I chal­lengerS’ strate­gies 2019 WHO, WHAT & HOW

CEOs of the 15 new BFSI or­ga­ni­za­tions (Chal­lengers) opened their hearts and minds for our cover story on the road ahead:

Banking Frontiers - - Cover Story -

n the last few years, the num­ber of BFSI or­ga­ni­za­tions in In­dia has mush­roomed. With RBI giv­ing out new bank­ing li­censes and sev­eral new dig­i­tal-DNA driven NBFCs emerg­ing, Bank­ing Fron­tiers in­ter­viewed CEOs of 15 or­ga­ni­za­tions com­pris­ing pay­ments banks, small fi­nance banks, in­sur­ance com­pa­nies as well as NBFCs.

This study probed 4 key as­pects that are deeply rel­e­vant in to­day’s sce­nario - op­por­tu­ni­ties, chal­lenges, com­pe­ti­tion and trans­for­ma­tion. Since tech­nol­ogy has be­come the pil­lar of all ac­tiv­i­ties, it was an area of spe­cial fo­cus. We ap­proach 40 new BFSI or­ga­ni­za­tions and are thank­ful to the 15 that re­sponded.


Dig­i­ti­za­tion has be­come an im­por­tant el­e­ment of the BFSI in­dus­try. Many things to­day are done through dig­i­tal channels and all the tra­di­tional banks are us­ing dig­i­tal in­ter­net bank­ing and mo­bile bank­ing. The chal­lengers are cre­at­ing com­plete pa­per­less mod­els. Dig­i­ti­za­tion is also ris­ing in ru­ral ar­eas thanks to smart phone pen­e­tra­tion.

In­dia is a cash dom­i­nated econ­omy. Due to dig­i­ti­za­tion, there is a shift from cash to non-cash and it will con­tinue in 2019. In 2019, most of the lend­ing banks in In­dia will be dig­i­tized in the way they source and ser­vice their cus­tomers for many of the prod­ucts and pay­ments so­lu­tions. Ra­jeev Ya­dav, MD & CEO at Fin­care Small Fi­nance Bank shares the de­tails of dig­i­ti­za­tion strat­egy adopted by his bank: “Fin­care Bank has fo­cused on dig­i­tal bank­ing from the first day of its launch. Open­ing of ac­counts in 15 min­utes and pa­per­less lend­ing are pop­u­lar among our mi­cro-fi­nance cus­tomers as well as li­a­bil­i­ties cus­tomers.”

ART Hous­ing Fi­nance is work­ing to­wards mak­ing the home loan a fully dig­i­tal prod­uct rid­ing on tech­nol­ogy. The com­pany is cre­at­ing dig­i­ti­za­tion of doc­u­ments, pro­cesses and de­ci­sion mak­ing, com­bined with the use of smart tech­nol­ogy and in­no­va­tive credit methodology to cover the new-to-credit seg­ment. It aims to pro­vide cus­tomers with a seam­less and has­sle-free ex­pe­ri­ence.

Its MD & CEO Arvind Hali said: “With a clear fo­cus on dig­i­ti­za­tion, use of tra­di­tional and non-tra­di­tional credit scor­ing an­a­lyt­ics, rapid distri­bu­tion ex­pan­sion and prompt ser­vice, ART Hous­ing Fi­nance is all set to cre­ate sig­nif­i­cant im­pact in the hous­ing fi­nance mar­ket in 2019.”

Dig­i­tal lend­ing com­pany Flex­iloans.com be­lieves in pro­vid­ing MSME loans in 48 hours. Co-Founder Man­ish Lu­nia shares: “We will con­tinue to ex­pand our of­fer­ings in terms of prod­ucts, geo­graph­i­cal reach, so cus­tomer feel easy in ap­ply­ing the busi­ness loans at a click of a but­ton.”

Digit In­sur­ance pro­vides smart­phone-en­abled self-in­spec­tion ser­vice to its cus­tomers. As nowa­days ev­ery­one is com­fort­able us­ing a smart­phone and with the help of the sim­ple cam­era fea­ture, the in­spec­tion time can be brought down from a week to 11 min­utes. CEO Vi­jay Ku­mar com­mented on mod­ern­iza­tion of prod­ucts due to dig­i­ti­za­tion: “We fo­cus on mod­u­lar­iza­tion, re­haul­ing of pro­cesses and dig­i­tal­iza­tion in mak­ing of our prod­ucts. For ex­am­ple, in our Travel De­lay prod­uct, 100% of the claims are au­to­mated be­cause we can track the de­lay of a cus­tomer’s flight, au­to­mat­i­cally, with­out any need for the cus­tomer to file a claim.”


