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UNCLAIMED PROPERTY FOCUS is a blog written by and for UPPO members, featuring diverse perspectives and insights from unclaimed property practitioners across the U.S. and Canada. We welcome your submissions to Unclaimed Property Focus. Please contact Tim Dressen via with any questions about submitting a blog post for consideration and refer to our editorial guidelines when writing your blog post. Disclaimer: Information and/or comments to this blog is not intended as a substitute for legal advice on compliance or reporting requirements.


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Unclaimed property in Australia

Posted By Administration, Tuesday, February 28, 2017

Map courtesy of


One of the more interesting unclaimed property regulatory structures is home to Australia, where the federal government, two territories and six states maintain unclaimed property statutes. Following is an overview of unclaimed property practices in Australia.  



Unclaimed property practices throughout Australia are regulated by the Banking Act of 1959, as amended. The Australian Securities & Investment Commission (ASIC) is the primary federal custodian of dormant bank accounts, credit union and building society accounts, insurance policies, company shares, lottery prizes and company deregistration proceeds. The most recent amendment to the law occurred in 2015 when dormancy periods, which previously had been decreased from seven years to three years, returned to seven years.


The law requires “authorized deposit-taking institutions” to report principal, interest, dividends, bonuses and profits legally payable to account owners when there has been no owner activity, including withdrawals or deposits, for seven years. Some of the noteworthy exceptions include: money held in retirement savings accounts, money in an account in a currency other than Australian dollars, money in children’s accounts, and farm management deposits. If conflicts arise, Australian federal laws preempt state and territorial statutes.


New South Wales

All New South Wales enterprises holding unclaimed money as of June 30 in any year are expected to escheat the funds by Oct. 31 to the New South Wales Office of Revenue. Enterprises are defined as: people, partnerships, associations, societies, institutions, organizations or other bodies. Amounts of more than $100 must be reported, while reporting amounts less than $100 is optional. Any reported amount over $20 will be listed for claim. Trust money in any amount, held under the Property Stock and Business Agents Act 2002, as well as New South Wales Public Superannuation (pension) Fund unclaimed benefits also must be reported.



Unclaimed property regulations in Queensland are managed by the Public Trustee. Entities expected to report include companies, hospitals and institutions, trustees and estate executors, local authorities, landlords, pawnbrokers, traders with uncollected goods, and those who possess proceeds from the sale of unclaimed stored good (after deducting money owed).


Reporting is expected for:

  • Funds held by companies if the owner cannot be located after a minimum of two years.
  • Unclaimed property held by hospitals, including jewelry and money that has remained unclaimed for a minimum of three months.
  • Estate entitlements where beneficiaries cannot be located.
  • Trust accounts held by solicitors, public accountants, real estate agents, auctioneers and other agents who operate a trust account.
  • Net proceeds of the sale of freehold properties where rates and charges remain unpaid for three years.
  • Contents of rental accommodations under residential tenancies.
  • Unredeemed pawned goods, uncollected trade goods, uncollected stored goods under storage liens.

South Australia

Companies headquartered in South Australia and anyone conducting business in South Australia is expected to report unclaimed property over $10 to the Department of Treasury and Finance. The dormancy period is six years. In January of the seventh year, notice of the unclaimed property must be published in the Government Gazette. After two additional years, remaining unclaimed amounts must be paid to the treasurer in January of the ninth year.



In Tasmania, funds from estates where beneficiaries cannot be located are reported by default via the Public Trustee’s mandate to administer estates and trusts. Other unclaimed property is reportable to the Department of Treasury and Finance by any company registered and incorporated in Tasmania; any person, firm, body or institution carrying on business as traders and having a principal office or place of business in Tasmania; and state entities, including government agencies, government businesses and local councils. Unclaimed property includes amounts greater than $50 that have been dormant for a minimum of 12 months, including funds paid into a court in Tasmania and any money payable to the treasurer under any of the state’s laws.



All Victorian businesses and trustees must report unclaimed money to the State Revenue Office annually by May 31. Any property valued at $20 or more, net of any reasonable expenses, is reportable. The dormancy period is a minimum of 12 months as of March 1 of the current year. Amounts under $20 for the same owner may be aggregated over multiple 12-month periods.


