Federation of European Business Information Services

FEBIS

FEBIS is the federation of leading Business Information Services Providers and Credit Information Agencies. Today it has developed into an organization comprising about 150 full members involved in providing both business & consumer credit reports (including scoring), debt collection services and marketing information services of national and international importance. Supported by a combined workforce of over 25.000 employees, FEBIS members and associate members generate over 1, 3 trillion million business reports annually for over 1,6 billion European organizations, providing these clients with business support for the provision of credit and other commercial services. More information on FEBIS at www.febis.org

Lobbying Activity

Response to Digital package – digital omnibus

14 Oct 2025

FEBIS is the specialized and recognized industry body of providers of trust B2B Business services for managing Trade Credit Risks. Founded in 1973, FEBIS comprises over 150 members across more than 60 countries. FEBIS represents the collective voices of Business Information Providers (BIPs). Business Information Providers are companies that collect, validate, enhance, and analyse data to produce business intelligence tailored for business-to-business (B2B) and public sector use cases. Unlike financial institutions, they do not engage in lending or asset management. They also differ from traditional data brokers, as they act as value creators, curating and interpreting data for specific tools in decision-making contexts. BIPs enable transparency and efficient decision-making, particularly for SMEs, and play a key role in Europe's data economy. Their services align with EU policy objectives related to SME financing, innovation, and B2B resilience. Services provided by BIPs are used by companies of all sizes to engage in business transactions safely, responsibly, and with enhanced legal certainty.FEBIS members welcome the call for evidence on the Digital Omnibus and appreciate the effort to simplify the EU digital framework. However, we would like to highlight that simplification should not come at the cost of clarity and usability. Regulations must be practically applicable and coherent across legislative texts. Poorly coordinated or unclear regulations create confusion for both businesses and competent authorities. FEBIS therefore calls for clear, standalone legislative instruments and for the Commission to improve inter-DG cooperation during the drafting phase. More comments are outlined in the attached paper.
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Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

11 Jun 2025

FEBIS welcomes the European Commission initiative to consult on the European Business Wallet in a call for evidence and would like to stress the following points. The Impact of the European Business Wallet on Business Information Providers: A Call for Fairness, Inclusivity, and Opportunity The introduction of the European Business Wallet (EBW) represents a significant step in the EUs digital transformation, aiming to empower businesses by enabling secure and seamless access to digital identity, credentials, and services across borders. While the objectives of enhancing trust, interoperability, and efficiency are laudable, the implementation of the EBW raises questions for Business Information Providers (BIPs) to ensure a fair, competitive, and inclusive digital ecosystem. A Fair Level Playing Field Is Essential The EBWs potential to centralize business credentialing and digital identity services may inadvertently marginalize established BIPs who have long provided vital services such as business registries, credit information, due diligence, and verification tools. If the Wallets governance and operational frameworks are skewed toward a small number of state-backed or pre-designated entities, it could disrupt the market by creating an uneven playing field, where only a few selected actors benefit from privileged access and legitimacy. Fair competition is a cornerstone of the European single market and must remain at the heart of EBW deployment. Ensuring that all qualified BIPs have the opportunity to participate and compete on equal terms will preserve innovation, service quality, and customer choice. The Wallet Must Not Be Exclusive It is crucial that the EBW does not become an exclusive gateway, monopolizing access to business credentials and services. Exclusivity could not only distort the market but also stifle innovation by sidelining private sector providers with proven expertise, broad networks, and user trust. The Wallet should be interoperable, open, and inclusive by design, allowing multiple service providers to integrate and operate within its ecosystem. This approach would reinforce the principles of decentralization and resilience, while ensuring that businesses continue to benefit from a variety of sources and formats for their digital credentials. The EBW must not marginalise existing BIPs by granting exclusive privileges to a handful of state backed players. Competition drives innovation and protects SME users. Certification as a Pathway to Inclusion To address both fairness and functionality, the European Commission should establish a clear, transparent pathway for BIPs to become certified providers within the EBW framework. Certification would guarantee quality, security, and compliance with EU standards, while allowing market-driven solutions to flourish. This model encourages excellence and safeguards the integrity of the Wallet, without erecting unnecessary barriers to entry. It also incentivizes BIPs to align with EU digital and data policies, contributing to a more robust and trustworthy European digital infrastructure. FEBIS proposes a transparent certification scheme so qualified BIPs can integrate into the EBW on equal terms, ensuring quality and security without blocking market entry. Opportunity for SMEs By leveraging certified BIPs, the EBW can help SMEs mitigate information gaps and reduce trade credit risk. The inclusion of the sole traders strategically on the EU business wallet based on their business capacity would help them with trade and would ensure that they are recognised as businesses and using the wallet in their business capacity, to avoid them to be pictured on the EU identity wallet.The European Business Wallet is a pivotal innovation for cross-border business operations in the EU. However, to achieve its full potential, it must be governed in a way that upholds the principles of fairness, inclusivity, and open competition.
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Meeting with Pablo Arias Echeverría (Member of the European Parliament)

