GEPF change rules regarding pension debt on divorce

Following the gazetting of the Government Employees Pension Law Amendment Bill on 23rd May 2019, the Government Employees Pension Fund (GEPF) will, once the amended rules are implemented, no longer subject a member to a debt model in executing a divorce settlement. Instead the new amendment provides for the reduction of pensionable service of the GEPF member that is equal to the value of the divorce settlement amount paid.

This amendment to the law removes the pension debt that accrued to the GEPF member when a portion of their pension was paid out by the GEPF as a divorce settlement.  This pension debt calculation created the perception that members could find themselves owing money to the GEPF when they retired.

The amendment now ensures that rather than creating a debt, there will be an adjustment to the member’s pensionable service following the payment of a divorce settlement by the GEPF. This means that the benefit that will be paid to the member upon retirement will now be decreased by reducing the members’ years of pensionable service to take into account the pension interest of the member that was given to the spouse upon divorce. 
Therefore, members will receive their full benefit after the reduced pensionable service has been affected. Members who have more than ten years of pensionable service will still be entitled to a lump sum and a monthly pension upon existing the fund, however at a reduced value. 

Following this law change, the GEPF is currently developing and gazetting rules that will govern the implementation. It is expected that this process will be finalised in July 2019 and the implementation of the new rules will come into effect as of the 01st August 2019.

Parallel to the process above, the GEPF will be writing to all affected GEPF members in July 2019 to inform them about how these changes are going to affect their pensions and service period and allow them the opportunity to opt from the old divorce debt model into the service reduction model. The affected members will have up until the 22nd May 2020 to indicate their choice of either remaining with the debt and interest model or move to the service adjustment model approach. Currently affected members who fail to indicate their choice by 22 May 2020 will automatically be converted into the new approach. Post 22 May 2020 all members who have a legal divorce claim against their pension will be subjected to the service reduction model.

Government Employees Pension Fund pensioners will receive a 5.2% annual pension increase as of 1 Apr

Government Employees Pension Fund (GEPF) announced today that an annual pension increase of 5.2% to its pensioners with effect from 1 April 2019.

The GEPF has granted this increase to enable pensioners to keep up with rises in inflation.

The pension increase is based on the 5.2% inflation rate for the 12 months ending 30 November 2018 released by Statistics South Africa on 12 December 2018 thus making the increase equal to 100% of Consumer Price Index (CPI) and higher than the 75% of Consumer Price Index (CPI) provided in terms of GEP Law and Rules.

Pensioners whose pensions commenced after 1 April 2018 will receive a proportionate increase based on the number of months they have been in receipt of a pension by 31 March 2019.

It must be noted that increases such as this increase which is above what is provided for in GEP Law and Rules is granted at the discretion of the Board taking the Fund’s investment performance into account.

An analysis of the assets held by the Fund in relation to the valuation of its liabilities undertaken in March 2018 showed that the Fund is 108.3% funded, which means that there are sufficient assets in the fund to cover its actuarial liabilities in full.

This funding level as been achieved despite, amongst others, the:
• increase in the number of pensioners 
• pension increases 
• increase in resignation pay-outs 
• increase in funeral benefits from R7 500 to R15 000 upon death of a member, pensioner or spouse as well as the funeral benefit increasing from R 3 000 to R 6 000 for eligible children
• the introduction of the Child Pension which replaced the Orphan’s Pension.

Benefit improvements over the years together with investment performance, salary and pension increases result in changes in both the minimum and long term funding level.

Statement by the Government Employees Pension Fund on the suspension of PIC Officials

The Government Employees Pension Fund (GEPF) is extremely perturbed by the latest announcement by the Public Investment Corporation (PIC) that it has suspended its Executive Head of Listed Investments, Mr Fidelis Madavo and the Assistant Portfolio Manager, Mr Victor Seanie, following a preliminary investigation report that reflects the flouting of governance and approval processes with respect to the Ayo Technology Solution transaction.

Of serious concern to the GEPF is that the PIC had assured the GEPF on numerous occasions and in correspondence that correct governance processes were followed with respect to the Ayo Technology Solutions transaction. The GEPF views this as a serious breach of trust.

The PIC invested in Ayo Technology Solution as part of the listed portfolio mandate. Thus at the time of its listing, the investment in Ayo fell outside of the unlisted investment portfolio within which there are set governance processes and there are limits set for the PIC to engage the GEPF.

