IBAT News

Summer Politics


With the delays in the primaries subsequent to hurdles with
the new redistricted election maps, we have the odd opportunity to vote in
runoffs at the end of this month.  The last round of elections prior to
November are set for July 31.  Early voting starts on the 23rd,
and will run only until the 27th  rather than the customary two
week period. 

Many of you have received emails from us seeking input on
your local races.  We did not poll every district in which there is a
runoff, but rather those where we heard from you requesting support or have had
direct communication with one or more of the candidates.  The majority of
the surveys reflected a "split" in support among our membership, which results
in neutrality for us.  We very much appreciate all of the input on these
races as we determine which, if any, of the candidates to support. 
Further, we are tremendously grateful to all of you who have supported the IBAT
PACs financially over the years.  It makes a difference!

We have engaged and made PAC contributions in several "open
seat" races based upon the overwhelming support of the members polled:
 Randy Weber (Congressional District 14); Roger Williams (Congressional
District 25);  Filemon Vela (Congressional District 34);  Greg Bonnen
(TX House 24);  and,  Bennett Ratliff (TX House 115).

Additionally, we have supported a number of incumbents who
are engaged in runoff elections:  Jeff Wentworth (TX Senate 25); Chuck
Hopson (TX House 11);  J.M. Lozano (TX House 43);  Sid Miller (TX
House 59);  and, Jim Landtroop (TX House 88).   Supreme Court
Justice David Medina also has the support of the IBAT PAC in his runoff for
Place 4. 

IBAT has endorsed and the IBAT FedPAC has contributed to Lt.
Governor David Dewhurst in his campaign for U.S. Senate.  The IBAT PAC
Committee at its meeting last week voted to provide additional financial
support for Governor Dewhurst.  We have enjoyed an excellent working
relationship with Mr. Dewhurst and his staff over the years. 

We strongly encourage you to vote in these
important elections, and encourage your circle of influence to do the
same.  Turnout will no doubt be low in this unique election cycle, which
makes your vote even more important.

NorthStar Bank of Texas


NORTHSTAR BANK OF TEXAS
Habitat for Humanity Project

July 6, 2012 - In mid-March, NORTHSTAR BANK OF TEXAS and Denton Bible Church partnered in a Habitat for Humanity Project in Denton, TX.  The three month construction project brought both organizations together with the intent of giving back to their community.

A house dedication took place on June 19th for the Nunez Family where volunteers, friends and families came together to see the finished project and to celebrate the completion.

Throughout the course of the project, NORTHSTAR BANK OF TEXAS and Denton Bible Church had close to 100 volunteers from each entity come together on Saturdays to swing hammers, sheetrock walls, paint, do landscaping, and all that goes into building a home.  Breakfast and lunch was provided on each Saturday's work schedule and much of it was donated by local businesses.

In addition, there were many construction professionals who donated their services as well.  Denton Bible found resources from Taylor Trim, Jeter 3 Company, Master Electrician Paul Strickland, Work Environmental, Elite Door and Trim, and Atlas Construction.  NORTHSTAR brought in professional help from Kent Key Construction, Quickset Concrete, CBS Mechanical, Dan's Painting and Gateway Concrete.  Habitat for Humanity has been blessed with the help of many businesses throughout the year; Woods & Floors, Whirlpool, Valspar Paint, Schneider Electric, Whitworth Engineering, K&K Landscape Services, Adam's Pest Control, Essex Woodworking, United Copper Industries, Sherwin Williams Paint, and Trinity Roofing.

Tony Clark stated at the house dedication that "this was such an awesome experience to participate in as we watched an empty lot become a family's dream home; working on this project was not only good for the community, it was a rewarding and fun experience for our employees."

As the largest community bank in Denton, and one of the largest in the Dallas / Ft. Worth area, NORTHSTAR continues to lead in the banking and mortgage industries.   Their professional staff and personalized style of banking have been the key ingredients to their success. 

Member FDIC and Equal Housing Lender

For more information please contact Michele Barber at 940-383-6211 or mbarber@nstarbank.com

Consumer Tips July 2012


"Pay
it off every month!"  That is what your
parents always told you when you first started using credit cards.  "Pay it off every month and you won't get bad
credit."  If your goal is to save money
on paying interest then this might be the ideal approach.  However, this won't keep you from getting bad
credit.  If your goal is to improve your
credit score then you may actually be hurting your credit rating by paying it
all off every month... Read more.

