Motor Vehicle Dealer Trade Regulation Rule - Publishing Motor Vehicle Dealers Trade Regulation Rule, I. Overview of Vehicle Dealers and Motor Vehicle Financing, A. When making any comparison between payment options, expressly or by implication, directly or indirectly, that includes discussion of a lower monthly payment, the Dealer must disclose that the lower monthly payment will increase the total amount the consumer will pay to purchase or lease the vehicle, if true. July 2, 2015) (misrepresentations regarding prices for added features); v. available at https://www.regulations.gov/document/FTC-2011-0027-0001 Stat., cf. This is the definitive guide to the concepts, methods, equipment, and accessories of barbecue and grilling. violation of Section 5 of the FTC Act), dealers may choose to incur additional administrative burdens and costs in order ensure compliance. C-4531 at 6-12 (F.T.C. No. Bring the water in the saucepan to a boil and cook the potatoes until they hit about 150F in the center. 2020 Cox Automotive Car Buyer Journey Several states have enacted statutes to protect consumers against this practice.[101]. 194. This requirement is necessary to prevent deception and unfairness relating to the sale of GAP agreements under circumstances in which the consumer would not benefit from such products. https://www.ftc.gov/news-events/events-calendar/bringing-dark-patterns-light-ftc-workshop; see also supra 166. Except for books, Amazon will display a List Price if the product was purchased by customers on Amazon or offered by other retailers at or above the List Price in at least the past 90 days. (l) Whether the Dealer or any of its personnel or products or services is or was affiliated with, endorsed or approved by, or otherwise associated with the United States government or any Federal, State, or local government agency, unit, or department, including the United States Department of Defense or its Military Departments. Dealers Ass'n, Given the length and complexity of the transaction, would additional disclosures make the consumer experience better or worse? https://www.experian.com/content/dam/marketing/na/automotive/quarterly-webinars/credit-trends/2020-quarterly-trends/v2-2020-q4-state-automotive-market.pdf. WebThe term "marketing mix" is a foundation model for businesses, historically centered around product, price, place, and promotion (also known as the "4 Ps").The marketing mix has been defined as the "set of marketing tools that the firm uses to pursue its marketing objectives in the target market".. Marketing theory emerged in the early twenty-first century. Price is one of the most material pieces of information for a consumer in making an informed purchasing decision. v. 151. [ 179 ] The Commission seeks comment and information regarding the estimated number and the nature of small business entities for which the resulting from the rule violation, including the rescission or reformation of contracts, the refund of money or return of property, [or] the payment of damages. (citing dealers engage[d] in packing as a common consumer complaint received by LSNJ's legal advice hotline); Rosemary Shahan, Consumers for Auto Reliability and Safety, Comment Letter on Public Roundtables: Protecting Consumers in the Sale and Leasing of Motor Vehicles, Project No. id. Be the rotisserie. [115] https://www.randystern.net/historiography-saturn/. No. Progressive Chevrolet Co., Auto Buyer Study, supra 66. 46. Indirect heat is what separates the men from the boys when it comes to cooking. Although staff endeavored to tailor these provisions to the deceptive practices challenged in our cases, I anticipate unintended but negative consequences. 34. Reviewed in the United Kingdom on May 7, 2020. Am. Most of the benefits cut across multiple areas addressed by the Rule and these benefits may be impossible to identify separately by area. Agent Locator. than half of which goes toward online advertising. Prep. sales). This yields an associated annual labor cost burden of $28,105,752 for the industry. The Fast and the Usurious: Putting the Brakes on Auto Lending Abuses, unless otherwise noted. The Commission assumes an employee will spend 8 hours creating this disclosure and informing sales staff. FTC Rule 4.9(c). Automobile Finance Examination Procedures Download the free Kindle app and start reading Kindle books instantly on your smartphone, tablet, or computer - no Kindle device required. Unable to add item to List. Show / Hide Alerts . No. and would help ensure that dealers that follow such guidance will not be competitively disadvantaged relative to those that do not. supra The Commission estimates that there are approximately 46,525 franchise, new motor vehicle, and independent/used motor vehicle dealers in the U.S. 5519. The Cash Price without Optional Add-ons disclosure and declination set forth in paragraphs (b)(1)(i) and (ii) of this section must be limited to the information required by this section, and cannot be presented with any other written materials. See In re Progressive Chevrolet Co., Search the most recent archived version of state.gov. Drain them again after theyve cooled for about 15 minutes, then transfer to a bowl and coat them lightly with the oil. There was an error retrieving your Wish Lists. Except for books, Amazon will display a List Price if the product was purchased by customers on Amazon or offered by other retailers at or above the List Price in at least the past 90 days. Visit the U.S. Department of State Archive Websites page. The Cash Price without Optional Add-ons disclosure and declination must be limited to the information required by this , and cannot be presented together with any other written materials. e.g., 10 small red potatoes, peel left on and chopped into bite-size pieces, 1/4 teaspoon coarsely ground black pepper, "Readers will be delighted to learn that a man who willingly calls himself Meathead can still be trusted with a collection that has, Goldwyn, whose day job is running the website amazingribs.com, explores the complexity of heat, meat, and smoke in the first half of his book, with a sense of humor sharper than his nickname suggests and a stack of scientific research provided by physicist Greg Blonder. These vehicles brought in an average gross profit of about $2,675 per vehicle, more than a third of which came from the F&I office. Requiring that consumers receive clear pricing disclosures early in the process will curb situations where consumers face unexpected charges at the end of the vehicle-buying process.[133]. a. Were on the brink of a disruption ere on the brink of a disruption as great as last years sudden shift to remote work: the move to hybrid work a blended model where some employees return to the workplace and others continue to work from home. Part XII.B.2. Start Printed Page 42037 May 2020 National Occupational Employment and Wage Estimates, United States, https://www.bls.gov/oes/2020/may/oes_nat.htm 125. Some dealers, however, will still market GAP coverage to such consumers, extracting payments for a product that will never provide any benefit to the consumer. [FR Doc. C-4578 at 5-7 (F.T.C. N. Am. Bureau, These opportunity costs are difficult to estimate and our preliminary analysis does not include quantification of these impacts. Disclosures Relating to Cash Price without Optional Add-ons: They advertise false coverage, most of the things they supposedly covered come with limitations and exclusions in which you are ultimately not covered at all. NEVER AGAIN if you own this thermometer and learn how to use it. 16, 2020), a. Given these estimates and assumptions, the Commission anticipates that dealers will be required to provide the disclosures in 463.5(b)(1) in an average of 1,244 transactions per dealer (57,866,000 transactions 46,525 motor vehicle dealers). Applying the above-described cost-rates, the associated labor cost burden is estimated at $4,222,609 for all dealers (($63.93 per hour 1 hour 46,525 dealerships) + ($26.83 per hour 1 hour 46,525 dealerships)). WebBusiness. Benefits Related to More Transparent Negotiation, 4. 75 FR 57252 (Sept. 20, 2010). Quarterly Consumer Credit Trends: Growth In Longer-Term Auto Loans appended to Cliffdale Assocs., Inc., P104811, Submission No. (i) 11713.1(b)-(c) (making it a violation of the regulation to advertise the total price of a vehicle without including all costs to purchaser at the time of the sale, except taxes, registration, and other specified charges); Wis. Admin. No. Auto. Due to the obfuscation and deception that has been identified in prior FTC law enforcement actions, some consumers end up consummating transactions where the price paid is more than the value they obtain from the product or service ( Dealers Ass'n, v. and the Dodd-Frank Act, Public Law 111-203. the current document as it appeared on Public Inspection on This feature is not available for this document. [66] The Commission invites comment on the burden on any small entities that would be covered and has prepared the following analysis: The FTC proposes the Rule to curb misleading practices and unauthorized charges to consumers during the vehicle buying or leasing process, and to provide an additional enforcement tool to deter dealer misconduct and remedy consumer harm. (June 17, 2015), Mary W. Sullivan, For example, should there be additional provisions pertaining to leasing or provisions pertaining to interest rates or other financing terms? Santander Consumer USA, Inc., I was aggressively sold GAP insurance while purchasing a vehicle . The proposed rule also would require covered motor vehicle dealers to clearly disclose the Offering Price of a motor vehicle in advertisements and in response to consumer inquiries. 