Decarbonization Advisory Panel Report
and Letter to NYS Comptroller
Posted by Joy-Therése Williams and Alicia
Seiger, Decarbonization Advisory Panel, on Saturday, April 20, 2019
Editor’s Note: Joy-Therése
Williams is chair and Alicia Seiger is a member of the
Decarbonization Advisory Panel for the New York State Common
Retirement Fund. This post is based on a recent letter to the New
York State Comptroller Thomas P. DiNapoli, and an Advisory Panel
report, by Ms. Williams, Ms. Seiger, Bevis Longstreth, Cary
Krosinsky, George Serafeim, and Timothy Smith. Related research
from the Program on Corporate Governance includes
Socially Responsible Firms by Alan Ferrell, Hao Liang, and Luc
Renneboog (discussed on the Forum
here) and Social
Responsibility Resolutions by Scott Hirst (discussed on the
Thomas P. DiNapoli
State Comptroller State of New York
Office of the State Comptroller
110 State Street
Albany, New York, 12236
On behalf of the
Decarbonization Advisory Panel, I am pleased to submit our recommendations for
your consideration. It has been a privilege to serve as Chair of this Panel of
distinguished peers who volunteered their time and expertise to reach a
consensus of opinion for the Report’s recommendations.
The Panel would like to
commend you, your department and the staff of the New York State Common
Retirement Fund for your leadership and the willingness to explore options of
managing climate change impacts on the Fund as a whole.
The Charge to the
Advisory Panel asked us to identify, assess and manage investment risks and
opportunities related to climate change, and how to prepare the Fund for a
transition to a low-carbon economy. Our approach took a holistic view to ensure
the recommendations can make the Fund sufficiently resilient to changing
physical conditions and economies. The Panel members aimed high with its
The Panel recognizes
climate change as an existential threat to global economies, markets and earth
systems. The Fund faces real risks related to loss of value and challenges to
the ability to secure the needed rate of return. The Panel also recognizes that
preparing the Fund to deal with the challenges of climate change provided
opportunities. Opportunities focus on capacity to capture value as the world
adapts to new realities.
Our consensus report
begins by articulating a set of beliefs that paint a picture of fundamental
economic changes as a result of the impact of climate change. Our beliefs set
the context for the breadth and depth of our recommendations. Our objective was
to articulate a compelling business case for the financial relevancy of climate
change to the Fund and the need for significant action to protect and add value
to the Fund for the benefit of its members.
Adapting a portfolio as
large as the New York State Common Retirement Fund is not just a process but a
journey, albeit one that needs to begin with prudent haste if the Fund is to be
properly prepared to lower risks and seize opportunities. The Panel took into
consideration the Fund’s significant operational and logistical challenges and
have provided flexibility in how the recommendations can be implemented. It is
the Panel’s view that some of these recommendations may be taken on board
quickly with the resources on hand while others can [sic; additional phrase
in original: be executed in short order after preparations have been made.]
You will note that
divestment as an investment strategy in and of itself is not included in the
consensus recommendations. Instead, the Panel looked at the whole picture and
believes that implementing our recommendations may well lead to divesting of
certain assets, but that decision will be an outcome of a larger, carefully
thought out investment strategy. As part of this discussion, there were ideas on
which the Panel did not reach consensus. Two Panel members have prepared
separate submissions with these alternative approaches that provide helpful
context to the recommendations.
The very existence of
this Panel is due to an acceptance that the New York State Common Retirement
Fund must make changes, or it may not be in a position to meet its mandate for
its members in the years ahead. It was a bold and visionary move, and the Panel
sought to ensure that the recommendations are just as challenging and ambitious
while giving the Fund a firm foundation for the future.
Chair, Decarbonization Advisory Panel for the New York State Common Retirement
Advisory Panel (the Panel) was charged with advising “the Comptroller, as
trustee of the $209.1 billion New York State Common Retirement Fund (Fund), on
how best to mitigate investment risks stemming from climate change and maximize
opportunities from the new, low-carbon economy.” The Panel was appointed in
March 2018 by Governor Andrew Cuomo and Comptroller Thomas DiNapoli.
To assist with the
process, the Fund met with the Panel on multiple occasions over the course of a
year. Staff from the Fund responded to the Panel’s questions and provided an
accounting of past and current climate-related activities. The Fund also
facilitated the Panel’s requests for information from trusted third-party
reports and industry experts. The Panel would like to thank the Fund staff for
their openness and willingness to discuss this topic.