Fun Fact Friday


If you think you've been asked some bizarre questions at work, read on... Your IT department might win this one.

From the
category "the strangest or most unusual requests ever received":

  • "Can
    you come over and plug this cord in for me?"
  • "How
    do I remove a sesame seed from a keyboard?"
  • "How
    do I pirate software?"
  • "Can
    I turn on the coffee pot with my computer?"
  • "How
    do I clean cat hair out of my computer fan?"
  • "I
    dropped my phone in the toilet. What should I do?"

From the
category "lending a hand well outside one's job description":

  • "Can
    you recommend a good dry cleaner?"
  • "I
    can't find my packages online. Can you help me?"
  • "Can
    you help me repair a washing machine?"
  • "We
    need you to fix the microwave in the lunchroom."
  • "Can
    you help me fix my toilet?"
  • "Where
    can I find a video of Elvis Pressley online?"
  • "Can
    you help me fix my chair?"
  • "My
    car's cup holder is broken. Can you help me fix it?"
  • "Can
    you help us get money out of the vending machine?"

And lastly, from
the category of "Computer 101 questions":

  • "Will
    you show me how to use the mouse?"
  • "How
    do I send an email?"
  • "How
    do I start the Internet?"
  • "My
    computer won't turn on or off." (The computer wasn't plugged in.)
  • "How
    do I click on different files?"
  • "I'd
    like to download the entire Internet so I can take it with me."

Read the entire article on the CFO Daily News website.

CFPB Proposed Rule


On
June 28, 2012 IBAT filed a comment letter with the CFPB on the proposed rule
to Implement Ability to Repay Mortgage Standards. The letter reiterates points
made in similar comment letters filed in 2011 with the Federal Reserve. IBAT
continues to stress that the availability of credit in numerous communities is
adversely affected by the escrow requirements imposed on "higher-priced
mortgage loans" and any ambiguous "presumption of compliance"
with the ability to repay requirements will continue to erode the availability
of credit in those communities.

Innovation


As branches of the federal government wrestle with the
future of healthcare in America, others in the private sector are looking for
actual solutions to tackle burgeoning costs.  Yesterday, The Kempton Group
Administrators Inc., sister company of The Kempton Company (administrator of
the IBAT-endorsed Advantage
Health Plans Trust
), was
recognized
for doing just that.

The praise came for the company's Premier Provider
program, which identifies healthcare providers that offer transparent,
greatly-reduced, all-inclusive cash prices, often resulting in up to 70% cost
reduction for certain procedures.  Providers
allow Kempton's participants to access this pricing, because the benefit plans
are self-funded.   Reduced pricing, however, is not just a
benefit enjoyed by the self-funded benefit Plan, as
participants using a Premier Provider incur no out-of-pocket cost for
procedures.   As a result, claims are
paid at 100% and quickly.

"Most people don't realize that for many
procedures and treatments, there can be up to a 400% variance in cost between
providers of healthcare, regardless of the quality of that care," said Jay
Kempton, President & CEO of The Kempton Group Administrators. "Being
aware of these differences and consciously making better healthcare purchasing
decisions is one of the most important steps towards bending the cost
curve."

The Kempton Company's innovative solution was
recognized by the HCC
Life Insurance Company
, which highlights new trends and approaches employed
by insurance administrators to contain costs. 

Amber Alert

THIS IS A CHILD
ABDUCTION ALERT ISSUED BY THE TEXAS AMBER ALERT NETWORK

 

The SAN ANTONIO POLICE DEPARTMENT is searching for GABRIEL RIVERA, HISPANIC, MALE, 3 YEARS old, DOB 12/13/08, 3’0”, 34 LBS, BROWN HAIR, BROWN EYES. 

Police are
looking for ROBERT MEDRANO JR. AND MONICA SOTO IN HIS
abduction.

The suspects
are driving a GOLD, 2000, FORD, EXPLORER with a TX License Plate Number of 57R8454
The suspect was last heard from in SAN ANTONIO, TX

Law
enforcement officials believe this child to be in grave or immediate danger.

If you have
any information regarding this abduction, call the SAN
ANTONIO POLICE DEPARTMENT AT 210-207-7660.
  