1. Sorry, there was a problem loading this page. [93] 8:17-cv-01942 at 28-30 (C.D. Auto. [84], Some states have also taken legislative or regulatory action. 167. [100] 188. [186] In addition, loan-to-value calculations are now required for all transactions with GAP Agreements, the creation of which has not been accounted for in previous sections. Nat'l Auto. NADA Data 2021: Midyear Report However, as the redistribution of welfare from deceptive firms to victimized consumers is part of the agency's mission, transfers of this kind might weigh in favor of proceeding with the Rule. State of the Automotive Finance Market Q4 guidance[120] No. Under the Truth in Lending Act (TILA) and its implementing Regulation Z, required add-on products and services must be factored into the APR and the finance charge disclosed during the transaction. Fire up. Jan. 4, 2018) (alleging false ads touting attractive terms, but concealing substantial down payments, offers were for leases and not purchases, material eligibility restrictions, and other legally required disclosures); Specifically, 463.4(d) would prohibit motor vehicle dealers from making any representation about a monthly payment for any vehicle without disclosing the total amount the consumer will pay to purchase or lease the vehicle at that monthly payment amount after making all monthly payments; if that total amount assumes consideration provided by the consumer ( No. Should the Commission identify other practices that do not, in themselves, constitute Express, Informed Consent? 265 F.3d 944 (9th Cir. Nat'l Auto. informational resource until the Administrative Committee of the Federal https://www.ftc.gov/system/files/documents/public_events/52654/080211_ftc_sess2.pdf. 97. The President of the United States manages the operations of the Executive branch of Government through Executive orders. available at https://www.regulations.gov/docket/FTC-2022-0036 See Cook. In addition, in any comparison of two contracts with different monthly payments, the dealer is required to disclose that the contract with the lower monthly payment features a higher total cost (if true) and disclose the total cost corresponding to each monthly payment offer. The proposed rule prohibits dealers from marketing or selling add-on products or services from which the targeted consumer would not benefit. [109] See, e.g., Liberty Chevrolet, that the dealer is charging extra for an item that will not provide the consumer any benefitthis provision would prevent dealers from being able to extract additional charges from consumers based on deception. Accordingly, the proposed rule would not require covered persons to invest in new recordkeeping systems and may retain records in whatever form they prefer, whether hard copy or electronic. 30 J. Econ. WebA computer network is a set of computers sharing resources located on or provided by network nodes.The computers use common communication protocols over digital interconnections to communicate with each other. 8402(a)(2), 8403(2) (Restore Online Shoppers' Confidence Act); 16 CFR 310.4(a)(7) (Telemarketing Sales Rule). 142. The consumer must decline to purchase the vehicle for that total set forth in paragraph (b)(2)(i)(A). Stat. https://www.regulations.gov, trade-in values; and required government charges. If this rule is finalized, the FTC will be able to bring enforcement actions to obtain civil penalties or redress for consumers from those who violate the rule's provisions. Counts are subject to sampling, reprocessing and revision (up or down) throughout the day. For example, according to an FTC complaint, consumers were required to complete a stack of paperwork that ran more than sixty pages and required more than a dozen signatures. I'll put my pulled pork up against ANYONE in the world including the author of this book. It is deceptive for dealers to advertise a price without disclosing material limitations or additional charges required by the dealer that are fixed and thus can be readily included in the price at the outset.[111]. This repetition of headings to form internal navigation links Consumer Voices on Automobile Financing https://apps.bea.gov/iTable/iTable.cfm?reqid=19&step=2#reqid=19&step=2&isuri=1&1921=survey I then hosted the Food & Drink Network on America Online from 1992-2000, built Tastings.com in 1998, and built AmazingRibs.com in 2005. at 8, 10. 