Although the total unlisted investments portfolio comprises less than 5% of the total assets of the Fund, it represents a significant amount of funds. These are funds that the GEPF invests into, contribute to the real economy of the country and to drive transformation but still aiming to realise it main objective of maximising returns. When the actions of officials bring this intention into question, it undermines the objective to invest in the real economy of the country and may lead to a review that may deprive the economy of greatly needed investment.

Despite the apparent failures on this and other investments, the overall performance of the PIC as an asset manager remains positive and in line with agreed criteria. Nonetheless, the GEPF continues to heighten its monitoring and oversight.

The GEPF requests of the PIC Board to urgently finalise its investigations of alleged impropriety with respect to the Ayo transaction and others and take appropriate action where it is warranted.

Minister of Finance appoints new GEPF Board

The Minister of Finance, Mr Nhlanhla Nene yesterday convened the first sitting of the new Government Employees Pension Fund (GEPF) Board of Trustees following the end of tenure of the previous Board. 

The new Board elected Dr Renosi Mokate as Chairperson and Mr Edward Kekana as Vice Chairperson. Both Trustees have been re-appointed to the GEPF Board.
  
The Board of Trustees comprises of 16 members, eight nominated by employer and the other eight nominated by employees. The names of the new Board of Trustees is as follows:

Employer Representative Trustees

Department – Name
National Treasury – Mr Stadi Mngomezulu (Re-appointed)
Department of Defence- Maj Gen Mulungisa Sitshongaye
State Security Agency – Ms Jennita Kandailal
Department of Basic Education – Dr Morgen Pillay (Re-appointed)
DPSA – Mr Thabo Mokwena
SAPS – Lt Gen Lineo Ntshiea
Specialist – Dr Renosi Mokate (Re-appointed)
Specialist – Mr Themba Gamedze (Re-appointed)

Employee Representative Trustees
Department – Name
NEHAWU – Ms Kgomotso Makhupola (Re–appointed) 
SADTU – Mr Edward Kekana (Re-appointed)
NATU- Mr Alan Thompson 
PSA – Mr Pierre Snyman (Re-appointed)
DENOSA – Mr Sibonelo Cele
POPCRU – Adv Makhubalo Ndaba (Re-appointed) 
Uniformed Services – Col Johan Coetzer (Re-appointed)
Pensioner – Dr Frans le Roux (Re-appointed)

The GEPF Chairperson Dr Renosi Mokate welcomed trustees to the GEPF Board and wished them well in their term of office. She thanked the previous Board with whom she had worked with and congratulated them on their achievements over the last four years. GEPF Principal Executive Officer (PEO) Abel Sithole said, “The staff of the GEPF and I welcome the new Trustees to their positions and look forward to their contribution and guidance in the services of members, pensioners and beneficiaries”.

Government Employees Pension Fund pensioners receive 5.5% annual pension increase.

Pretoria – Government Employees Pension Fund (GEPF) has announced an annual pension increase of 5.5% to its pensioners and beneficiaries with effect from 1 April 2018. 

The GEPF has granted this increase to enable pensioners and beneficiaries to keep up with rises in inflation. 
Inflation over one year until 30 November 2017 was 4.6% thus making the increase granted higher than inflation and higher than the 75% of Consumer Price Index (CPI) provided in terms of GEP Law and Rules.

An analysis of the assets held by the Fund in relation to the valuation of its liabilities undertaken in 2016 showed that the Fund is 115.8% funded, which means that there are sufficient assets in the Fund to cover its actuarial liabilities in full. However, increases above those provided for in GEP Law and Rules is granted at the discretion of the Board taking the Fund’s investment performance into account.

PIC/GEPF statement following a meeting on Steinhoff

The Investment Committee of the Government Employees Pension Fund (GEPF) and the Public Investment Corporation (PIC) held a meeting yesterday to discuss the recent developments regarding Steinhoff. It is important to note that notwithstanding the collapse in the Steinhoff share, the GEPF portfolio remains financially healthy, because of its diversified nature. It is also important to note that GEPF members’ benefits will not be changed by these developments, given that the GEPF is a defined benefit pension fund.