Planning the Future


IBAT
leadership bankers from across the state gathered last week for two days of
Committee and Board meetings.  In addition to the normal reports and
discussions of IBAT activities, the Board approved the Convention Policy
Resolutions and recommendations for Bylaws amendments submitted by the Bylaws
and Nominating Committee.  These will be reviewed and voted on at the
Annual Meeting of the Membership at the IBAT Convention in October.

Rogers
Pope, Jr., President and Chief Operating Officer of Texas Bank & Trust,
Longview, was nominated as Secretary-Treasurer.  The remainder of the
proposed leadership of IBAT, to be voted on at the Annual Convention, includes
John W. Jay (Roscoe State Bank) as Vice Chairman;  Jay Gober (First State
Bank, Graham) as Chairman-Elect;  and Troy Robinson (Bank Texas, Quitman)
as Chairman.  Scott Heitkamp, the current Chairman of IBAT, will remain in
a leadership position as Immediate Past Chairman. Several new directors were
nominated as well, and will be announced when all have accepted.

The
Board also reviewed and approved the recommendations of the IBAT Legislative
Committee regarding our proactive agenda for the upcoming 83rd Texas
Legislature.  Additional information will be forthcoming, and we encourage
you to "save the date" - February 5 - for the IBAT Legislative Day in
Austin.

Baker Market Update


[Last]
week proved that the equatorial latitudes of the world's oceans are not the
only place in which summer doldrums exist. With the news-worthiest of events
taking place in other arenas, the U.S. Treasury market had little reason to
leave the lower, narrower trading range it has inhabited for the past several
weeks. After starting the week around 1.60%, the Benchmark Ten Year note
reached its low yield of the week (1.57%) [last Thursday], before [Friday]
morning's sell-off pushed that level up to around 1.65%.... Read more in the Baker Market Update.

Is your ATM a Lawsuit Risk?


You may have missed it last week.  Not long after it issued its opinion on
the Affordable Care Act, the Court announced its decision in First American
Financial v. Edwards,
the decision every banker had looked forward to as a
cure for the recent epidemic of EFTA "statutory damages" class actions.  
So, how did the court rule?  It didn't.  Rather than issuing a
decision the Supreme Court dismissed the case, effectively spitting the hook on
this important question.  And now, I have more bad news.  The same
lawyers who vigorously pursued the EFTA "class actions" for lack of a second
sign on your ATM have found a new non-compliance issue:  are your ATMs
accessible to the blind and persons with disabilities? 

These lawyers say "no" and already have started filing "class actions" seeking
injunctions and damages to enforce their position.  A check of Court
records shows that one set of firms has filed no less than ten such lawsuits in
federal courts for the Northern and Eastern District of Texas since June
13.  Experience teaches that these are the first of many such suits; it
also teaches that how our industry reacts to these first cases will have a
large impact on whether more are filed. 

The legal background for this new wave of suits comes from federal and state
statutes and regulations designed to remove architectural barriers for the
disabled.  These statutes generally track Title III of the Americans with
Disabilities Act [the "ADA"], which requires places of public accommodation, a
term defined in the ADA to include banks, to provide disabled customers with
reasonable and appropriate accommodations that enable them to partake of the
bank's services to the same extent as non-disabled customers because of their
disability.

To implement the ADA, the Department of Justice established advisory committee
to create accessibility guidelines that became known as the ADA Accessibility
Guidelines, usually referred to as ADAAG.  There are two comprehensive
sets of these ADAAG, one issued in 2004 and another issued in 2010.  The
2010 Standards, which incorporate the 2004 standards and include provisions
governing ATMs, became effective on March 15, 2012.  Under the ADAAGs, at
least one ATM at every location must meet the specific requirements in ADAAG;
the ADAAGs treat lobby ATMs and drive-up ATMs at the same facility as two
different locations; therefore, say the Plaintiffs, machines at both locations
must comply.  The issue will be particularly acute at drive-up ATMs, where
it is more difficult to provide a reasonable alternative service.

As with the EFTA cases, there are potential responses and defenses; they are
"potential" at this point because the 2010 ADAAGs have only been in effect
since March, and there is virtually no case law addressing where the main
statutory language meets the ADAAGs.  It also appears to be reasonably
probable that these cases probably will not proceed as "class actions,"
although that is relatively little solace for those who are affected:  an
injunction requiring the Bank to take action requires the same action
regardless of whether there are one or a million plaintiffs.