The Panel recognizes
the Fund’s leadership and depth of activities with regard to climate change,
particularly with respect to active ownership. We specifically call out and
commend Comptroller DiNapoli for his ongoing leadership on climate change.
Based on the Panel’s
assessment of the latest climate science, our review of the Fund’s materials and
our expertise at the intersection of climate change and finance, the Panel
believes major, additional steps will be necessary to protect the financial
interests of the Fund’s beneficiaries in the future.
The complete publication lays out the Panel’s foundational beliefs (Part
1) which, in turn, drive our consensus recommendations (Part 2). Part 1, Part 2
and Exhibit A (Minimum Standards Framework) represent a united view from the
The two appendices are
personal statements from individual panel members. While the Panel was not in
consensus on the entirety of these pieces, the ideas articulated in these
statements influenced the Panel’s final recommendations and the Panel agreed it
was appropriate to append them in service of additional context and insight.
The Panel views climate
change as not one discrete risk factor or even a set of factors, but as a macro
disruption across industries (e.g., energy, agriculture, mobility, etc.),
geographies (e.g., emerging markets, coastal property, flood plains, etc.) and
arenas (e.g. physical, policy, technology, liability, etc.). It will
fundamentally change economic systems and thus has a financially material impact
on investing. While there is uncertainty on when and where these impacts will
fully manifest, the transition to this new future is already well underway.
There is no opting-out of climate consequences—to invest as “usual” is to take a
bet against scientific principles. To delay action is, itself, a decision to
enter unprepared into a more volatile investing environment and a more abrupt
The Panel acknowledges
that in undertaking all or even most of our recommendations, the Fund will
confront challenges with respect to staffing and compensation. To allow for
these challenges, the recommendations are intended to enhance the Fund’s
internal operations as well as expand its relationships and leverage the skills
and resources of its managers, index providers and consultants.
recommendations have been developed to best prepare the Fund for financial
impacts as climate change continues to unfold. The Panel sees real risk to the
value of the Fund and its ability to achieve a target annual rate of return if
the Fund is not prepared for the transition to a low-carbon economy or for the
worsening physical risks from climate change. The cost of unpreparedness to the
Fund’s operations is likely to be significant, including the potential to impact
contribution rates. Therefore, we believe our recommendations are consistent
with the goals of a responsible investor. However, we understand these
recommendations may be challenged in the short-term as the market does not
currently reflect the full extent of climate change risks and opportunities.
These recommendations break from the status quo and pursuing them will cause the
Fund to face challenges in its operations and investing practices.
The Panel has
conviction that the market will evolve through efforts by bodies such as the
Financial Stability Board, but it may take time. The Panel recognizes that there
is uncertainty in the short-term losses and gains that may be associated with
its recommendations. In recognition of these challenges, the Panel has built
flexibility into its recommendations rather than prescribe a fixed process or
implementation road map. The Fund may choose to pilot or phase-in initiatives,
which would also allow for course corrections as new information becomes
recommendations are sweeping and ambitious. We believe our comprehensive
approach will best prepare the Fund for resilience in the face of climate
It is in this spirit
that the Panel offers our beliefs and recommendations for the Comptroller’s
consideration and with a hope that others will follow the Fund’s lead.
The Panel has
conviction that its recommendations stand firmly on a compelling business case
that climate risks and opportunities present real financial consequences for the
Recommendations: Pursuit, Processes and Products
The Panel recommends a
bold ambition, a big first step, and a suite of actions with regard to the
Fund’s investment processes and products that support both the ambition and
first step. Our recommendations address both mitigating risks and capitalizing
on investment opportunities.