In the last few years, the BFSI sec­tor has wit­ness a tech­nol­ogy rev­o­lu­tion un­like ever ear­lier. Ar­ti­fi­cial in­tel­li­gence, ma­chine

learn­ing, blockchain, an­a­lyt­ics, RPA, API, data sci­ence, etc, are rac­ing into the ecosys­tem.

Cigna TTK Health in­sur­ance uses AI and an­a­lyt­ics for un­der­stand­ing the cus­tomers’ needs and to cus­tom­ize its prod­ucts. Cover­fox will use ma­chine learn­ing in 2019 to help cus­tomers con­ver­sion and cost cut­ting. The in­suretech sees a big op­por­tu­nity for blockchain in the com­ing years but has a con­cern that it needs to be adopted across the in­sur­ance in­dus­try for it to work. The com­pany also started us­ing a chat­bot that helps cus­tomers in choos­ing the right pol­icy suit­ing his needs.

Tof­fee in­sur­ance sees a big op­por­tu­nity for AI and data sci­ence. CEO Ro­han Ku­mar says: “We will see AI and data sci­ence play a big­ger role in in­sur­ance. It will help in un­der­writ­ing and pric­ing prod­ucts for cus­tomers, an­a­lyz­ing the ca­pac­ity of claims and process thereby mak­ing so­lu­tions more ef­fi­cient. Fraud mit­i­ga­tion will lever­age both these tech­nolo­gies where smart al­go­rithms will dic­tate pay­outs based on past and pre­dicted con­sumer be­hav­ior.”

He fur­ther adds: “An­other de­vel­op­ment to watch is the emer­gence of blockchain tech­nol­ogy and how var­i­ous in­dus­tries across sec­tors are adopt­ing it. The same has been slowly pen­e­trat­ing the in­sur­ance sec­tor, re­mov­ing third-party in­ter­ven­tion, elim­i­nat­ing pa­per­work and bu­reau­cracy.”

Utkarsh Small Fi­nance Bank sees a big scope in RPA. Fin­care Small Fi­nance Bank uses AI for bank­ing so­lu­tions. Ra­jeev Ya­dav com­mented on blockchain: “Blockchain is very cru­cial tech­nol­ogy - many banks are now do­ing projects on it, but it is will take s years for the any sig­nif­i­cant ap­pli­ca­tion of based on the tech­nol­ogy in In­dia.”

Both Ru­bique and Flex­iloans see good op­por­tu­ni­ties in the tech­nolo­gies like ar­ti­fi­cial in­tel­li­gence and ma­chine learn­ing. Manav Jeet speaks on im­por­tance of data sci­ence in un­der­stand­ing be­hav­iour of the cus­tomers: “Data sci­ence plays a very cru­cial role. Blend of con­ven­tual and al­ter­nate data like shop­ping pat­tern and trav­el­ling data helps in un­der­stand­ing be­hav­ior pat­tern of the cus­tomers. This tech­nol­ogy helps in bring­ing pre­dictabil­ity in our busi­ness.”

Flex­iloans is plan­ning to cre­ate sharper data sci­ence mod­els and in­vest into re­search to dou­ble the num­ber of pro­pri­etary mod­els. “We have a DELTA re­search lab in our com­pany which fo­cusses on new tech­nol­ogy, to im­prove the speed and ac­cu­racy of cus­tomer on­board­ing, cus­tomer file pro­cess­ing and cus­tomer ser­vic­ing and projects. We will work on mul­ti­ple vir­tual re­al­ity and AI tech­nolo­gies that help in cus­tomer doc­u­men­ta­tion in a very fast man­ner,” says Man­ish Lu­nia.

CASHe’s pro­pri­etary credit eval­u­a­tion frame­work, the So­cial Loan Quo­tient (SLQ), uses a com­bi­na­tion of big data an­a­lyt­ics and pro­pri­etary ar­ti­fi­cial in­tel­li­gence-based al­go­rithms to eval­u­ate tra­di­tion in­puts and the user’s dig­i­tal foot­print to mea­sure their credit wor­thi­ness. The SLQ de­ter­mines both the loan amount and the in­ter­est rate to be charged, says CEO Ke­tan Pa­tel.