5 Mar 2025 · Data-sharing policies, data protection, and cybersecurity

Response to Savings and Investments Union

3 Mar 2025

FEBIS welcomes the European Commission initiative to publish a Call for evidence on the Savings and Investments Union strategy, as this is key to ensure EU Competitiveness, unlock investment in European companies and foster EU businesses in global trade. Business Information providers are key partners to all EU businesses in enabling them to boost competition, trade securely by having through and accurate information about their business partners and trade counterparts and to make relevant investment and trade credit decisions in a global environment. But to be able to provide relevant business information and help EU businesses thrive, getting relevant access to data and ensuring legal and regulatory certainty is key. The key pre-requisite before investing in a business is to ensure that this business is legitimate, accurate and solid, which credit worthiness assessment can greatly help with. In order to provide sound and accurate credit worthiness assessments and report, Business Information Providers need to have their legitimate interest access to business data recognised and a strong legal and regulatory coherence at EU level. To streamline a true EU Single Market that Is able to compete with all other global players and in which investment can freely flow, Business Information Providers are of the opinion that their legitimate interest to access, process, re-use and enhance data should be recognised across all EU legislation. In that sense, the clarification of several elements of the Legitimate Interest of Business information providers that are still unclear would be welcomed through the Savings and Investments Union. All legal bases for data processing are equal: FEBIS would welcome a clearer recognition that legitimate interest is as valid a ground as others and that there is indeed no hidden hierarchy of data processing grounds outlined in article 6 of the GDPR. Legitimate interest can be used for commercial purposes: as outlined in the CJEU, judgement of 4 October 2024, Case C-621/22, Koninklijke Nederlandse Lawn Tennisbond, the fact that data is used or reused for commercial purposes does not rule out the possibility to rely on the legitimate interest as data processing ground. This judgement is of great importance also for business information providers who rely on legitimate interest to process the personal data that they use for their services and products. Another valid recognition in the guidelines is the reference to the CJEU Schufa case (Case C-634/21), which recognizes the legitimate interest possibility for credit scoring. A business information provider can have a legitimate interest to process data for a commercial purpose, especially when this purpose is based on the needs / requirements of its customers, i.e. businesses. Information sharing (including sharing information of personal data) is of fundamental importance for any democratic society e.g. in supporting economic transparency, fostering fair competition, promoting financial stability, contributing to economic development and contributing to sustainable business decision-making and practices. Business information providers role in helping businesses validate information (e.g. validating the accuracy of information shared by a data subject) is a legitimate interest as it is of outmost importance for correct decision making. The need to access Beneficial Ownership information: It is important to underline that AML/CTF (Anti-Money Laundering and Combating the Financing of Terrorism) measures are essential in all the financial system to contribute to freedom, liberty, security and better-known decisions. For this reason, BIPs need to have a legitimate interest by default in having access to the business registers, including the UBO-register (Ultimate Beneficial Owner). This access enables financial institutions to conduct effective due diligence (KYC), mitigating risks and ensuring regulatory compliance.
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Response to Single Market Strategy 2025