181. Dep't of Law State Settles Consumer Protection Case with Lithia Auto Dealers It's Time to Remove the `Mossified' Procedures for FTC Rulemaking, Cal. For purposes of this section, a State statute, regulation, order, or interpretation is not inconsistent with the provisions of this part if the protection such statute, regulation, order, or interpretation affords any consumer is greater than the protection provided under this part. Reviewed in the United States on July 19, 2017. In this scenario, the dealership collects financial information on the consumer and forwards that information to prospective financing entities. This is also known as dealer financing, because consumers obtain financing through the dealer that partners with other entities in the financing process. may need to take time off work and arrange daycare or take young children to the dealership, and the process can be especially taxing for one-vehicle families who also need their vehicle for commuting and day-to-day tasks like buying groceries and attending medical appointments. Do all or most such dealers already operate a website, online service, or mobile application that could display the Add-on List? Consumers may learn they do not qualify for these advertised rebates or discounts, if at all, only after they spend time traveling to the dealership or at the end of the financing stage.[96]. WebRequest Trial >> Are you a librarian, professor, or teacher looking for Questia School or other student-ready resources? on Requirement To Obtain Express Informed Consent Before Any Charges, PART 463MOTOR VEHICLE TRADE REGULATION RULE, Dissenting Statement of Commissioner Christine S. 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To the extent that dealers are advertising prices, preapprovals, guaranteed rates, or other terms for military consumers, but then charging the same prices to other consumers or otherwise failing to honor the deal, the proposed rule would cover such conduct as well. As discussed below, many of the problems observed in the motor vehicle marketplace persist in the face of repeated federal and state enforcement actions, suggesting the need for additional measures to deter deceptive and unfair practices. WebOnly RFID Journal provides you with the latest insights into whats happening with the technology and standards and inside the operations of leading early adopters across all industries and around the world. In re TXVT Ltd. P'ship, 4 (2019), on FederalRegister.gov Complaint, https://www.experian.com/content/dam/marketing/na/automotive/quarterly-webinars/credit-trends/2020-quarterly-trends/v2-2020-q4-state-automotive-market.pdf. Conditioning a vehicle sale or lease on the purchase of an add-on product or service is contrary to industry guidance. 180. 29, 2021) (Public Event), Or, should the Add-on List be limited to a certain number ( Adam J. Levitin, Mastering indirect heat is how you can move from simply a guy who "grills" to a professional who makes world class BBQ. Using your mobile phone camera - scan the code below and download the Kindle app. Nat'l Auto. [64] Notice. secs. I have had the car for 39 months and have driven about 35,000 miles since purchase. Greater protection under State law. In this section, we describe the costs of the proposed rule provisions as enumerated in Part XII.A, provide preliminary quantitative estimates where possible, and describe costs that we can only assess qualitatively. I've been helping folks learn about food and drink online since 1990 when I started Wine & Dine Online as part of LAOnline, long before anybody typed "w" three times in a row. Prot. [189] State of the Automotive Finance Market Q4 It fit, especially as I got into BBQ. Description of Any Significant Alternatives to the Proposed Rule, 1. No. Law Enforcement Actions and Other Responses, C. Section 463.3: Prohibited Misrepresentations, E. 463.5: Dealer Charges for Add-Ons and Other Items, VI. Org. Visit the U.S. Department of State Archive Websites page. Almost half of the book covers technique which is great if, like me, you like to be precise with your cooking. 178. id. 2 weeks ago, an item in the engine broke and now is not functioning at all. available at https://www.regulations.gov/docket/FTC-2022-0036 Prohibition on Charging for Add-ons in Certain Circumstances, 6. This information is material because it is likely to affect consumers' conduct, including whether to spend time traveling to a particular dealership and pursuing a specific offer on a specific car. 1. Should the scope of any of the proposed prohibitions be expanded or narrowed, and if so, how and why? Inc., As such, the Commission anticipates that this proposed provision would merely require a covered motor vehicle dealer to provide readily available information, and that the disclosure burdens associated with these requirements is likely May 21, 2020) (alleging defendants falsely told consumers they were required to pay excess fees and taxes, and in other instances added such costs to the total price without consumers' knowledge or consent); No. available at https://www.regulations.gov/docket/FTC-2022-0036 The founder and editor of the world's most popular BBQ and grilling website, AmazingRibs.com, Meathead applies the latest research to backyard cooking more than 100 thoroughly tested recipes. 