Western Australia

Only organizations based in Western Australia are required to report to the Department of Treasury. With the exception of bank accounts, life insurance, company shares and pensions, all types of unclaimed money are reportable under the Unclaimed Money Act of 1990. Amounts of $100 or more that have been held for six years are considered unclaimed. Treasury accepts voluntary reporting of amounts under $100. Notifications of amounts that have been held for at least two years also may be accepted by Treasury. Government agencies must hold funds for the mandatory six years, however.


Each January, organizations must provide Treasury with a summary of the unclaimed monies they hold. In the second half of the year, Treasury will issue a Register of Unclaimed Money. The public have until July 31 the following year to claim the property. The following August, organizations transfer the balance of any remaining unclaimed funds to Treasury.


Australian Capital Territory

Accounts, including deposits, dividends, trust account funds, interest, refunds, overpayments, sale proceeds and bonds, are considered unclaimed if they have been inactive for more than six years. Trust money held by licensed agents (including real estate, travel, business, stock and station and employment agents) is considered unclaimed after three years of inactivity.


When a company is holding unclaimed property, it must enter details of the unclaimed property into an alphabetical register by Jan. 31. No later March 31 of the next year, the company must publish a notice in a newspaper circulating in the Australian Capital Territory with information regarding claiming the funds. All property remaining unclaimed after one year from the date of publication must be paid to the Public Trustee and Guardian within one month after the end of the year.


Northern Territory

Companies with headquarters or a principal office in the Northern Territory are expected to report unclaimed deposits, securities and other funds payable (dividends, bonuses or profits, for example). The dormancy period is generally three years. By the end of February following the dormancy period, holders submit a register of unclaimed property to the Territory Revenue Office for publication in the Government Gazette. Remaining fund balances are to be paid no later than 13 months after the date of publication.  



Information for this article was compiled from the linked government websites as well as a recent UPPO International Escheatment webinar, led by Darren Jack, director of business development for AssetMine Global Inc.



Tags:  Australia  unclaimed property 

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Legislative process offers multiple opportunities for member advocacy

Posted By Administration, Thursday, February 23, 2017

Just two months into 2017, the year is already shaping up to be one of the busiest in recent memory for unclaimed property bills under consideration by state legislatures across the country. Because these bills have the potential to significantly change compliance requirements, unclaimed property professionals not otherwise inclined to participate in the political process beyond voting in the elections may develop a greater interest in advocacy.


Many of us remember the basics of how a bill becomes a law from Schoolhouse Rocks or high school civics lessons—the legislative branch of government considers the bill and, if passed, the governor decides whether to sign it into law. However, the path a bill takes is a bit more detailed than that, and definitely worth understanding to recognize where in the process advocacy efforts are likely to be most effective.


“Understanding how a bill progresses is really important,” says Karen Anderson, senior manager, state and local tax, unclaimed property for KPMG LLP. “A bill usually goes through two chambers, and it goes through committees in each, so there are several components to the process where communication is not only important but also welcomed by state legislatures and governors.” 


Every state operates under slightly different procedures and processes, so the nuances of the legislative process will vary. However, this overview should provide a reasonable understanding of the journey an unclaimed property bill is likely to take on its way to becoming a law or not.


Introduction and First Reading

Other than Nebraska, state legislatures have two chambers. Any legislator in either chamber can introduce a bill. Some issues tend to skew heavily toward introduction by one political party, but unclaimed property bill authors aren’t so easily defined.


“Legislators introducing unclaimed property bills could be doing so for one of several reasons,” says Kendall Houghton, partner with Alston & Bird LLP. “A constituent may have approached them after experiencing an issue related to unclaimed property. A committee member works with a state administrator who encourages introduction of a bill. Or another stakeholder may push for new legislation. So, because legislation may originate in many different ways, there isn’t really a ‘typical’ profile of an unclaimed property bill.”


State legislative procedures usually require bill to go through three official readings before becoming law. Depending on the state, the first reading may occur either before or after being assigned to a committee. Some states have rules preventing bills from proceeding through the system too quickly, preventing adequate time for study and public comment. California, for example, specifies that bills cannot receive a vote until at least 30 days after introduction.  