Ambition and First Step
The Panel’s ambition
for the Fund takes into consideration the Panel’s belief that securities across
the entire portfolio are exposed to physical and transition risks in the
business-as-usual scenario. Our “first step” recommendation specifically
addresses the Fund’s desire to capitalize on the emerging investment
opportunities that directly promote adaptation to or mitigation of climate
change impacts. The overarching ambition and first step work together to
increase the Fund’s resilience to climate change.
recommends the Fund pursue alignment of its entire portfolio with a 2-degree or
lower future by 2030 in accordance with climate science consensus. As a first
step, the Panel recommends the Fund establish a new “climate solutions”
allocation through which the Fund can substantially increase its commitment to
investments with a proactive approach to climate risk and opportunity in the
For the purposes of
this document, the Panel defines “sustainable assets” as investments, in any
asset class, that are consistent with a 2-degree or lower future. Those assets
may directly or indirectly work to help create that future or have a neutral
effect on its development. The Panel notes that multiple pathways to a 2-degree
future have been modeled and recommend the Fund, in consultation with experts,
develop a point of view regarding which scenario(s) it deems appropriate and
credible. The pursuit of sustainable assets is as much about the decision-making
process as it is about the assets themselves. As such, the Panel recommends the
Fund develop and apply “Minimum Standards” across all of its investment
decisions. (See Exhibit A below.)
Rather than making a
narrow recommendation to divest from specific stocks, the Panel supports the
concept of Minimum Standards to guide the Fund in its decisions to sell
securities and/or avoid investment managers whose operations and strategies are
not sustainable. In pursuit of 100% sustainable assets, divestment of companies
not consistent with a 2-degree future is “baked in.”
The Panel recognizes
so-called “low-carbon indices” as a first step towards decarbonization. These
products however, rely on a relatively narrow view (sometimes, but not always,
due to data constraints) of what it means to create portfolios that mitigate
physical and transition risks. The data to inform decarbonized portfolios need
to extend beyond carbon emissions of an organization and move to an analysis
that models product demand changes across industries and companies, changes in
cost structures across value chains, and an organization’s competitive
positioning in the marketplace.
Why by 2030?
Much of the argument
for a 2030 target was articulated in the Panel’s beliefs; a few points are worth
reiterating. According to the IPCC, model pathways with no or limited overshoot
of 1.5°C require global CO2 emissions to decline by roughly 45% by 2030,
reaching net zero in 2050.
To avoid overshooting
2°C, global emissions reductions must decline roughly 20% by 2030 and reach net
zero around 2075. The increase in global economic damages between 1.5 and 2
degrees is significant; a 3-degree world verges on unrecognizable. By 2030, the
planet will be locked into temperature rises that may put the Fund’s value at
significant risk. These dates are driving mitigation efforts around the globe.
First step: A New
The panel recommends
the Fund develop a new “climate solutions” allocation. This allocation would
rise substantially as a share of the portfolio in the short-term. Over time, the
Fund can leverage the data and relationships accumulated through the allocation,
combined with its existing and new efforts across all asset classes, to more
quickly implement the sustainability overlay across the entire portfolio so as
to achieve 100% sustainable assets before 2030.
The climate solutions
allocation acts as a leading edge driving the Fund’s sustainability goals. The
allocation would be multi-strategy (including both equities and debt).
Investments under this allocation share a common thread of actively supporting
the Transition or addressing adaptation problems. The Fund has already committed
$6 billion to investments consistent with this recommendation. Further
investments may be sourced through increasing allocations that already
contribute to climate solutions and through new allocations in existing or new
The Panel recommends
establishing a new Head of Climate Solutions position to manage the allocation,
supported by a well-resourced team. Cognizant of the diversity of strategies in
the allocation and the fact that traditional benchmarks are, by nature, backward
looking, the Panel recommends the carve-out be managed against an absolute
return rather than a benchmark. The absolute return should be set according to
the Fund’s blended target rate of return net of fees and inflation.
Specifically, the Panel
The leading edge of
climate-related opportunities require deep expertise in climate mitigation and
Superior returns will
flow from making decisions based on a robust pipeline of opportunities rather
than weighing the occasional sustainable manager against traditional
strategies. A dedicated team will have greater capacity to build a robust
pipeline of deal flow and vet opportunities against a broader consideration
Capitalizing on the
Transition requires more flexibility than traditional investment practices
(i.e., backtesting, benchmarks, tracking error, check sizes, fund structures,
etc.—see additional recommendations in the next section).
The Panel recognizes
and respects a preference among the sustainability community for “integration”
of sustainability practices, including ESG factors. In this approach,
responsibility for connecting climate change to investment decisions is shared
among investment professionals. The climate solutions allocation is not
inconsistent with an integrated approach. By dedicating staff and resources
through a new allocation, the Panel points to the following benefits:
The allocation serves
as a hedge against the climate risk to which the rest of the Fund remains
The allocation better
positions the Fund to capitalize on the Transition.
in-house capacity will serve the Fund well in its pursuit of aligning the
portfolio to a 2-degree or lower future.