Amit Sax­ena, MD & CEO, Un­i­moni says: “Our em­pha­sis and in­vest­ment on build­ing data an­a­lyt­ics while ad­vanc­ing cus­tomer assess­ment tools pro­vide our cus­tomers an easy ac­cess to our mul­ti­prod­uct and multi-ser­vice plat­forms.”

Arvind Hali ex­plains the use of lat­est tech­nolo­gies in the op­er­a­tions of ART Hous­ing Fi­nance: “Tech­nol­ogy is crit­i­cal for our growth and our vi­sion is to be the new age hous­ing fi­nance com­pany us­ing tech­nol­ogy to de­liver a great cus­tomer ex­pe­ri­ence. There is a tremen­dous scope for the tech­nolo­gies like AI, ML and blockchain. Ma­chine learn­ing has come to play an in­te­gral role in many phases of the fi­nan­cial ecosys­tem, from ap­prov­ing loans to manag­ing as­sets, to as­sess­ing risks. While pre­vi­ous fi­nan­cial fraud de­tec­tion sys­tems de­pended heav­ily on com­plex and ro­bust sets of rules, mod­ern fraud de­tec­tion goes be­yond fol­low­ing a check­list of risk fac­tors – it ac­tively learns and cal­i­brates to new po­ten­tial (or real) se­cu­rity threats.”


BFSI chal­lengers see op­por­tu­ni­ties in in­tro­duc­ing new prod­ucts and ser­vices for their cus­tomers in 2019. They fore­see rise in de­mand for prod­ucts like busi­ness loans, per­sonal loans, se­cured loans, loans against prop­erty, loans against gold, 2-wheeler loans, af­ford­able hous­ing loans, MSME EMI card, wealth man­age­ment and in­sur­ance.

Fin­care Small Fi­nance Bank has 85% of mi­cro­fi­nance loan prod­ucts in its port­fo­lio. The bank will fo­cus on al­ter­nate as­sets such as loans against prop­erty, loans against gold, 2-wheeler loans and af­ford­able hous­ing fi­nance in 2019. Ujji­van Small Fi­nance Bank will be in­tro­duc­ing per­sonal loans and will be ac­tive in ve­hi­cle fi­nance in 2019.

R. Baskar Babu dwelt on the fo­cus prod­ucts for Sury­o­day in 2019: “At a strate­gic level, our fo­cus is on scal­ing up the small shop­keeper loan seg­ment, and on the cur­rent busi­ness op­er­a­tions. MSME busi­ness loans and se­cured loans con­tinue to be amongst the fastest grow­ing port­fo­lio for us.”

The start-up fin­tech com­pany CASHe is tar­get­ing young salaried mil­len­ni­als, and plan­ning to dou­ble its busi­ness by 2019. It will be in­tro­duc­ing other prod­ucts like EMI card, wealth man­age­ment and in­sur­ance prod­ucts for its cus­tomers in 2019.

The other fin­tech com­pany Flex­iLoans.com has spe­cial fo­cus

on un­der­writ­ing the busi­ness loans. Man­ish Lu­nia re­veals fur­ther de­tails: “We will achieve high de­gree of au­to­ma­tion in un­der­writ­ing of busi­ness loan in 2019. Au­to­ma­tion and ad­ding sur­ro­gates in credit un­der­writ­ing will be the big­gest trans­for­ma­tion for us.”


The newly es­tab­lished BFSI com­pa­nies have made spe­cial strate­gies to tar­get last mile cus­tomers and un­served cus­tomers in In­dia. The Prad­han Mantri Jan Dhan Yo­jana and mo­bile pen­e­tra­tion has brought many changes in the fi­nan­cial sec­tor of In­dia. Rishi Gupta, MD & CEO at Fino Pay­ments Bank, sees an op­por­tu­nity in pro­vid­ing ac­ces­si­bil­ity to the Jan Dhan ac­count holder and to the last mile cus­tomer: “Ac­ces­si­bil­ity is some­thing we are fo­cus­ing on, which will in­clude mi­cro ATM, APS, do­mes­tic money trans­fer, etc. Largely we are see­ing op­por­tu­ni­ties open­ing in ru­ral In­dia as well as for low mid­dle group.” He sees dig­i­ti­za­tion is grow­ing in the un­pen­e­trated and un­der-pen­e­trated mar­kets.