So what do you do?  Just as it was with the EFTA signage cases, the best
way to avoid a problem is to make sure your ATMs are compliant; if they provide
audible services for visually-impaired users, check the functionality from time
to time to make sure it works.  The response for many banks will be that
they have ordered new, compliant equipment but that the manufacturer has not
been able to deliver it yet because of high demand.  That's good as far as
it goes, but some judge will ask, "What are you doing in the meantime?" 
What are you doing in the meantime?

And if you're sued?  No one wants the publicity of being the "bad guy" in
a suit by a blind or disabled individual, but ADA and the companion Texas Act
include words like "reasonable" and "undue," which mean there are
defenses.  Those words are important but work best when you have taken
steps in advance to create accommodations for disabled customers.  It is
not improper or unreasonable to make a plaintiff prove their case and to show
that their injury is real rather than self-directed for profit.  Our work
with EFTA cases suggests it may be possible to resolve these claims early and
proactively.

The other issue is insurance.  Here, the fact that ADA does not provide a
remedy in damages may initially prompt insurers to deny coverage. 
Nonetheless, this is an issue that should be carefully considered.  To
ensure that coverage is not lost because of late notice, submit the claim
early; it may be possible to start a dialogue with the insurer that leads to
some support, just as occurred when IBAT members and IBAT Financial Services
worked with insurers to secure coverage for EFTA suits.

The Supreme Court's non-decision in First American and this new wave of
suits ultimately carry a simple, overarching message:  there aren't going
to be any "silver bullets" we can use to resolve these issues.  We will
have to roll up our sleeves, work on compliance, respond appropriately and
forcefully to litigation and work with our insurance professionals to resolve
risk management issues. 

Thomas B. Alleman is of Counsel, Cox Smith Matthews
Incorporated, 1201 Elm, Suite 3300, Dallas, Texas 75270.  Please direct
questions to the author at 214 698 7830 or talleman@coxsmith.com.  The
material discussed in this article is for general, educational purposes and
does not create an attorney-client relationship.

TAG Extension A Win-Win


If
unlimited FDIC protection for non-interest-bearing accounts is so good
for the biggest American banks, then why is the American Bankers
Association silent on the need for the program to be extended?

This is the question that came to my mind time and time again as I read "More Evidence TAG Helps Only the Big Banks" in American Banker
last week. The piece, written by Christopher Whalen, senior managing
director of Tangent Capital Partners, certainly made some interesting
points. Mr. Whalen supports his claim with the following arguments... Read more.

ICBA: Fine Points


This month 236 years ago, our Founding
Fathers set in motion our country's radically ingenious American experiment. No
other social or political revolution has done more to spread freedom,
opportunity and prosperity.

As our country continues its slow recovery
from the recent financial and economic debacle, we shouldn't lose sight of, or
forget to tell others about, how essential community banks are to sustaining America's
great economic promise. Jefferson, Madison, Hamilton and the other founders
understood that personal political freedom and individual economic liberty are
intertwined. Each helps ensure the other. That remains as true today as in
1776.

The
roots of our diversified community banking system-a dynamic system unmatched by
any other country's for its resiliency-extend back to our nation's earliest days.
By backing hard work, initiative and ingenuity, community banks remain the most
widely accessible gateways to the American economic dream. By their very missions and operational models, community banks most
efficiently and safely deploy our country's collective economic capital. Turning local
deposits into fertile funding for local small businesses and households,
community banks provide vital support to the backyard inventors and startup
entrepreneurs that fuel our nation's economy. Community banks are this nation's
primary small-business lenders, and small businesses generate more than 70
percent of all new jobs, often in new industries with bright futures.

True
freedom stems from having a viable chance to achieve one's own financial
goals, to control one's own economic destiny, to succeed based on one's own talent,
effort or ideas. Whether a dream involves a candle-making shop or a software
development firm, those opportunities remain the most accessible and alive at
community banks.

Today's sharp policy debates in Washington
and on this year's campaign trails reflect the decisions Americans face in
recalibrating the role of government in the aftermath of the Wall Street
financial crisis. In part because of your efforts and ICBA's, the dangers of
financial overconcentration and unstable too-big-to-fail institutions also
figure prominently in that debate. So, too, does the discussion of what is
appropriate and sensible regulation for community banks and small businesses.

