDS
Purpose
The purpose of this instruction is to formally issue a further part of the new General Orders. The part is for inclusion in the Practice and Procedural Volume and covers the subject of: PART 4 QUALITY ASSURANCE STANDARDS.
Background
When the decision was taken to write and issue a completely new set of General Orders following the bedding down of the Subsidy Scheme, it was agreed that the new document would contain two volumes. The first volume would cover 'Legislation Interpretation & Policy' and the second volume 'Practice & Procedural Matters'.
Four parts of the first volume were issued in October 1993, two parts of the second volume were issued in March 1994 and one part in November 1994.
The Quality Assurance Standards General Orders describe DSH's service standards for processing subsidy applications and insurance claims.
General Orders
Copies of Part 4 of the 'Practice & Procedural Matters' volume of the General Orders, covering 'Quality Assurance Standards' are enclosed. They are to be added to the GO folders provided in October 1993.
DAVID MACKRELL
General Manager
31 May 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 27 March 1995
BEST EVIDENCE POLICY
- STATEMENTS OF SERVICE
Purpose
The purpose of this instruction is to further refine the application of the 'best evidence' policy.
Background
The 'best evidence' policy was introduced by COI 19 on 1 January 1993 and clarified for Malaya/Singapore service by COI 34 on 1 November 1994.
As mentioned in COI 19, one of the prime considerations in introducing this policy was to improve our service to clients. It was recognised that any decision making process involves some element of risk, but that the new approach to determining eligibility was about improving our turnaround times without unduly risking the accuracy and integrity of the process. The main thrust of the policy was to widen the circumstances in which forms of Defence documentation other than service checks, could be used to determine service eligibility. In addition, it allowed the use of records held elsewhere in the Department.
The original instruction indicated that the new policy would be monitored to gauge its effectiveness and that we would be seeking appropriate feedback. Indeed, it was valuable feedback from staff which led to the issue of COI 34 clarifying the arrangements for determining Malaya/Singapore service.
Impressions are that the 'best evidence' policy for determining eligibility is working well and that our service to clients has improved as a direct result of its introduction. We remain committed to continuing this approach.
A recent case brought to our attention however, has highlighted the risk associated with 'best evidence' and the need to be ever vigilant in its operation.
The case involved a statement of service which indicated that the applicant had served for five years and two hundred and thirty two days at a time when the required minimum period was three years. A subsequent service check done because a delegate noticed that the total period of service was for an unusual or uneven period, resulted in advice from Defence that the person had been AWOL for three years and furthermore, had been discharged by reason of misconduct or misbehaviour.
As statements of service make no reference to non-effective service and misconduct discharges, it is important to be aware of the potential risk in accepting them. This is not to say that they may not still be used for determining eligibility. For example, if the statement indicated that the applicant had served a neat three, six or nine years, it would be reasonable to assume that the discharge occurred as a result of completion of service for which the person was engaged. Delegates would also be aware that the engagement periods for officers differ from those for 'other ranks' and that the incidence of misconduct terminations of service among officers is minimal. If the total period of service as indicated on the statement is not substantially greater than the required minimum period, a service check should be done to ascertain whether it included any non-effective service. Where a statement of service indicated that the person had served for nine years when the required minimum period was a period beyond six years, it would be reasonable to assume that the person's service did not include non-effective service of at least three years. In other words, it would be reasonable to determine eligibility favourably in such cases. Likewise, statements which indicated that the person was awarded campaign medals for conflicts covered under the Defence Service Homes Act 1918 may be used for determining eligibility favourably. We do not regard it necessary for service checks to be done to rule out misconduct discharges where there is no good reason to suspect that the person's service may have ended in that fashion.
Policy to be applied
As mentioned in COI 19, a service check may be required where a person has been discharged from the Forces and the delegate has reason to believe that there is a possibility that he/she may have had a period of non-effective service or was discharged for misconduct or misbehaviour. Delegates should not request service checks without good reason. An unusual or uneven period of service would be sufficient grounds for seeking further information.