In­dia Post Pay­ment Bank is work­ing on a sharp plan to lever­age In­dia Post’s en­tire net­work of 155,000 points, to pro­vide bank­ing ser­vice to the cus­tomer at their doorstep. It is fo­cus­ing on cre­at­ing sus­tain­able last mile de­liv­ery model, fo­cused on pa­per­less cus­tomer on­board­ing. The bank is build­ing a model that is highly dig­i­tal in na­ture and has pro­vided bio­met­ric de­vices and smart phones to its staff.

Suresh Sethi, MD & CEO at In­dia Post Pay­ments Bank, re­veals the com­pany’s core mis­sion: “2019 is very wa­ter­shed year for us to take bank­ing to last mile cus­tomer. Our core mis­sion is to pro­mote fi­nan­cial lit­er­acy in In­dia, both for the ser­vice providers and for the con­sumers. By the end of this year we will be train­ing around 2 lakh peo­ple about bank­ing. Con­sumer lit­er­acy will help them in un­der­stand­ing the fi­nan­cial needs of the cus­tomer - it is a crit­i­cal ob­jec­tive for us.” IPP Bank of­fers a va­ri­ety of trans­ac­tions in­clud­ing Bharat Bill Pay­ment Sys­tem, NEFT, RTGS, IMPS, etc.

Ujji­van Small Fi­nance Bank faced 2 main is­sues, trans­for­ma­tion in to bank and im­pact of de­mon­e­ti­za­tion in its first year. The first 2 quar­ters were good for the bank and the com­pany reg­is­tered sig­nif­i­cant growth in par­tic­u­larly in mi­cro-fi­nance seg­ment.

Samit Ghosh, CEO, Ujji­van Small Fi­nance Bank, shares the banks strat­egy to tar­get non-English speak­ing pop­u­la­tion of In­dia: “We have de­vel­oped our en­tire bank­ing sys­tem on Aad­har based KYC, UPI pay­ment sys­tem, pa­per­less ac­count open­ing and mo­bil­ity de­vices so that we trans­act at cus­tomer work­place. We are among the few in­sti­tu­tions that has mo­bile bank­ing app in 5 lan­guages. We want to reach out non-English speak­ing pop­u­la­tion of In­dia, which is 90% of over­all pop­u­la­tion and get them mo­bile bank­ing ac­tively es­pe­cially in ru­ral and semi ur­ban ar­eas of In­dia.”

Ro­han Ku­mar, CEO at Tof­fee In­sur­ance, re­veals his strat­egy to tar­get un­served mar­kets: “The in­sur­ance sec­tor is re­shap­ing with the en­trance of new play­ers in the mar­ket, by merg­ing prod­uct think­ing, data and tech­nol­ogy with the ex­ist­ing struc­ture of the in­dus­try. The new, lean play­ers that have the abil­ity to in­no­vate are tak­ing this as an op­por­tu­nity to tar­get un­der­served mar­kets and pro­vide them with sim­pli­fied and tai­lored in­sur­ance poli­cies.” In the last few years, many dis­rup­tions have hap­pened in the mar­ket, such as af­ford­able data plans launched by tel­cos and Prad­han Mantri Ayush­man Bharat Yo­jana launched by the gov­ern­ment. These have in­creased the aware­ness and ac­ces­si­bil­ity about in­sur­ance.

Cover­fox has a phi­los­o­phy of build­ing a plat­form of tech­nol­ogy and prod­uct – which is very use­ful for off­line agents. In­dia has 2.6 mil­lion reg­is­tered in­sur­ance agents. It helps the agents by pro­vid­ing them com­par­i­son met­rics and other de­tails about the in­sur­ance com­pa­nies.