The investment loss recorded was 0.6% of the total GEPF portfolio on 6 December 2017. Despite the fall in Steinhoff share, the total GEPF equity portfolio had created a value of approximately R140 billion over the preceding 12 month period, and had performed better than the equity benchmark. Albeit a relatively small reduction in the total portfolio, and despite the signs of recovery in the share price this week, the PIC and GEPF remain deeply concerned about Steinhoff. 

STATEMENT: GEPF position on Steinhoff shareholding

Government Employees Pension Fund (GEPF) has taken note of the current concerns regarding possible lapses in governance at Steinhoff International Holdings and assures its members, pensioners and beneficiaries that their pensions are safe.

As at 31 March 2017 the GEPF through PIC owned about R28billion in Steinhoff International Holdings which is about 10% of the shares of the company but 1% of the total assets of the Fund.  The impact of significant movement in the share price on the GEPF is significant but manageable. 

As a defined benefit fund, the movement in the value of individual investments does not affect the benefits to members and pensioners. Therefore benefits to members and pensioners are safe.

The GEPF expects the highest standards of corporate governance from all investee companies. Allegations of accounting irregularities by Steinhoff International Holdings N.V., that have exposed the company to possible criminal investigations, are a serious concerns for the GEPF. 

The GEPF through the PIC is monitoring the situation while awaiting further information from investigations by domestic and international regulators and/or law enforcement agencies, to decide on an appropriate course of action.

GEPF amend benefit rules for Members

In its endeavor to improve the benefits of member and pensioners, the Government Employees Pension Fund (GEPF) Board of Trustees is pleased to announce the improvement of the funeral and discharge benefit effective from 1 October 2017.

The improvement to the funeral benefit for a GEPF member or pensioner, whose pension either commenced on or after 1 December 2002 or prior to 1 December 2002 and is still alive as at 1 April 2012, the funeral benefit payable upon death of such a member or pensioner and/ his or her spouse and/or eligible children and/or stillborn will be as follows, current amounts are in brackets:
• In a case of a member or pensioner funeral benefit payable is R15 000 (R7 500)
• In a case of a spouse funeral benefit payable is R15 000 (R7 500)
• In a case of eligible child funeral benefit payable is R6 000 (R3 000) per child
• While in a case of a stillborn funeral benefit payable is R6 000 (R3 000) per stillborn, provided that a child was born after 26 weeks of pregnancy who shows no signs of life. If the child was deliberately terminated, a funeral benefit is not payable.
The improvement to the discharge benefit is that if a member has less than 10 years of pensionable service and is discharged for the following reasons:
• Medical reasons ( not of their own doing)
• When jobs are abolished, reduced, re –organised or restructured due to operational requirement
• To promote the efficiency of the department 
• When the President or the Premier appoints the member to another position 
• When injured on duty; or
• Incapability not as a results of own doing
The discharge benefit will be consistent with and not less than the resignation benefit effective from 1 October 2017.

Principal Executive Officer, Abel Sithole said that “these amendments will make a significant difference in our members, pensioners and beneficiaries’ lives. These changes also attest to the fact that the Fund is well managed. Sithole points out that the employer, members and pensioners do not have to make any additional contributions for these benefit improvements. He concluded by saying that the wellbeing of all GEPF members and pensioners is the reason why the Fund exists”.

Members or pensioners who claimed for these benefits before 1 October 2017 will receive payment according to the previous rules. If their claims are effective on or after 1 October 2017 they will receive their benefits payment according to the new rules. Members and pensioners must note that the claim processes and the documentation that is required to claim these benefits has not changed and remains the same.

GEPF is not funding South African Airways (SAA)

Government Employees Pension Fund (GEPF) would like to reiterate and to assure its members, pensioners and beneficiaries that their pension savings are safe.

Last week National Treasury told the National Assembly that it is considering various options to recapitalise South African Airways (SAA) which includes the Public Investment Corporation (PIC) who is our fund manager as a possible equity partner, however Treasury speculation is perceived as confirmation that the GEPF’s assets will be used through the PIC to Fund SAA.

The GEPF would like to assure its members, pensioners and beneficiaries that the Fund has not received or been approached with such a proposal and no discussions have been held with GEPF on this matter, therefore we urge all our members and pensioners not to panic or read too much into this speculation. The GEPF through the PIC receives many requests all the time and rigorously considers the merits of all investment opportunities and invests prudently in the best interests of its members, pensioner and beneficiaries.