Over time, the Fund
will generate the data it feels is lacking to test “new” strategies (i.e. fill
the current data gap for backtesting).
In order to ramp-up
ambition swiftly and move towards sustainable assets, the allocation provides
a blueprint for climate solutions on a larger scale.
Support the Ambition and First Step on the Fund’s Investment Processes
employ Minimum Standards. Building on the Fund’s effort to
memorialize climate change-related principles for investment, the Panel
recommends the Fund establish criteria for observation and exclusion based on
Minimum Standards for investments. These Minimum Standards would serve as the
basis on which the Fund decides to buy, hold or sell assets exposed to
transition and physical risks. Minimum standards can be used to construct
indices, evaluate managers and direct engagement. See Exhibit A of the
complete publication for the Panel’s suggestions on Minimum Standards and how
they have inherent flexibility to allow for dynamic conditions in investments,
companies and strategies.
The Panel recognizes the centrality of benchmarks in the evaluation of the
Fund’s overall performance, individual product and asset class performance,
and compensation incentives for investment professionals. Yet, traditional
market indices reflect historical trends with no accounting for future
dislocations as a result of climate change. This mispricing includes physical
risks, of which there is certainty, and impacts of the Transition, about which
there is a great deal of uncertainty and therefore risk.
The Panel recommends the Fund consider moving to absolute return instead of
market-driven benchmarks that are plagued with the aforementioned challenges
in light of climate change. Note that this is our preferred option for the
new climate solutions allocation.
Create a new benchmark.
Notwithstanding the dangers of mispricing embedded in traditional market
benchmarks, the Panel understands that this is a foundational element for
public funds and will take time to change to absolute return. Therefore, in
the interim, the Panel recommends that the Fund develop new sustainability
Use “sustainability” benchmarks.
Benchmarks that are consistent with a 2-degree or lower future would support
the goal of 100% sustainable assets. These could be used alone or alongside
traditional benchmarks when working with managers. Tying climate-wise
strategies to short-term and backward-looking benchmarks limits the value of
those strategies out of the gate.
Develop expertise on climate risk modeling.
Much of the work to date on climate risk has yielded results that a) are not
useful enough to inform investment decisions, b) underestimate impacts, c)
overestimate timescales or d) all of the above. The Fund should build on its
own capabilities and work with partners to develop sophisticated models to
measure the climate risk of the Fund’s real assets and to undergird risk
methodologies for new index products. The Panel recognizes the state of
existing data and reporting remains inadequate and inconsistent and will
benefit from owner-led initiatives.
Re-audition consultants and managers.
The Panel recommends the Fund conduct a review of its consultants and managers
to identify strengths in climate analysis as well as biases and misaligned
incentives hamstringing the Transition. To re-fresh its relationships, the
Fund should evaluate third-parties to determine the extent of their knowledge
and capabilities regarding climate risk and opportunity. As necessary, the
Fund should also actively solicit new consultants and managers with particular
expertise in climate.
Integrate sustainability metrics into
compensation structures. The Panel
recommends the Fund further incorporate sustainability goals into the
compensation structures of its staff, consultants and managers.
Break the soft barriers.
The Panel understands the rationale for minimum check sizes, percent ownership
and non-traditional fee structures. In many cases, however, managers and
vehicles best poised to capitalize on the Transition will not fit the Fund’s
conventional manager mold. The Panel recommends the Fund establish new
criteria and metrics to evaluate all asset managers on sustainability criteria
and for the climate solutions allocation in particular.
Review staffing requirements.
The Panel believes the Fund will need more staffing not only to manage the
different initiatives in these recommendations, but also to bolster in-house,
climate-specific capabilities. The Fund should consider the appropriate level
of dedicated staff and other resources needed to maintain and ratchet its
leadership in light of the rapidly evolving array of data sources, products,
managers and consultants responding to the Transition.
On the Fund’s Engagement Processes
The Panel recognizes
the Fund’s leadership in corporate engagement activities and encourages the Fund
to continue its efforts. Accordingly, the Panel recommends the following:
forward-thinking companies. The Fund’s voice is powerful and the
Panel recommends that the Fund seek out forward-thinking companies in which
the Fund has a stake in order to support those companies to effect and
accelerate positive change across their industries.