Pre­man­shu Singh, CEO at Cover­fox, pre­dicts the trans­for­ma­tion of in­sur­ance distri­bu­tion in 2019: “The tra­di­tional in­sur­ance distri­bu­tion, that we called in­sur­ance 1.0, is not go­ing to scale. Go­ing for­ward, a lot of distri­bu­tion is go­ing to be dig­i­tal. Due to dig­i­ti­za­tion in the bank­ing in­dus­try and since the in­tro­duc­tion of net bank­ing and wal­let ser­vices, the num­ber of cus­tomers vis­it­ing banks has re­duced con­sid­er­ably. As only a small num­ber of peo­ple from ur­ban In­dia visit banks to­day, lesser num­ber of in­sur­ance poli­cies are sold through banks.”

Pre­man­shu as­sets that in 2019, in­sur­ance com­pa­nies will cre­ate prod­ucts for dig­i­tal distri­bu­tion that can be sold only on­line and not by any other distri­bu­tion chan­nel. That means sa­chet in­sur­ance will be avail­able at `1 and `2. Niche in­sur­ance prod­ucts too will be in­tro­duced, con­tin­u­ing the ex­ist­ing in­no­va­tions such as dengue and heart in­sur­ance. Low ticket in­sur­ance will pre-dom­i­nate in 2019.

ID­DAI is open­ing new distri­bu­tion channels, dig­i­tal route and PoS are the path break­ing in­no­va­tions by reg­u­la­tors that has helped the in­sur­ance com­pa­nies to be more rel­e­vant to the cus­tomers. Pra­sun Sik­dar, MD & CEO at Cigna TTK Health In­sur­ance chipped in: “In­sur­ance is still a push prod­uct, so this in­dus­try re­quires both distri­bu­tion reach and tech­nol­ogy.”


Em­ploy­ees re­ten­tion and hir­ing has emerged as a cru­cial chal­lenge for most BFSI com­pa­nies. They face prob­lems in find­ing the right tal­ent that matches the job pro­file. The big­gest prob­lem is get­ting ex­perts for the IT depart­ment for open­ings re­lated to data sci­ence, an­a­lyt­ics and AI. The com­pa­nies also tak­ing time in re­cruit­ing a per­son as the process goes through mul­ti­ple dis­cus­sions with

mul­ti­ple teams.

Start-up com­pa­nies pro­vide mone­tary ben­e­fits to the em­ploy­ees to re­tain them. They also main­tain an in­for­mal cul­ture in their of­fice to make the em­ploy­ees feel re­laxed. Man­ish Lu­nia dwells on this is­sue: “At­tract­ing tal­ent is al­ways a chal­lenge and Mum­bai has lim­ited pool of tech and data sci­ence tal­ent and we keep work­ing to at­tract best tal­ent to join us. We are the only fin­tech com­pany to have re­ceived ‘Great Places to Work’ recog­ni­tion in 2018.”

In­dia Post Pay­ments Bank faces pe­cu­liar HR chal­lenges: “We see some chal­lenges in em­ployee re­ten­tion as we are a pub­lic sec­tor or­ga­ni­za­tion. We face dif­fi­cul­ties in at­tract­ing cut­ting edge tal­ent from the pri­vate sec­tor. Cut­ting edge tal­ent is crit­i­cal for us, be­cause tech­nol­ogy is the im­por­tant de­ter­ment for es­tab­lish­ing the low cost dig­i­tal model. Hence, we are very keen on hir­ing peo­ple hav­ing right skillset. We are try­ing to come out with so­lu­tions for this chal­lenge, so key skilled peo­ple from pri­vate banks can work for us,” Suresh ex­plained.

R. Baskar Babu talks about GenY and GenZ em­ploy­ees: “In our or­ga­ni­za­tion there is a think­ing gap be­tween GenY and GenZ em­ploy­ees. What we need is a com­bi­na­tion of new and ex­pe­ri­enced em­ploy­ees for ef­fec­tive work­ing of the or­ga­ni­za­tion.”


BFSI or­ga­ni­za­tions face a va­ri­ety of reg­u­la­tory chal­lenges in the course of their op­er­a­tions. The reg­u­la­tory re­stric­tions af­fect not only the op­er­a­tions, but also fund­ing, merg­ers and ex­pan­sion.

Ujji­van Small Fi­nance Bank faced reg­u­la­tory chal­lenges in a re­v­erse merger with Equitas Small Fi­nance Bank. Samit Ghosh ex­plained: “As per the RBI, for bank merger both banks need to be listed. As we both are newly es­tab­lished banks, we are still not a listed as banks. How­ever, our hold­ing com­pany is listed. RBI wants both the banks to be listed sep­a­rately as banks not as hold­ing com­pa­nies. This is the chal­lenge for us and we are work­ing on find­ing a so­lu­tion.”