The GEPF adheres to strict regulations governing its financial liability to members, beneficiaries and pensioners, as well as its financial soundness. Moreover, the GEPF has confidence in the PIC’s ability to prudently invest funds on its behalf in terms of the agreed investment mandate. The GEPF constantly monitors and evaluates the PIC’s performance in accordance with its investment policy and mandates.

GEPF members, pensioners and beneficiaries are reminded that the primary role of the GEPF is to protect the wealth of its members and pensioners by safeguarding their retirement benefits through proper administration and prudent investment.

Your retirement saving is safe with GEPF, PIC

MEDIA STATEMENT

Thursday, 11 May 2017

Your retirement saving is safe with GEPF, PIC

Government Employees Pension Fund (GEPF) and Public Investment Corporation (PIC) reassure its members and pensioners that their benefits and pensions are not at risk.

The GEPF adheres to strict regulations governing its financial liability to members, beneficiaries and pensioners, as well as its financial soundness. Moreover, the GEPF has confidence in the PIC’s ability to prudently invest funds on its behalf in terms of the agreed investment mandate. The GEPF constantly monitors and evaluates the PIC’s performance in accordance with its investment policy and mandates.

The GEPF would like to reiterate and to assure its members, pensioners and beneficiaries that their pension benefits are safe. They are also reminded that GEPF is a defined pension benefit fund which means the benefits are defined in terms of the rules of the Fund. The benefits are paid in terms of the rules and are not dependent on the investment returns of the fund or on the level of employer contributions. Members and pensioners should therefore not focus inordinately on the ordinary and normal fluctuations of the Fund’s individual investments, which is of greater interest to the GEPF Board of Trustees and the Minister of Finance.

In the past financial year 2015–2016, the assets of the Fund grew to over R1, 6 trillion. The GEPF achieved an overall investment performance return of 4% during this time. This enabled the Fund to grant a pension increase of 5, 3% to its pensioners which was above 100% of the Consumer Price Index (CPI) of 4, 8% as at November 2015. This is higher than the 75% increase recommended by the Rules of the Fund.

The GEPF’s investment strategy also uses a liability-driven approach that takes into consideration expected future benefit payments, the actuarial position, and other long-term objectives, as well as the risk to the overall solvency of the Fund which reflects steady growth and a sustainable long term investments.

GEPF has a solid track record of safeguarding the value of active members’ retirement savings and protecting its pensioners against inflation and it is currently one of very few large defined benefit pension funds in the world which is 100% funded after the 2008/2009 financial crisis. This reflects the Fund’s robust investment strategy and its ability to adapt to dynamic and turbulent market forces.

GEPF affirms that the well-being of all of its members and pensioners is the reason why it exists.

Issued by Government Employees Pension Fund 
For information contact:
Matau Molapo, Communications
T: +27 (0) 12 424 7315 E: Matau.molapo@gepf.co.za 

GEPF announces the 2017 Pension Increase

The Government Employees Pension Fund (GEPF) is proud to announce that the Board of Trustees has granted a 6.6% pension increase to pensioners with effect from 1 April 2017. 
“The increase is equal to the year-on-year change in the consumer price index (CPI) for the year to 30 November 2016, and this attests to the Fund’s undertaking to ensure that pensioners retain their purchasing power,” says Principal Executive Officer, Abel Sithole.

“GEPF has been striving towards paying pension increases that are in line with inflation since inception, this confirms that the well-being of our pensioners remain a priority. The Fund is in a relatively good financial standing and, as per the GEPF Rules, the Fund will continue to pay pensions until a pensioner dies as well as spouse’s and an orphan’s pension where applicable, it does not matter how old they live to be”, adds Sithole.

Note to editors
The GEPF is governed by the Government Employees Pension (GEP) Law of 1996, as amended, and the GEPF Rules that accompany it. The GEP Law and the GEPF Rules, along with GEPF’s Pension Increase and Funding Level policies, give firm guidelines on how the Board of Trustees decide on the annual pension increase that is paid to pensioners.

GEPF pension benefits are intended for members, pensioners and beneficiaries

MEDIA STATEMENT

Thursday, 23 February 2017

GEPF pension benefits are intended for members, pensioners and beneficiaries

The Government Employees Pension Fund (GEPF) adheres to strict regulations governing its financial liability to members, beneficiaries and pensioners, as well as its financial soundness. There are very strict rules governing how benefits from the GEPF must be paid and distributed. These rules are spelled out in the Government Employees Pension Law.