Committee Consideration

Either before or after the first reading of the bill, depending on the state, a committee made up of members of the legislative chamber where the bill was introduced receives the bill for consideration. The process for assigning bills to specific committees varies by state, but it generally goes to a committee deemed to have the appropriate interest or expertise in the subject being considered. It may go to a banking, finance, taxation or revenue committee, however it’s not uncommon to find an unclaimed property bill assigned elsewhere, depending on the state and specific issues the bill addresses.


“If someone wants to get active, the committee assigned to review the bill is the first place to have a great impact advocating for or against it,” says Michelle Andre, managing member of Tre Towers Advisory Group LLC. “Getting information to the chair and members of that committee, as well as the sponsors of the bill makes a lot of sense. Most legislators don’t understand unclaimed property from an owner and holder perspective, so you need to be very clear about where you stand on an issue and why.”


The committee may review and vote on the bill or, in some cases, the committee chair may decline to move the bill forward. The committee may hold a public hearing to gather additional information. The committee may table the bill or vote on it. If tabled, a vote may or may not be held later. If a vote is held, the committee can either advance the bill, in which case it returns to the house of origin, or defeat the bill, killing it in committee.


Because committees hold the power to advance or kill a bill, this is an important stage in the process for parties interested in supporting or fighting the legislation. Contacting the committee chair and members to educate them on the bill’s potential effects can be beneficial.


Second and Third Reading

If the bill returns to the chamber of origin, that chamber’s leadership typically decides whether to schedule the bill for its second reading. If not, the bill dies. If the bill receives a second reading, legislators may have a chance to debate and suggest amendments, which are incorporated into the bill if approved by a majority vote. Again, each state and each legislative chamber has its own rules; some prohibit debate and/or amendments until after the third reading.


When the third reading occurs, legislators generally get an opportunity to discuss, debate and amend it before a final vote. If the legislature approves the bill, it transfers to the other chamber of the legislature.


Because unclaimed property is not a high-profile issue, many legislators responsible for voting on it will not know its intricacies or understand the potential ramifications of the bill they are considering. That’s where constituents play an important role. Contacting legislators in your district to encourage them to favor or oppose a bill and explain why they should take that position can make a significant difference.


“The value of grassroots contacts cannot be underestimated,” Houghton says. “If you reside in the legislator’s district or your business is headquartered in their district, those contacts mean a lot to elected officials. Education on the issues is really important to help them understand what their vote really means. That type of outreach doesn’t take a lot of time, but it can be very impactful.”


The Other House

If the bill moves to the other chamber, the process repeats. It is assigned to a committee in the second chamber and may move on or die. It again will go through the three-reading process and may move forward or die at any stage. Again, interested parties have a chance to educate and influence committee members and elected officials from their districts.


If the second chamber approves the bill with no amendments, it moves on to the governor. If it has been amended, it returns to the chamber of origin, which may vote to approve the amended bill, sending it to the governor, or vote against the new bill, sending it instead to a conference committee. If a conference committee receives the bill, members of both legislative chambers work to reach an agreement on the language of the bill. If they fail to reach an acceptable compromise, the bill dies. If they reach agreement, the bill returns to both chambers for another vote.



Once both chambers of the legislature agree upon and approve a bill, it moves to the executive branch of government for consideration by the governor. However, the governor’s influence on a bill may occur well before it reaches this stage. While a bill is still under consideration in the legislature, the governor may suggest to legislators or to the public whether a bill is likely to be signed into law and under what conditions. This may influence how legislators draft, amend and/or vote on a bill.


“Sometimes people forget that governors are such a key component to the legislative process,” Anderson says. “They aren’t merely a last step, but in many cases they’re involved as a bill moves through the legislatures.” 


When a bill that has been approved by the legislature reaches the governor, three things can happen. The governor may sign it, allow it to become law without signing it or veto it. Upon a veto, the legislature typically has the ability to override the veto with a two-third vote in both chambers.


Some bills will include an effective date as part of their language. Others may not, in which case it is effective on a specific date as mandated by the state’s laws. Some states, for example, specify that the bill is effective immediately upon receiving the governor’s signature unless otherwise specified, while others designate a timeframe (30 days after the governor’s approval, for example) or a certain date, such as Jan. 1 of the following year.