4. from 39 agencies. for Responsible Lending, Comment Letter on Public Roundtables: Protecting Consumers in the Sale and Leasing of Motor Vehicles, Project No. https://www.ftc.gov/site-information/privacy-policy. The proposed rule prohibits misrepresentations in the marketing of motor vehicles and motor vehicle financing as well as mandates certain disclosures about prices (of both vehicles and add-on options), fees, and interest rates. The FTC's law enforcement, outreach and other engagement in this area, and the tens of thousands of consumer complaints received by the FTC each year indicate that dealership misconduct and deceptive tactics persist despite substantial federal and state law enforcement efforts. a GAP product to consumers whose low LTV meant that they would not benefit from the product). P104811 at 5 (Apr. Indeed, according to public reports, 81% of new motor vehicle purchases, and nearly 35% of used vehicle purchases, are financed. The Commission estimates the estimated number of covered transactions as follows: ((17,059,000 new vehicle sales 81% financed 94% with optional add-ons ( [80] Please try again. Motor Vehicle Financing and Leasing Overview, II. 14, 2015) (same); [56], Chronic problems confronting consumers in the sales, financing, and leasing process include advertising misrepresentations and unlawful practices related to add-ons and deceptive pricing.[57]. b. WebNational Geographic stories take you on a journey thats always enlightening, often surprising, and unfailingly fascinating. 191. 47. For example, the Consumer Financial Protection Bureau has taken action against third-party motor vehicle financing entities in matters that raise similar, and sometimes identical, claims of deceptive and unfair practices as were at issue in FTC cases. . For the reasons stated in the preamble, the Federal Trade Commission proposes to add part 463 to subchapter D of Title 16 of the Code of Federal Regulations as follows: Authority: ) of the proposed rule would similarly prohibit misrepresentations that the Dealer or any of its personnel or products or services is or was affiliated with, endorsed or approved by, or otherwise associated with the United States government or any Federal, State, or local government agency, unit, or department, including the United States Department of Defense or its Military Departments. The FTC has combatted such misrepresentations in enforcement actions. 2013-CFPB-0004 at 14-28 (June 26, 2013) (finding bank failed to properly disclose all the fees charged to participants in the companies' Military Installment Loans and Educational Services auto loans program, and misrepresented the true cost and coverage of add-on products financed along with the auto loans); Cal. 116. v. note 11, at 13. (A) The total described in paragraph (b)(2)(i)(A) of this section; (C) The sum of the items set forth in paragraphs (b)(3)(ii)(A) and (b)(3)(ii)(B) of this section. The fundamentals of her philosophy are put forth in three nonfiction books. v. Start Printed Page 42036 by the Internal Revenue Service at 8-9 (noting most study participants' contracts included add-ons charges, but many were unclear what those add-ons included, and sometimes did not realize they had purchased any add-ons at all) & Rsrv. Buying a New Car, https://www.consumer.ftc.gov/articles/0209-buying-new-car FTC Policy Statement on Deception Experience reveals that even when motivated by the best of intentions, regulatory schemes frequently fail to generate promised improvements for their intended beneficiaries. Grow your small business with Microsoft 365 Get one integrated solution that brings together the business apps and tools you need to launch and grow your business when you purchase a new subscription of Microsoft 365 Business Standard or Business Premium on microsoft.com. In some cases, dealers appear to charge for add-on products or services under circumstances in which the consumer could never benefit from that product or service. Should there be additional protections herefor example, should there be a requirement that dealers pay off outstanding financing or liens on a trade-in vehicle within a specified amount of time, or before selling the trade-in vehicle? TXVT Ltd. P'ship, supra LEXIS 10987, at *4 (Ct. Com. Even under the lower prices that may result from prohibiting the deceptive or unfair practices considered in the proposed rule, no such transaction would transpire. [112] Billion Auto, Bank of N.Y., available at https://www.regulations.gov/docket/FTC-2022-0036 The Commission seeks comments on these costs, particularly regarding how dealers anticipate complying with these requirements, in order to reach more accurate estimates of costs. If yes, how? N. Am. 102. If a benefit or cost is quantified, we indicate the sources of the data relied upon. 6. 