NBFCs in In­dia are fac­ing the chal­lenges of short­age of cap­i­tal. Rishi Gupta would like reg­u­la­tors to solve NBFC prob­lems in the com­ing days: “We ser­vice SMEs, MSMEs and lower in­come groups. If the NBFC credit to the SME and MSME is squeezed, it im­pacts the lower in­come groups as its dis­pos­able in­come and sav­ing po­ten­tial will come down sig­nif­i­cantly. We are wait­ing for the reg­u­la­tor to come out with some di­rec­tion in this mat­ter.”

FDI in in­sur­ance distri­bu­tion is one of the big­gest changes ex­pected by many in­sur­ers. Pre­man­shu Singh com­mented: “I am ex­pect­ing a big change from the reg­u­la­tory per­spec­tive. Cur­rently 51% hold­ing has to be with an In­dian en­tity and 49% can be a for­eign en­tity. But IRDA is likely to al­low 100% FDI in the com­ing months. That will at­tract for­eign cap­i­tal in­vest­ment and also ven­ture cap­i­tal to grow the ecosys­tem.”


Aad­haar played a crit­i­cal role in pro­vid­ing bank­ing ac­cess to mil­lions as new age banks built dig­i­tal eKYC process cen­tred around it. How­ever, the re­cent Supreme Court guide­lines re­gard­ing usage of Aad­haar eKYC for bank­ing – not al­lowed, not manda­tory – is a chal­lenge for most of the newly es­tab­lished fi­nan­cial com­pa­nies. Aad­har based eKYC was re­li­able and easy method to get the cus­tomer in­for­ma­tion and to open bank ac­count.

Samit Ghosh shares some de­tails: “The Supreme Court de­ci­sion on Aad­har based KYC has im­pacted in our busi­ness; it doesn’t af­fect our mi­cro-fi­nance cus­tomers as they ben­e­fit from di­rect ben­e­fit trans­fer. But it had im­pacted our other cus­tomers. We will be han­dling de­vices but as eKYC is not el­i­gi­ble now, some pa­per­work will be re­quired.”

Ke­tan Pa­tel, CEO, CASHe re­veals the de­tails about the so­lu­tions for solv­ing Aad­har based eKYC prob­lem: “Many changes in eKYC and Aad­har reg­u­la­tions have im­pacted busi­nesses and vi­a­bil­ity for fin­tech loans in some seg­ments. There are al­ter­nate so­lu­tions to Aad­har based KYC and banks must come up with such al­ter­na­tive to solve the prob­lem. It is a prob­lem but not an is­sue which can­not be solved.”


The tier 2,3 & 4 cities of In­dia have grown sig­nif­i­cantly. Many SME and MSME have started their op­er­a­tions in these cities, cre­at­ing op­por­tu­nity for banks and in­sur­ance com­pa­nies. Along with these cities, the ru­ral mar­kets of­fer a good po­ten­tial.

Fino Pay­ment Bank used to do trans­ac­tions worth `0.5 bil­lion a day, now they are do­ing `2.5 bil­lion worth of trans­ac­tions a day – a 5X in­crease. Its ban­cas­sur­ance plat­form for life and non-life has also grown over 4X since the start of the bank. It has close to a mil­lion CASA cus­tomers with 50% debit card pen­e­tra­tion. Do­mes­tic re­mit­tance has grown by 5X since July 2017. How was all this achieved? “We ex­panded our mer­chant net­work. We started the bank with 25,000 mer­chants points, now we have over 60,000 and plan to have a net­work of 1 lakh by 2019,” ex­plained Rishi.

IPP Bank fo­cuses on reach­ing the last mile cus­tomers: “In­dian Post Pay­ment Bank want to lever­age with the en­tire post net­work. We have 170 mil­lion In­dia Post ac­count hold­ers, who have sav­ing ac­count with us, and we will trans­form those In­dia Post cus­tomers to our cus­tomers and will pro­vide them other bank­ing ser­vices as well – that is our mis­sion.”

Ujji­van Small Fi­nance Bank has 25% of its branches in the ru­ral ar­eas of In­dia. Samit Ghosh re­veals the geo-ex­pan­sion plans: “By

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