Engage with consequences.
The Panel encourages the Fund to utilize all active ownership tools available
to them up to and including legal action where necessary. However, in light of
the urgency needed on the climate issue and in cases where companies continue
to resist change, the Panel recommends the Fund establish a glide- path,
including active engagement, so that it will no longer own securities in
companies that do not meet and are not making progress toward the Minimum
Standards. This should be accomplished as soon as the Fund’s capabilities
allow. To achieve this goal, the Fund will benefit from working in partnership
with select index managers and owners.
Engage with investment managers.
As soon as the Fund’s capabilities allow, the Panel recommends that the Fund
find new managers that are able to invest in accord with Minimum Standards and
no longer invest in new managers that do not meet Minimum Standards. As well,
the Panel recommends that the Fund leverage its capabilities to empower funds
it already owns to develop new sustainable strategies. Lastly, the Panel
recommends that where existing managers do not meet Minimum Standards, the
Fund will no longer increase allocations to these managers and may re-consider
the relationship altogether.
Collaborate with peers.
The Panel supports the disclosure of the Fund’s stewardship activities as a
way to communicate its leadership in active ownership leadership activities.
We recognize that engagement in concert with like-minded peers can be more
effective and serve to educate and learn from others. The Fund is currently
participating in Climate Action 100+ and the Panel recommends continuing and
expanding these types of engagement initiatives as resources allow.
On the Fund’s efforts in Advocacy and Education
The Panel recognizes
the Fund’s current efforts in advocacy and education and the value these
activities serve in support of advancing the field of sustainable investing. The
Panel recommends the following enhancements:
beneficiaries. The Panel encourages the Fund to continue and enhance
its efforts to educate its beneficiaries about the impact climate change will
have on the State of New York and what can be done to adapt to and mitigate
Advocate for smart climate finance policy.
The Panel encourages the Fund to continue and ratchet-up where possible its
advocacy efforts with state, national and international government bodies in
support of progressive climate policy, particularly policies that incentivize
the investment community. Specifically, for the government of New York State,
the Panel encourages the Fund to be proactive in suggesting investment
structures for state-related climate initiatives that will allow the Fund to
financially support these initiatives.
The panel recommends the Fund ensure staff are actively encouraged to keep up
to date on information and best practices around climate-related risks,
impacts and the Transition, especially as events are unfolding rapidly in
science and across the finance sector.
On the Fund’s Investment Products
The Panel recommends
the following actions with regard to specific investment products:
best-in-class index products. The Panel recognizes the Fund’s heavy
reliance on passive index products. Based on the Panel’s belief that
traditional index products carry risk that is not adequately priced in light
of climate change, the Panel recommends the Fund work with consultants,
managers and partners to develop new index products that better account for
climate-related risks. These index products may include the following:
A low-carbon index
that includes a tilt towards companies better poised for the Transition;
An index with an
active overlay where non-compliant companies can be sold; and
An index built on
Minimum Standards for climate-related risks.
Investigate direct and co-investments
capabilities. Particularly for the new
sustainability asset class, and with support of climate-wise advisors, the
Fund should consider pursuing direct or coinvestment opportunities in climate
infrastructure and real estate.
Seed new strategies.
The Fund should consider seeding new managers, including the “fund of one”
strategy where the Fund is the only Limited Partner, having architected the
strategy and the General Partnership. The Panel also supports consideration of
the Danish pension fund model of creating a separately managed climate
infrastructure team as a possible avenue to pursue investments in the climate
Develop partnerships for green lending.
The Fund should explore partnerships with the New York State Energy Research
and Development Authority (NYSERDA), the Green Bank and other agencies to
establish a sustainable lending facility. This partnership would be supported
out of the new asset class with the same absolute return benchmark.
Exhibit A: Minimum Standards Framework
Minimum Standards based on sound climate science and best-in-class management
practices is critical to implementing the Panel’s recommendations. Designing
those standards, however, is beyond the remit of a group of volunteers, no
matter how expert. The Panel thus offers below a possible framework for
establishing Minimum Standards.