As you can see, there are a lot of stages to any bill’s path from inception to enactment. This enables you to express your support for or opposition to the bill at several points throughout the process. Fortunately, tracking a bill’s progress is easy for UPPO members. UPPO monitors all of the pertinent bills affecting members and reports on their status via the govWATCH website and email updates. Let your voice be heard and make a difference.


“If members are trying to get a handle on issues that are likely to be the subject of legislation this year, they should read the Revised Uniform Unclaimed Property Act and pay close attention to govWATCH,” Houghton says. “Those are the two resources that provide great information on issues that matter to the unclaimed property community (states, holders, industries, audit firms and owners) and what is being introduced.”



Tags:  legislation  unclaimed property 

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New Pennsylvania and Texas due diligence requirements raise questions

Posted By Administration, Tuesday, February 21, 2017

In recent years, Pennsylvania and Texas enacted new unclaimed property due diligence requirements that affect holders this year. In both cases, the statutes raise several questions for holders required to comply with the new requirements.



Last year, Pennsylvania amended its unclaimed property law, effective Sept. 12, 2016. Among the changes was the addition of a due diligence requirement. According to draft guidance from the state, the new due diligence requirement applies to all property to be reported on April 15, 2017.  


The due diligence requirement specifies that property holders must send a notice to owners between 60 and 120 days before reporting the property to the state treasurer. The requirement applies to any property valued at $50 or more for which the holder has an owner address it believes is valid.


Holders are also permitted to provide optional, additional notice any time between the date of last activity by, or communication with, the owner and the escheatment date, under the new requirement.


Unless the holder has valid consent from the owner for electronic contact the owner, written notice must be sent by first-class mail. The holder is required to include descriptions of the property and property ownership, value of the property (if known) and information for contacting the holder to avoid escheatment of the property.


The due diligence requirement’s language raises several questions for holders. It is unclear whether having valid consent to communicate electronically triggers a requirement that the holder must provide the notice electronically, or if the holder has the option to provide notice either electronically or by first class mail.


It is also unclear what constitutes owner consent to receive the due diligence notice electronically. Does the consent have to specifically mention due diligence notices? Does consent apply if the owner agreed to receive only specific types of documents, such as tax forms, electronically?


UPPO has raised these questions via comments to Pennsylvania’s treasurer in hopes of receiving clarification for the holder community.



In June 2015, Texas passed H.B. 1454, which includes new due diligence requirements, effective on Sept. 1, 2017. Under the new requirements, if a property owner has designated a “representative for notice,” the holder must mail or email the written notice required upon presumption of abandonment to the representative in addition to mailing the notice to the owner.


The requirements specify that, although the designated representative does not have any rights to claim or access the property, the dormancy period will cease if the representative communicates to the holder knowledge of the owner’s location and confirms that the owner has not abandoned the property.


Holders are also required, under the new requirements, to include the name and last-known mailing or email address of the representative for notice designated by the holder.


As with Pennsylvania’s new requirements, the Texas requirements raise several questions for holders:

  • What types of property are covered? The law specifies mutual funds, deposit accounts and safe deposit boxes, but doesn’t specify whether both open-end and closed-end mutual funds, and IRAs are included?
  • What are the acceptable methods for obtaining representative information? The requirement specifies that the comptroller provides a form that a holder may make available to an owner to designate a representative. However, it does not specify whether this is the only acceptable method for collecting this information.
  • Is there any criteria for being designated as a representative for notice, and does the designated representative have to provide any sort of consent to serving this role?
  • How long does a designation of being a representative for notice last, and are there any requirements for an owner to revoke this designation and/or for a holder to notify Texas of the revocation?
  • If the owner holds multiple accounts with the same holder, is designation of a representative for notice on one account considered applicable to all accounts? Likewise, does a representative response regarding one account automatically reflect interest in all of the owner’s accounts maintained by the holder?

UPPO has raised these questions with Texas officials and will continue to monitor implementation of the new requirements.