America is listening. Most people recognize
that our country's economic recovery depends significantly on the ability of
small businesses to grow and create more jobs. As community bankers, your
firsthand work and experience as responsible stewards of our Main Street
economies have never been more relevant and important. Your views can influence
the direction and trajectory of our country's economic public policy as never
before.

Every
day community banks like yours-where direct accountability
still drives common-sense decisions-continue to fulfill America's founding
ideals of economic liberty and opportunity for all. Never forget that's what you
do, and what, together, we are working to pass along to future generations.

Happy
Independence Day!

Risk-Based Capital Rules


Last
week, the Independent Community Bankers of America (ICBA) posted a comprehensive summary of the new interagency
proposed rules on risk-based capital. The summary covers proposed capital
ratios and their phase-in schedule, prompt corrective action requirements and
asset risk weight requirements.

IBAT,
along with ICBA, is researching the various provisions proposed and is
preparing an official comment letter.   Further, we will be meeting
with senior regulatory officials in mid-July to discuss the community bank
concerns relative to the proposed rule, continuing our history of involvement
on this developing issue. 

Bearden's Tips on Leadership



CONCEPTS
In my younger days-much younger-I had the privilege of serving as a Marine officer. The training required to earn a commission in the Marine Corps is rigorous, and the providers of that training are mighty demanding. They are also very good at what they do. You might say that they have a passion for it.

One of my instructors at Officer Candidates' School was a Marine gunnery sergeant, a "gunny" (although officer candidates are well advised not to take the liberty of calling them anything other than "gunnery sergeant"). The "gunny" was absolutely certain that his mission as an instructor at OCS was to ensure that every one of us who earned our commissions (survived his tender mercies) was able and willing to lead Marines just like him.

The "gunny" used every activity as an opportunity to teach us fundamental truths about leadership. Field exercises, long runs, classroom sessions and every imaginable form of physical training became his "pulpit" for instilling in us his passion for leading men in difficult situations.

There are probably variations on his central message that are more eloquent or sophisticated, but none will ever have more impact on me than the lesson on leadership we learned from the gunny:

"You can't lead from the rear!"

That lesson from a man for whom I had-and still have so much respect, is the basis for what I see as a key characteristic of effective leaders. They are out front.

THEORY TO PRACTICE
Here are some suggestions for putting this tip to use:

1. I want to begin a process we'll continue in subsequent tips in this series, so as you complete these steps, remember that we'll come back to them later.

2. I want you to make a list of some of the people you admire for their effectiveness as leaders. They can be people with whom you've worked or people you've admired "from afar".

3.Next, I want you to identify some of the specific things those people have done or are doing to earn your respect for them as leaders

4. Here are some points to consider as you complete your lists:

  • Notice that what I'm asking for are specific behaviors, and not characteristics of behavior
  • If you've listed things like "courageous", "professional", "good communicator" or other such terms, what you've identified are not specific behaviors but characteristics of behavior
  • What I'm looking for here are the specific things the people on your list did or are doing, the specific behaviors they've exhibited to earn your regard for them as leaders

5. The point I'm making here is that "lead" is a verb; leadership is a composite of the things leaders do to get "out front."

Jim Bearden, CSP
jim@jimbearden.com
www.jimbearden.com
512-306-1797

Excellence in Leadership


Darrell Brown, Senior Vice
President of Business Development with Town and Country Bank was awarded IBAT's
Excellence in Leadership Award at the 2012 Leadership Conference, June 15 in
The Woodlands.

The
Excellence in Leadership Award is presented annually by the Leadership Division
Board of Directions, honoring personal commitment to the division, as well as:

  • Outstanding
    leadership recognition within their community;
  • Selfless
    donation of time to promote, support and serve independent bankers in the
    state of Texas; and
  • Creating
    excitement about political action and support for the PAC.

Brown
is a past president of the IBAT Leadership Division and current member of the
IBAT Education Foundation Board of Directors.  In 2007, he was honored
with the IBAT Chairman's Award.  In addition to his involvement with IBAT,
he has been active with the Stephenville Chamber of Commerce, the NAACP,
Tarleton State University Texan Club, United Way of Erath County and a member
of the Stephenville City Council.  