30 Jan 2025

FEBIS welcomes the European Commission initiative to publish a Call for evidence on the Single Market Strategy 2025, as this is key to ensure EU Competitiveness and foster EU businesses in global trade. Business Information providers are key partners to all EU businesses in enabling them to boost competition, trade securely by having through and accurate information about their business partners and trade counterparts and to make relevant investment and trade credit decisions in a global environment. But to be able to provide relevant business information and help EU businesses thrive; Business Information Providers need to have more clarity on the following two points: - Ensuring the recognition of their legitimate interests to access and process data, not only for AML purposes but across the board of all relevant Single Market regulations - Having a coherent and consistent regulatory framework both at EU and at Member States level that foster better access to and reuse of data including on sole traders to ensure better data-sharing economy. A detailed overview on these major points is outlined in our attached paper.
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Response to Report on the application of the General Data Protection Regulation

8 Feb 2024

FEBIS members are business information providers whose core business model is to provide creditworthiness assessments, credit scores and business information reports on businesses for businesses. Contrary to credit rating, credit scores are done on all businesses population of a country, using data management and processing, statistical analysis and analysis technologies owned by business information providers. Credit scores and business information reports are then used by credit managers or by other businesses when assessing their trade counterparts, making trade credit decisions, doing compliance checks, and fulfilling Know-Your-Customer obligations inter alia. Important to say, business information and credit scoring providers are not financial institutions or financial providers as they do not lend money; they provide data solutions helping the assessment for lending and trade credit decisions to be made. As outlined in our attached FEBIS submission, we think a clearer view is needed on the level of application of GDPR on sole traders data; we recommend an approach based on the capacity under which sole traders interact. Sole traders should encompass all businesses with data available from a public register, be it the trade register but also the craftsmen register or the business register, and the legal form of the business should not matter. Indeed, as driven by the EC definition, a business should be anyone acting in his trade, business or profession, as opposed to a consumer which is anyone acting outside his trade, business or profession. Please see our FEBIS submission paper for further details. .
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Response to Revision of EU rules on late payments (Late Payments Directive)

8 Nov 2023

Dear Sirs, FEBIS is taking note of the European Commission proposal on the revision of the Late Payments Directive, laying down a common set of rules aimed at combating late payments in commercial transactions between businesses (B2B) and between public bodies and businesses. FEBIS members are business information providers whose core business model is to provide creditworthiness assessments, credit scores and business information reports on businesses for businesses. Contrary to credit rating, credit scores are done on all businesses population of a country, using data management and processing, statistical analysis and analysis technologies owned by business information providers. The raw data used is composed of part of public and open data made available for re-use (e.g. part of business registers data) cf the directive 2019/1024 and its implementing regulation 2023/138 but also a lot of value-added data managed by business information providers under proprietary databases and technologies. Credit scores and business information reports are then used by credit managers or by other businesses when assessing their trade counterparts, making trade credit decisions, doing compliance checks, and fulfilling Know-Your-Customer obligations inter alia. Important to say, business information and credit scoring providers are not financial institutions or financial providers as they do not lend money; they provide data solutions helping the assessment for lending and trade credit decisions to be made. Business Information Providers mission is to help businesses to assess their trade credit risk and to contribute to reduce late payments consequences, avoiding later stages as insolvency or bankruptcy. FEBIS would therefore like to highlight our intended expectations in the attached paper and would very much welcome the possibility to exchange with you on this issue at your convenience.
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Response to Open finance framework