The pension industry as a whole is faced with unclaimed benefits and GEPF is no exception. Unclaimed benefits refer to all cases where more than 24 months have lapsed since an identified benefit became legally payable but, due to a lack of information from the beneficiary, employer or the member, the payment cannot be successfully effected. The benefits remain in the fund until claimants come forward.

Further to GEPF’s Principal Executive Officer, Abel Sithole, appearing at the Commission of Inquiry into Higher Education and Training, GEPF would like to re-iterate the funds in its care are only intended for the benefit of its members, pensioners and beneficiaries only as currently stated in the GEP Law and Rules.

In terms of the current law of the land, the GEPF Law and rules, these funds will remain in the Fund as unclaimed until the member or beneficiary has been traced and cannot be used for funding higher education or any other initiative.

Issued by Government Employees Pension Fund 
For information contact:
Thulisile Mbuli, Communications
T: +27 (0) 12 424 7329 E: Thulisile.mbuli@gepf.co.za

GEPF celebrates 20 years in existence and reflects sustainable growth

GEPF celebrates 20 years in existence and reflects sustainable growth

The Government Employees Pension Fund (GEPF) has released its Annual Report for the financial year 2015 – 2016, marking the 20th anniversary of its existence. The report reflects steady growth and a sustainable investment strategy coupled with continued dedication and service to its members and pensioners.

The GEPF was established in 1996 when various public sector pension funds were amalgamated into one fund. “The 20-year anniversary marks an important milestone for the GEPF as we look back on our legacy and accomplishments,” says Principal Executive Officer, Abel Sithole.

In the financial year 2015–2016, the assets of the Fund grew to over R1,6 trillion. The GEPF achieved an overall investment performance return of 4% during this time. This enabled the Board to grant a pension increase of 5,3% which was above 100% of the Consumer Price Index (CPI) of 4,8% as at November 2015. This is higher than the 75% increase recommended by the Rules of the Fund.

“The GEPF’s investment strategy uses a liability-driven approach that takes into consideration expected future benefit payments, the actuarial position, and other long-term objectives, as well as the risk to the overall solvency of the Fund,” adds Sithole.

In 1996, the GEPF started out with assets under management of R127 billion, which has since increased to more than R1,6 trillion. The GEPF is currently the single largest investor in Johannesburg Stock Exchange (JSE) listed companies, with significant holdings in government bonds, listed equity, money markets, as well as investments in unlisted equity and property.

Accumulated assets have grown at an average rate of 12,09% over the past 10 years. This growth has been in tandem with an improvement in the GEPF’s funding level, an increase from 72% in 1996 to 100% in 2014 (according to the actuarial valuation of 31 March 2014).

Adds Sithole, “the GEPF is proud of this achievement as it is currently one of very few large defined benefit pension funds in the world which is 100% funded after the 2008/2009 financial crisis. This reflects the Fund’s robust investment strategy and its ability to adapt to dynamic and turbulent market forces”.

The total membership of the GEPF now stands at 1 693 078 consisting of 1 269 948 members who are still in service and 423 130 pensioners and beneficiaries. The good news is that the benefits paid decreased by R3 billion in the current year, mainly due to a decrease in resignations from the Fund.

“Looking back at the achievements of the last 20 years, the GEPF will continue to ensure the financial security and strive for superior levels of service for its pensioners and members. It will be a catalyst for change in terms of securing investment opportunities locally, regionally, and globally to meet its pension liabilities, concludes Sithole.

Issued by Government Employees Pension Fund 
For information contact:
Thulisile Mbuli, Communications
T: +27 (0) 12 424 7329 E: Thulisile.mbuli@gepf.co.za

NOTICE TO GEPF MEMBERS, BENEFICIARIES AND SPOUSES

TO: 
(i) ALL CURRENT MEMBERS;
(ii) BENEFICIARIES AND SPOUSES WHO BECAME ENTITLED TO BENEFITS SINCE 1 APRIL 2015; AND
(iii) FORMER MEMBERS WHO RESIGNED SINCE 1 APRIL 2015

NOVEMBER 2016

1. In August 2016, the Public Servants Association (“PSA”) applied to the North Gauteng High Court in Pretoria for an order directing the Government Employees Pension Fund (“GEPF”) to give written notice of the PSA’s court application to all current members, former members who resigned since 1 April 2015, beneficiaries and spouses who became entitled to benefits since 1 April 2015 (hereinafter “stakeholders”).