Tags:  due diligence  Pennsylvania  Texas  unclaimed property 

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S.B. 13 makes sweeping changes to Delaware’s unclaimed property statutes

Posted By Administration, Thursday, February 16, 2017

On Feb. 2, 2017, Gov. John Carney signed Delaware S.B. 13 into law, significantly updating the state’s unclaimed property statutes. Many of the changes mirror the 2016 Revised Uniform Unclaimed Property Act (RUUPA), and others appear to respond to issues raised by the Temple-Inland case. The new law is intended to “bring greater predictability, efficiency and fairness to the state’s unclaimed property reporting process and compliance initiatives.” Following is a summary of several of the law’s most noteworthy provisions.


Lookback, Record Retention and Statute of Limitations

S.B. 13 reduces the lookback period for both audits and voluntary disclosure agreements (VDAs) to 10 years plus dormancy. It also defines an express record retention period of 10 years from the date a holder submits a report. The statute of limitations is now 10 years from the date the duty arose, whether or not the holder reported the property. The previous statute of limitations, although shorter, began to run from the time the holder reported the property.


Estimation Methodology

The new law mandates that the secretaries of finance and state develop estimation regulations by July 1, 2017. They must include permissible base periods; items to be excluded from estimation calculation; aging criteria for outstanding and voided checks; and a definition of what constitutes “complete and researchable records.”


Audit Conversion

Under the new law, all holders currently under audit may convert to a two-year accelerated audit. Holders under audit as of July 22, 2015, may convert to a VDA program. Holders have until 60 days after the promulgation of the new estimation regulations to decide whether to convert to an accelerated audit or VDA program. Interest and penalties will be waived if conversion is made. Holders remaining in the audit will be subject to mandatory interest that is waivable only up to 50 percent.


Subpoena Authority

Provisions of the new law give the state escheator the power to issue an administrative subpoena and the ability to seek enforcement of an administrative subpoena in the Court of Chancery. These provisions appear to address issues raised by Delaware Department of Finance v. Blackhawk Engagement Solutions.


Judicial Review

Among the new provisions adopted in Delaware is a process for appeal by holders to the Delaware Court of Chancery, replacing the previous multi-step administrative review process. Under the new appeal process, holders have the ability to challenge the state escheator’s determination of liability. The court’s standard of review is deferential to the state escheator regarding factual determinations, but errors of law will be reviewed de novo. The judicial review provision also expressly gives the Court of Chancery the authority to review questions of state or constitutional law related to the examination. This provision appears to be a response to the Temple-Inland case.


Indications of Owner Interest

S.B. 13 adds a specific list of owner activities that prevent running of the dormancy period. Indications of the owner’s interest in property includes:

  • A written or oral communication by the owner to the holder or agent of the holder concerning the property or the account in which the property is held.
  • Presentment of a check or other instrument of payment of a dividend, interest payment or other distribution.
  • Accessing the account or information concerning the account, or a direction by the owner to increase, decrease or otherwise change the amount or type of property held in the account.
  • Payment of an insurance policy premium with some exceptions.

The new law also specifies that if an owner has more than one investment or account with a holder, an indication of interest in one investment or account is an indication of interest in all of those accounts.


Knowledge of Death

The new law adopts the “knowledge of death” concept as a dormancy trigger for life insurance proceeds. “Knowledge of death” may be identified through any source, such as declaration of death, a death certificate or the comparison of the holder’s records against the Social Security Administration’s Death Master File.


Priority Rules

For the first time, the Delaware unclaimed property law includes a codification of the U.S. Supreme Court’s priority rules. It expressly prohibits Delaware as the state of domicile under the second priority rule from taking property into custody that is exempted in the first priority rule state. It also allows the state of domicile to claim foreign-address property but excludes property claimed under foreign law.


Owner Address

S.B. 13 adopts portions of RUUPA’s definition of an owner’s “last-known address.” The last-known address of an owner is defined as “a description, code or other indication of the location of the owner on the holder’s books and records that identifies the state of the last known address of the owner.”


Disposal of Securities

The new law specifies that the state escheator shall sell or dispose of securities on any established stock exchange or by such other means as soon as the escheator deems it feasible after the delivery. The escheator may not sell a security listed on an established stock exchange for less than the price prevailing on the exchange at the time of sale. The escheator may sell a security not listed on an established exchange by any commercially reasonable method.