An effective set of
Minimum Standards would be contextualized to match the Fund’s investment
portfolio and decision-making processes. At best, robust Minimum Standards can
serve to overcome many of the principal-agent problems that exist within
investing in general and sustainable investing in particular. The examples below
are simplified and are provided solely as illustrative of the proposed
framework. Details in the examples are not part of the recommendations.
What are Minimum
Criteria that define
desired behaviors, achievements or position relative to an established and
The criteria may be
quantitative, qualitative or a combination of both.
The criteria would be
coupled with definitive actions should the standards not be met according to a
criteria are not met according to the defined timeline, the types of actions
taken would ideally be in the form of direct investing decisions (e.g. buy,
sell, hold), but could also be interim steps such as moving to more aggressive
active ownership tools.
would be codified through the use of contracts or other documentation and
supported through the alignment of compensation and governance structures.
Examples of criteria
company’s rate of decrease in GHG emissions year-on-year.
corporate governance system for the management of climate-related issues.
A climate policy
for an investment manager that clearly addresses risks and opportunities
from physical impacts and the Transition.
A lobbying policy
actively supporting government actions to address climate changes.
existing framework such as the TCFD Disclosure Recommendations or the
Climate Action 100+ strategy.
professional compensation structures tied to specific sustainability
outcomes or decision-making processes.
Examples of actions
and timelines include:
By 2020, exclude
all companies that derive more than 10% of revenue from mining thermal coal
or account for more than 1% of global production.
If less than 5%
decrease in GHG emissions year on year after [#] engagements, consider a
If a manager has no
climate policy after engaging for [X] years, consider no new allocations.
If a company shows
no progress after engaging on all of the selected engagement criteria,
mandate that managers remove that security from segregated funds.
How might Minimum
Standards be implemented?
Minimum Standards can
be set for companies, funds, indices, fund managers and consultants. Given the
reliance of the Fund on external managers and passive indices over direct
investing, the Panel proposes that the standards be layered as described below.
should be applied to external managers and general partners. These standards
would likely focus on manager processes and capacity (education, staff,
resources) to apply a climate lens to their own investment process.
In order to apply
Minimum Standards to companies, the Fund can communicate its expectations
around sustainable assets and climate solutions to the managers. The Fund
could leverage existing methodologies, such as that of Climate Action 100+,
and expand those methodologies over time.
For index providers,
Minimum Standards might be a combination of criteria on the index provider’s
processes and capacity and serve as a climate lens that acts as an active
overlay on an index.
should consider changing conditions including the Fund’s climate ambition,
capacity and resources over time.
should not be static. Criteria and actions should evolve to match the Fund’s
climate goals as they change over time.
The Fund can phase-in
Minimum Standards to sub-categories according to a priority ranking such as
greatest risk, ease of implementation, etc. Sub-categories that could be
products, e.g., indices, segregated funds, comingled funds, bonds;
e.g., consultants, external managers, general partners;
By asset classes,
e.g., private equity, real estate, public equities, fixed income;
By sector, e.g.,
energy, agriculture, transportation;
e.g., utilities, clean energy, manufacturers, upstream oil and gas; and
By regions, e.g.,
coastal areas, US, emerging markets.
Below are a few
examples for how Minimum Standards might be implemented. These examples are for
illustrative purposes only, are by no means comprehensive.
such as fossil fuel producers, will be more affected by the Transition than
others. Starting with the highest risk sub-sectors first, the Fund could
design a set of Minimum Standards that define expectations with respect to
identifying, managing and measuring climate risk. The standards would inform
the Fund’s engagement with companies and managers holding securities in these
sub-sectors. If the Minimum Standards are not met, the actions triggered will
depend on whether the company is held in a segregated fund (divest), in new
comingled funds (do not invest), in indices (work with index provider). Over
time, the set of sub-sectors can be expanded to the next most affected by the
Transition in an order such as fossil fuel power generators, automotive
vehicle manufacturers, utilities, service industries to the fossil fuel
Some companies and
assets will have characteristics that make them more exposed to physical
climate risks. Companies or managers with these characteristics will require a
different set of Minimum Standards around adapting to physical risks,
anticipating implications to their operations and managing financial losses
due to increased cost and liability. These Minimum Standards might include
criteria such as a robust and climate- informed board and enterprise risk
publication, including footnotes, is available
Harvard Law School Forum
on Corporate Governance and Financial Regulation
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