2. The GEPF did not oppose the order that it give written notice of the PSA’s application to the aforementioned stakeholders. This order was granted on 13 September 2016

3. The PSA also launched an application for the review and setting aside of the decision of the board of the GEPF, taken in terms of the rules of the GEPF, to amend the actuarial factors used to determine certain benefits payable by the GEPF. The basis for the PSA’s review application is that the GEPF’s board did not consult it before making its decision.

4. The GEPF is opposing the PSA’s review application and has to that end filed and served a notice of intention to oppose.

5. The purpose of this notice is simply to inform GEPF stakeholders of the existence of the PSA’s review application and also to inform any stakeholder that the PSA’s review papers will be available at the GEPF’s offices below upon request.

6. A copy of the PSA’s notice of motion setting out the relief the PSA says it will seek in the review application is attached to this notice.

Yours sincerely

Abel Sithole

Principal Executive Officer

R10.5 billion financing injected towards affordable housing for government employees

R10.5 billion financing injected towards affordable housing for government employees and qualifying members of the publicPRETORIA -The Government Employees Pension Fund (GEPF) through its investment manager Public Investment Corporation (PIC) has announced an investment commitment of R10.5 billion into SA Home Loans (SAHL) to facilitate housing financing for qualifying government employees and members of the public.

The investment aims to provide government employees and qualifying members of the public with end-user home finance and development finance for approved affordable housing projects.

The investment comprise of the following:
• R 5 billion for public service employees;
• R 2 billion for affordable housing end user financing as defined in terms of the Financial Sector Code;
• R 2 billion to enable SAHL to extend home loans to the rest of qualifying home loan applicants; and
• R 1.5 billion will be used to fund affordable housing developers.
The investment in SAHL is part of the developmental investment mandate that the PIC is carrying out on behalf of the GEPF. Specifically, this investment addresses the social infrastructure element which has housing as one of the key components.
Dr. Claudia Manning, Member of the PIC Board said: “The PIC is intentionally implementing a developmental investment mandate, which primarily seeks to achieve two types of returns, namely: financial and social returns. Financial return means that PIC must generate profit for clients and social return means our investments should positively affect the social conditions of the stakeholders. Our view is that members of the GEPF should benefit during their active working years and during retirement – and this is a social return. Investing in affordable housing finance schemes such as this, provides these members with a real benefit.”

Lack of access to housing has been identified by the National Development Plan (NDP) as one of the challenges facing South Africa. In its diagnostic report, the NDP notes that: “the growth of property value has led to an overall average house price that has made housing unaffordable to many South Africans, and has further excluded participation in the property market by historically excluded groups. The growth has largely benefitted middle and higher income groups.”

Abel Sithole, Principal Executive Officer of the GEPF, said: “We believe there are many GEPF members who often do not qualify for bank-issued housing loans and housing subsidies offered by the government. We are, therefore, excited about this investment as
it will enable many government employees to own their own houses at a much more affordable rate. Most importantly, we believe home ownership can restore people’s dignity”

The Government Employees Housing Scheme (GEHS), an agency of the Department of Public Services and Administration, will assist government employees to access funding from SAHL.

Mashwahle Diphofa, Director General of the Department of Public Service and Administration, DPSA said: “The DPSA welcomes the participation of the GEPF through the PIC in the Government Employees Housing Scheme. The GEHS housing finance access service seeks to secure and deliver affordable and enabling housing finance for government employees. It is even more pleasing to see the PIC stepping forward as the first investor and participant in the GEHS housing finance service to bring this much needed value-added service to government employees.”Interface systems between GEHS and SAHL have already been developed and are operational. Government employees may also approach SAHL directly to apply for home loans.

Kevin Penwarden, Chief Executive Officer of SAHL, said: “We are excited about this partnership. More than anything, this investment is an expression of confidence in our service offering. We believe we have the necessary capacity and skills to deliver excellent home financing services to clients that will be coming through the GEHS platform, as we have consistently done with all our clients.”

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