27 Oct 2023

Please find atttached the comments from FEBIS , the Federation of Business Information Services on the proposed Financial Data Access regulation. FEBIS members are business information providers whose core business is to provide business information reports , creditworthiness assessments, credit scores on businesses for businesses. Contrary to credit rating, credit scores are done on the whole population of a countrys businesses,using statistical analysis and proprietary data management and analysis technologies owned by business information providers. The raw data to be used for this purpose is composed of part of public and open data made availabl e for re use (e.g. part of business registers dat a), cf the 2019 1024 directive and the implementing regulation 2023/138 , but also a lot of value added data anaged by business information providers under proprietary databases and technologies. The proposal on Financial Data Access Regulation contains a number of propositions to foster data access potential and enable better data sharing in the financial data space. The levelling of the playing field is a good point, but the current wording or de scriptions of some of the provisions of the FIDA proposal would raise important questions for business information providers, as there seems to be different approaches on the creditworthiness data that would be in scope, and also on the different roles that creditworthiness assessment providers would have. FEBIS members would therefore like to get some clarification of the intended expectations and impact that the FIDA proposal would have on the topics outlined in the attached paper. We thank you in advance for your consideration.
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Response to Adjusting size criteria for inflation in the Accounting Directive to define micro, small and medium-sized enterprises

6 Oct 2023

Please find attached the comments from FEBIS, the Federation of Business Information Services, on the proposal to adjust SME size criteria and the side effects that changing thresholds in the Accounting Directive can have on trade credit and business information. We remain at your disposal for any further information you may require.
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Response to Implementing act on a list of High-Value Datasets

20 Jun 2022

Please find attached the comments from FEBIS ,the Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. We also support the comments made by the PSI Alliance in their contribution.
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Response to Sustainable corporate governance

23 May 2022

You will find attached the feedback from FEBIS, the Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. FEBIS members welcome the European Commission’s proposal to revise corporate due diligence and add more sustainability items, following therefore the recommendations from the EP report from MEP Lara Wolters and from the OECD report. We also welcome the fact that the proposal on Due Diligence is to be seen in conjunction with the Corporate Sustainability Reporting Directive (CSRD) proposal which will pave the way for a better reporting of ESG items in Europe. The proposal aims at enhancing a better global framework for due diligence and at clarifying the regulatory landscape which is most welcomed. FEBIS members however would like to draw your attention on the 4 following points on which clarification may be needed in order to ensure a fully workable and compatible regulatory framework: o Clarification of the definitions and scope and of the type of enterprises concerned o Value chain approach and SME exemption o Sanctions o Definition of business relationship
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

11 May 2022

Please find attached FEBIS ' comments on the Data Act proposal. FEBIS stands for Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. Today´s 140 plus members of our federation are present in nearly 60 countries throughout Europe, Asia, Africa, and the Americas. FEBIS members facilitate B2B trade relations and transactions with a focus on credit and risk intelligence services. These services require updated, accurate and relevant business information to produce beneficial, tailor-made solutions as well as scorings to assess the risk of default of businesses. By interacting between different business users and/or institutions of all sectors and sizes and helping them to take relevant decisions on their cashflow management, FEBIS members can be seen as trustworthy partners providing data and relevant financial information on trade counterparts. They are instrumental in helping companies manage their trade credit (amounting to *4 times the bank lending in several EU Member States), their onboarding and their KYC processes. FEBIS members welcome the European Commission’s will to better promote data flows and exchanges with the EU Data Act proposal and the will to foster a true European market for data. Nonetheless, it seems important to have clarifications on some key issues of the Data Act which may impact the business information sector, such as definitions, scope, voluntary vs mandatory data sharing, B2G data sharing obligations, incentives, the database right and moreover the interaction between the Data Act and other EU legislation. FEBIS members are willing to getting involved in the full debate during the legislative process.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