General Orders
Attached are amended pages 55 - 58 for the Eligibility General Orders. Please replace the existing pages with the amended version. The sixth paragraph of Eligibility 13.1 has been amended to read:
'Where eligibility is being claimed on the basis of service on land in Malaya or Singapore between 1 September 1957 and 28 May 1963, it is appropriate that a service check be sent to the Department of Defence. A service check may also be required if, for example, an applicant has served for 6 years 2 days but it is not clear whether the additional service was due to a delay in processing the person's discharge. Where a statement of service is tendered as evidence of service, delegates need to be aware that non-effective service and misconduct discharges if applicable, are not specifically highlighted. Where a statement of service indicates an unusual or uneven period of service, a service check would be considered appropriate. Where a statement of service indicates a neat 3, 6, or 9 years service for example, it is reasonable to assume that the person had completed the period for which he was engaged to serve. A service check to ensure that the discharge was not due to misconduct would not be necessary in such circumstances. Delegates would also be aware that the engagement periods for officers differ from those for 'other ranks' and that the incidence of misconduct terminations of service among officers is minimal. If the total period of service as indicated on the statement is not substantially greater than the required minimum period, a service check should be done to ascertain whether it included any non-effective service. Delegates are to use sound judgement in these matters.'
Effect on previously issued NOIs (previously COIs)
This instruction should be read in conjunction with COI 19 and COI 34, both of which remain unamended.
DAVID MACKRELL
General Manager
23 March 1995
National Office Instruction
amending General Orders (1993 edition)
Date of Effect: 3 April 1995
Modifications and Repairs
Maximum Amount Included on Certificates of Entitlement
Purpose
The purpose of this Instruction is to clarify the amount which should be recorded in the Maximum advance box on a Certificate of Entitlement issued for the purposes of to modify, to repair, or to modify and repair a home.
Background
The restrictions on acceptable modifications have led, in some cases, to undue detail in determining a monetary limit for the advance when issuing a Certificate of Entitlement for the above purposes. If the limit is overly restrictive in initial or further advance cases, the client may be forced into an additional advance at 10 % pa interest if the cost of the work subsequently exceeds the specified amount. The Standard Phrases for Special Information on Certificates of Entitlement were issued on 24 November 1994 with the intention of overcoming this problem. However, it was not clearly spelt out that it was no longer necessary to seek detailed costs of the proposed work. Activities, such as asking for quotes or examining plans, are no longer necessary.
Maximum flexibility should be afforded in such circumstances. The amount of the maximum loan available (be it $25,000 in an Initial Advance case or the maximum available under a Further Advance case) should be inserted in the Maximum advance box and The DSH subsidised advance must not exceed the cost to repair or to modify and repair or $.....(maximum loan available) whichever is the lesser should be inserted in the Special information box. Westpac then administers the actual amount advanced within these limits.
Policy to be applied
Given that restrictions on allowable modifications have been removed, quotations and copies of plans should not be obtained to consider applications for modification and/or repair to a home. The Certificate of Entitlement should be issued with the maximum possible amount being quoted in the Maximum advance box with the over-rider The DSH subsidised advance must not exceed the cost to repair or to modify and repair or $.....(maximum loan available) whichever is the lesser in the Special information box.
General Orders
No changes are required to General Orders.
Effect on previously issued NOIs (previously COIs)
This Instruction has no effect on any previously issued NOI.
Other changes
The opportunity is taken to correct a typographical error in Entitlement GO 3.6.5.2 where the word operation inadvertently became occupation.
Attached is an amended page for the Entitlement General Orders. Please replace the existing page 23/24 with the amended version.
The currently issued List of Operative COIs omits the second half of COI 23. A new list is supplied to correct this, and a modified COI 23 is supplied to replace the partially superseded Instruction.
DAVID MACKRELL
General Manager
27 March 1995
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