S.B. 13 provides for indemnification of security owners for 18 months. The escheator will provide either a replacement security or the market value of the security at the time the claim is filed if the owner comes forward with that 18-month period.


Gift Cards

For the first time, Delaware’s statute defines “gift cards,” “stored value cards” and “loyalty cards.” Gift cards and stored value cards remain escheatable after five years of inactivity. The state retained its unique profit retention provision defining the amount unclaimed as “the amount representing the maximum cost to the issuer of the merchandise, goods, or services represented by the card.” S.B. 13 adds “Goods” and “Services” into the mix, as old statute only provided exemption for “maximum cost to issuer of merchandise represented by the card.” Loyalty cards are expressly exempt.


Holders are prohibited from transferring their unclaimed property liability or obligation, except to a parent, subsidiary or affiliate. This provision affects third-party, unrelated companies that issue gift cards on behalf of a business and appears to address some of the uncertainty resulting from the Card Compliant qui tam litigation.


Compliance Review

Another new provision in the law permits the state escheator to conduct a “compliance review” if the escheator believes a filed report was inaccurate, incomplete or false. The compliance review is limited to contents of report and all supporting documentation. The escheator is required to adopt rules governing the procedures and standards for compliance reviews, but no timeline was included in the statute.


Application of the New Law

S.B. 13 represents a major change in Delaware’s unclaimed property practices with many positive developments for holders. They include reduced lookback, clear record retention period, estimation regulations, statute of limitations regardless of prior reporting compliance, direct appeal to Court of Chancery, new definitions and new exemptions.


As with any new law, it remains to be seen how provisions will be interpreted and applied. Holders await the regulations still in development regarding audit conversions to fast-track audits and VDAs, and the new compliance review provision. Clarification from Delaware will help holders make informative judgments about whether to convert current audits into VDA or fast track audits, and whether other changes to their unclaimed property practices are warranted.


Tags:  audits  Delaware  estimation  gift cards  RUUPA  unclaimed property 

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New York reduces voluntary compliance program reach-back period

Posted By Administration, Thursday, February 9, 2017

Effective on Jan. 1, 2017, the state of New York implemented a reduced reach-back period for holders participating in the voluntary compliance program. The reach-back period is now 10 years plus dormancy on general ledger items, reduced from 20 years plus dormancy before the change.


“We’ve been talking to holders quite a bit about what works and doesn’t work,” says Kelly Kuracina, assistant bureau director for New York’s Office of Unclaimed Funds. “We heard over and over that the reach-back period was intimidating. It’s uncommon for companies to have records going back more than 20 years. We thought it would be a good-faith olive branch to set a more reasonable timeframe for when companies are likely to have records.”


The reduced reach-back period applies only to the voluntary compliance program—not to audits. Companies participating in the voluntary compliance program before Jan. 1, 2017, also fall under the previous reach-back period. However, if a holder joined the program near the end of 2016 and identifies issues related to the reach-back period, New York’s Voluntary Compliance Unit will review the circumstances and work with them on a case-by-case basis, according to Kuracina.


Holders are eligible to apply for the program if they have not been contacted about an audit in New York and would be first-time reporters or recently identified a property type that hasn’t been reported.


As part of its outreach efforts, New York’s Voluntary Compliance Unit has been sending letters to likely property holders, inviting participation. Whether they receive an invitation or initiate the process on their own, potential program participants can complete a self-audit checklist to help determine whether the company is holding unclaimed funds. Or, if the holder already knows it has past-due unclaimed property to report, it can complete a voluntary compliance agreement (VCA). Upon review of the survey or VCA and acceptance into the program, the holder has six months from the date of acceptance to conduct its review, complete its due diligence and file a report.


“We know there’s a population of companies that are either not aware or not in compliance,” Kuracina says. “We take responsibility for raising awareness and making sure they know there’s a requirement under the law to report unclaimed funds they hold. If it’s simply a case where they aren’t aware, we want them to become aware. If they weren’t in compliance because the reach-back period seemed too onerous, now they have the opportunity to come forward.”


Learn more about New York’s voluntary compliance program on the state’s unclaimed property website, or contact the Voluntary Compliance Unit at with any questions about the program or unclaimed property compliance in the state.



Tags:  New York  unclaimed property  VDA  voluntary disclosure agreements 

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