"Darrell
Brown is a tireless giver, supporting IBAT and its mission," said outgoing
LD President Angie Brown, who presented the award.  "He has given
literally thousands of hours to support this organization, and I cannot think
of a more worthy recipient."

Photo: IBAT Leadership Division President Angie Brown presents
Darrell Brown with the Excellence in Leadership Award.

Frost Bank


Commissioner
Charles Cooper announced last week that Frost Bank has completed
the conversion process and is now a state-chartered bank.

"Frost is the only one of the ten largest Texas-based banks to survive the
1980's crisis without merging or closing, and their commitment to Texas is
clear," said Chris Williston, President and CEO of IBAT.  "We
appreciate the long-term partnership between IBAT and Frost, and their
commitment to community banking.  This charter conversion is a strong
signal that they intend to remain a Texas-based force in the financial services
industry in our state for years to come."

Texas Bank Files Lawsuit


The
State National Bank of Big Spring, along with at least two other think tank
groups, filed suit in the District of Columbia federal
court last week challenging the constitutionality of the Dodd-Frank financial
reform measure.  The suit specifically challenges the creation of the
Consumer Financial Protection Bureau (CFPB) because Congress does not appropriate
its budget and the courts face restrictions in reviewing its rule making
authority.

"My
phone began to ring off the hook Thursday afternoon when the lawsuit was
filed," said IBAT President and CEO Chris Williston.  "Members
of the financial press wanted to know about the bank's involvement and whether
IBAT was directly or indirectly involved."

IBAT
is not a plaintiff in the lawsuit and was never contacted about our initiating
or joining the suit.  The IBAT Board will receive a complete briefing on
the suit and its prospects at its regularly scheduled meeting in Austin later
this week.

CFPB Arbitration Clauses


As
required by the Dodd-Frank Act, the CFPB is studying the issue of pre-dispute
arbitration clauses in consumer transactions. As a preliminary step, the CFPB
requested information to identify the appropriate scope of the study and the
methods and sources of data for conducting the study. IBAT commented on the three areas identified by the
CFPB: prevalence of use, use and impact in particular arbitral proceedings and
the impact and use outside particular arbitral proceedings. IBAT's primary
message to the CFPB is to urge support for the U.S. Supreme Court's approach,
which provides businesses with a template for fair arbitration provisions, and
to advocate reasonable parameters on arbitration clauses in consumer
transactions.

IBAT Leadership Division


The IBAT Leadership Division, the nation's largest organization for present and future banking leaders, is expanding its reach to provide more opportunity for its members to connect.  The change was recently approved at a meeting of the Leadership Board of Directors following recommendations made by its Strategic Planning Committee.  

The plan calls for the creation of eleven chapters throughout the State of Texas which will elect its representatives to the Leadership Board and establish local committees to provide opportunities for greater involvement for the Division's 550 members.  Three committees will be established in each of the districts to help advance the Division's mission of assisting IBAT in raising political action committee funds, providing local specialized education and networking opportunities and expanding the Division's membership.

"The Board unanimously and enthusiastically endorsed the new structure," said Brandon Bartek, Mills County State Bank, Early.  Bartek was named Chairman of the Division for the 2012-2013 fiscal year.  "We needed a structure that would allow for the membership to work on Division projects and that could tap the expertise of so many that have expressed interest in being involved.  I'm excited about these enhancements, and the opportunities to increase banker involvement in an already terrific organization."

Two regions (Texas Panhandle and Northeast Texas) will serve as pilots this year.  Other regions will begin to phase into the new structure over the next several years with full implementation scheduled for 2015. 

Leadership members will soon receive details of the plan and are encouraged to engage in this important opportunity to further the cause of community banking, as well as foster personal and professional development. 

Fun Fact Friday


Money can't buy happiness, but how much would it take to
make you feel successful?

A recent
survey conducted by CareerBuilder
found that the answer for most Americans
might be less than you'd think.  According to the survey, "the vast
majority of U.S. workers - 75 percent - don't feel that they need to earn six
figures in order to be successful."

Twenty-eight percent of respondents said that a salary of
$50,000 to $70,000 a year would give them a feeling of success.  Twenty
three percent put the number at less than $50,000.  Only one in ten said
that it would take $150,000 or more.

Men were twice as likely than women to say it would take six-figures
for them to feel successful.   

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