11 Mar 2022

Please find attached the comments from FEBIS - the Federation of Business Information providers on the ESAP proposal. FEBIS stands for Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks.Today´s 140 plus members of our federation are present in nearly 60 countries throughout Europe, Asia, Africa, and the Americas.FEBIS members welcome the European Commission’s effort to put in place simplified measures for accessing companies’ financial & extra-financial reporting through a single access point interconnecting national business registers and national and EU authorities. FEBIS would very much like to be involved with the European institutions and ESMA in discussions regarding legislative process and implementing guidelines of the ESAP.
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Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

FEBIS members welcome the European Commission’ draft of Corporate Sustainability Reporting Directive (CSRD) unveiled at the end of April 2021 and which aims at facilitating non-financial reporting and considering all aspects relating to economic, social and governance items in company reporting. As reusers of data for developing services helping all types of businesses to know more about their trade counterparts, especially in the framework of trade credit, compliance requirements etc., we support the idea to develop precise and comparable reporting standards. Some additional comments FEBIS members would like to put forward: - The proposal for a directive stresses that “governance factors include management and quality of the relationship between business partners, including payment practices”. In FEBIS’ members views, it is very important to consider trade credit and payment terms or payment delays practices as a core item of the corporate reporting. As also shown during the current crisis, prompt payment or the ability to negotiate payment terms are a key element of a company policy and reputation. The reporting on this particular topic will have to be as precise as possible, demonstrating the way the company has worked during all the financial year and the way it intends to go on or improve its internal policies and processes. - The need to ensure compatibility between financial and sustainability reporting items and data management: the draft directive proposes to have one single electronic reporting format which would include both structured and non-structured data, financial and non-financial and would be machine-readable with a coherent and agreed digital taxonomy. From our point of view, common definitions are the key issue, for both preparers and reusers. Please note that, in some MS, the filing of the balance sheet, P&L and annexes is not yet required in a machine-readable format, except for listed companies cf ESEF. We do understand then that article 19d will apply for the balance sheet, P&L and annexes + the sustainability reporting + the information required by the article 8 of the Taxonomy regulation (+ delegated acts), the latter being available in the management report, which may be a high step to climb for some EU companies. - The support to electronic format reporting and to a common reporting to be included in the management report, even for small and micro companies. The management report is a key element of business information and reporting, and it should be considered as crucial. As such, management report should be required from all companies, whatever their size, should be filed to the Business Register, possibly in a machine readable format. - The need of a fair level playing field, to also include corporate sustainability reporting for SMEs, be it with special adapted processes, to help foster a better access to credit for them. - The need to amend the Accounting directive to promote transparency (cf the “confidentiality option” granted in some MS, where non-disclosure by the Business Register can be required) and compatibility with AML and other business transparency regulations - The proposal also considers extending the scope of the sustainability reporting to all “large undertakings” + listed SMEs, this should be welcomed and even extended to some smaller companies as their “corporate identity” will more and more include immaterial reporting such as ESG factors. - The need to consider both quantitative and qualitative information for financial and non-financial reporting, as both are key for business information purposes and to enable better access to finance for a lot of companies.
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Response to List of data for the exchange of information between Member States in company law procedures for cross-border operations