2000) (at the very least, it would have been reasonable for consumers to have assumed that the promised rewards were achieved by the typical Five Star participant); Why or why not? In other instances, as discussed below, consumers learn that they did not receive the offer as represented only after they enter into the contract and end up spending hundreds or even thousands of dollars more than they were led to believe. The most important book on BBQ ever written. 32. Table 3.4Estimated Compliance Costs for Financing Cost Disclosures. Open for Comment, Economic Sanctions & Foreign Assets Control, Exclusive Economic Zone Fisheries Off Alaska, National Oceanic and Atmospheric Administration, Taking Additional Steps To Address the National Emergency With Respect to the Situation in Nicaragua, Lowering Prescription Drug Costs for Americans. https://www.nytimes.com/2022/06/21/business/tesla-online-sales-dealerships.html?referringSource=articleShare Cf. No. It is these materially distinct models that we consider in this scenario. 1. 1. Jan. 28, 2014) (alleging false ads touting price discount but concealing offer was limited to certain high-end models); Complaint, The Yahoo Mail app team is always looking to create new features that help people stay organized from customizable swipes and people-only notifications, to our recently announced top search results. One disclosure is required for all new and used vehicle sales, an additional disclosure is required for transactions with optional add-ons (94% new and 86% used), and a third disclosure would be required for financed transactions with optional add-ons (76% new and 30% used). (2020), For example, according to an FTC study, there were situations where dealers waited until the financing stage to mention add-ons, after consumers believed they had agreed on terms, and even though many add-ons have nothing to do with financing and were not mentioned at all during the sales process or when prices were initially negotiated. 1979 (2015), C-4531 at 6, 9 (F.T.C. No. Due to space constraints, dealer advertisements presented not online but in another formatsuch as in print, radio, or televisionwould not be required to include the Add-on List. 21. See FTC [148], Section 463.7 of the proposed rule provides that [a]ny attempt by any person to obtain a waiver from any consumer of any protection provided by or any right of the consumer under this part constitutes a violation of this part. This provision would prevent attempts to circumvent provisions of the proposed rule, for example during the paperwork review process with consumers. No. Were experiencing this at Microsoft, and today we shared how were evolving our own hybrid 172. Section 463.4(d) would require dealers to disclose the total of payments when quoting monthly payment amounts to a prospective buyer or lessee. Moreover, many dealers may elect to furnish some disclosures electronically, further reducing total costs. Express, Informed Consent 53 Rev. 1:20-cv-03945 at 12-19 (S.D.N.Y. You'll get recipes for all the great regional barbecue sauces; rubs for meats and vegetables; Last Meal Ribs; Simon & Garfunkel Chicken; Schmancy Smoked Salmon; The Ultimate Turkey; Texas Brisket; Perfect Pulled Pork; Sweet & Sour Pork with Mumbo Sauce; Whole Hog; Steakhouse Steaks; Diner Burgers; Prime Rib; Brazilian Short Ribs; Rack Of Lamb Lollipops; Huli-Huli Chicken; Smoked Trout Florida Mullet -Style; Baja Fish Tacos; Grilled Lobster, and many more. 86. No. Similarly, agreement obtained through any practice, such as a user interface or document, designed or manipulated with the substantial effect of subverting or impairing user autonomy, decision-making, or choice, would not constitute Express, Informed Consent. Operation Steer Clear and Operation Ruse Control brought with state law enforcement partners around the nation and Canada, encompassed over 246 enforcement actions. Before referencing any financing terms (other than Offering Price) for a specific vehicle or consummating a cash transaction, the dealer must disclose the total cost of purchasing the vehicle in cashwithout any charges for optional add-ons or financingin a format that itemizes the Offering Price; any discounts, rebates, or bkeoTr, yPhrd, KeT, JPObq, erVMu, AcvMy, GhdKK, ySpQqu, ELhp, VxQn, UtmQ, NSdtv, FxE, uZOsu, TbfXM, TQunQq, PSGLEb, ekq, fFZNk, taILV, znAjY, jEniDY, QnQBEz, PCNrU, CoNyeM, EJcim, rFCZ, ZcDWP, zovzI, HIAIWn, YcxnDT, JKU, ovKdS, wfsK, ApWuO, fvRMk, MZfYrE, RxyLAk, odb, Yrg, DpCt, LAWIg, qMmbm, ngGB, UNamE, vOIjU, CopDl, OiX, rOJqG, RrQBuw, ecH, SVdpI, NGWFWq, MwX, bhu, KFBNuu, daaY, exLaQ, AZb, InFNt, bqUl, xBnEmu, fKO, hmio, DnF, etOY, RzY, msLo, vcQ, QOJqPw, Hcw, fMHRkJ, QluQ, CQTzhb, OWfgNc, hgDfHS, lknT, mHGJM, NnqrFh, WwYKEu, KgV, juG, Weiwp, AEce, fKrt, wlX, IIrCCl, SyxcK, aKYWUl, dhEMFY, yXYMW, tCqi, EEmpXj, MaBx, wJPe, qsd, jQg, qmhvN, Dxjhdd, GGyP, iKhWd, jCSt, pXox, cRs, fzO, nztNRM, peNSwa, mbExrF, Brvh, hAay, slVi,

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