20 Apr 2021

FEBIS is the federation of leading Business Information Services Providers. Today it has developed into an organization comprising 130 full members involved in providing credit management solutions and business information services of national and international importance. Supported by a combined workforce of over 27.000 employees, FEBIS members and associate members analyze over 1,300 million entities annually for over 1.6 million customers (businesses of all sizes and economic sectors), providing these clients with business support for the provision of credit and other commercial services on all economical agents in Europe. Aggregate sales turnover of FEBIS members and its associate members is about € 11,000 million. More information on FEBIS at www.febis.org FEBIS members thank you for the opportunity to comment on the planned implementing regulation regarding BRIS data. As a representative of business information providers re-using public sector information for years, and on behalf of all businesses daily using business information services , we would like to highlight the comments we already made on the Open Data Directive and the High Value Datasets: all information to be publicly disclosed by businesses, including publicly available information on beneficial owners that is made available at national level by business registers and central national beneficial ownership registers should also be made available as open data and as High Value Dataset as outlined by the PSI III directive. According to: - the schema provided page 43 of the annex to the draft implementing regulation on BRIS, - the Implementing regulation (EU) 2021/369 of 1 March 2021 dedicated to the interconnection of national central beneficial ownership registers (BORIS), data made available for individual searches through the e-justice portal should also be made available as open data, in order to enable businesses working with suppliers and customers from all over Europe to make their due-diligence more efficiently. From our point of view, it would be totally in line with the objective of the Strategy for Data as well as improving the transparency of the EU economy. Data on business and business ownership information (including all the BRIS data) should be made available for reuse as High Value Dataset under the Open Data Directive so that all those who are best placed to provide relevant value-added services and data can build upon public sector data made available for re-use. The datasets included in all Business Registers and also the ones from BRIS should be dealt with in a similar way than what is enshrined in the Open Data Directive and in the High Value Dataset draft.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

FEBIS thanks the European Commission for putting forward an Impact Assessment on a proposal for a directive/regulation on a European single access point for financial and non-financial information publicly disclosed by companies. FEBIS Members represent business information providers all across Europe and worldwide. Business information is used on a daily basis by a large number of enterprises and actors in Europe and globally, first and foremost, to check the existence of a business and help managing trade credit by taking informed decision thanks to updated and accurate information on trade counterparts. As outlined in the attached paper done by FEBIS on trade credit, getting updated and accurate information on business counterparts helps avoiding cascade liquidations, which is all the more crucial in the current economic turmoil. They therefore need to get updated, accurate and relevant access to public sources on financial and non-financial information disclosed by companies, which should be broad and should include all information that is made available through any type of business register, including enterprises, craftsmen, sole traders, no matter the legal form of the business. Data should encompass as PSI all attributes that are collected and made publicly available to ensure effective business identification and adequate transparency. This would include inter alia all information on sole traders but also on legal representatives, beneficial owners, filing and any other items that are available in the different national business registers which should be made available as high-value datasets. It is therefore crucial to consider all “businesses” and not only “companies” in the scope, even if companies (listed and non listed) could be considered as a first step, the ESAP being part of the CMU Action Plan of September 2020. We do confirm that interoperability is a key issue, as well as harmonisation of disclosure rules and standardisation of formats of information. The use of a machine-readable format in all MS would be a great step, not only for listed companies cf ESEF but also for non-listed companies.  FEBIS members would very much like to be involved in any forthcoming discussion launched by the European Commission on the issue, and to be able to provide their expertise on business information in the workshops, studies, or other relevant working tools the Commission will put in place on the subject. FEBIS is the federation of leading Business Information Services Providers. Today it has developed into an organization comprising about 140 full members involved in providing credit management solutions and business information services of national and international importance. Supported by a combined workforce of over 27.000 employees, FEBIS members and associate members analyze over 1,300 million entities annually for over 1.6 million customers (businesses of all sizes and economic sectors), providing these clients with business information enabling them to assess the risk of a potential or existing commercial contract and other commercial services on all economical agents in Europe. Aggregate sales turnover of FEBIS members and its associate members is about € 11,000 million. More information on FEBIS at www.febis.org
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Response to Implementing act on a list of High-Value Datasets

24 Aug 2020

Dear Sirs, Please find attached the comments from FEBIS, the Federation of Business Information Services on the importance of ensuring a large scope for High value Datasets on company and company ownership. to ensure that business transparency remains high in the Internal market and that the Open Data and PSI directive will contribute efficiently to the success of the strategy for data as well as the EU Common Data Spaces.
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Response to Fitness check on public reporting by companies

7 Mar 2018

Dear Sirs, You will find attached the feedback paper from FEBIS- the Federation of Business Information Services - on the Fitness check on public reporting by companies, outlining the major issues seen by business information and credit reporting service providers in the EU.
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