FIFTEENTH CONGRESS OF THE REPUBLIC)

OF THE PHILIPPINES )
First Regular Session ) . ;
cr
SEN,
sno 4890 7
Introduced by Senator Miriam Defensor Santiago j

EXPLANATORY NOTE

Every technological breakthrough changes the procedure in transacting business. The
payment of bills, whether it be for utilities, groceries, gasoline, medicine, or any other item,
can now be made through a credit card, automated teller machine card, or by telephone.

The use of electronic systems to transfer funds has provided substantial benefits to
consumers. However, due to the characteristics of such systems, the application of existing
consumer protection legislation is unclear. The rights and liabilities of consumers, financial
institutions, and intermediaries in electronic fund transfers are undefined.

‘This bill seeks to establish the rights, liabilities, and responsibilities of participants in

electronic fund transfer systems.'

it obhstadbatee

' This bill was originally filed during the Fourteenth Congress, First Regular session.

1


UbENne

was

21
22
23
24
25
26

FIFTEENTH CONGRESS OF THE REPUBLIC)
OF THE PHILIPPINES, )
First Regular Session )

SENATE
s.No._ 1

Introduced by Senator Miriam Defensor Santiago

AN ACT
DEFINING THE RIGHTS AND LIABILITIES OF PARTIES IN
ELECTRONIC FUND TRANSFERS

Be it enacted by the Senate and the House of Representatives of the Philippines in
Congress assembled:
SECTION 1. Short Title. - This Act shall be known as the “Electronic Fund Transfer

Act.”

SECTION 2. Declaration of Policy. - It is the policy of the State to promote commercial
transactions. Toward this end, the State shall enact measures to protect the rights and define the

liabilities of parties in commercial transactions.

SECTION 3. Definitions. -As used in this Act, the term

(A) “accepted card or other means of access” means a card code or other means of access
to a consumer's account for the purpose of initiating electronic fund transfers when the person, to
whom such card or other means of access was issued, has requested and received, or has signed
or has used, or authorized another to use, such card or other means of access for the purpose of
transferring money between accounts or obtaining money, property, labor, or services;

(B) “account” means a demand deposit, savings deposit, or other asset account (other
than an occasional or incidental credit balance in an open end credit plan), as described in
regulations of the Board, established primarily for personal, family, or household purposes, but
such term does not include an account held by a financial institution pursuant to a bona fide trust
agreement;

(©) “Board” means the Board of Governors of the Bangko Sentral ng Pilipinas;

1


10

il

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

(D) “business day” means any day on which the offices of the consumer’s financial
institution involved in an electronic fund transfer are open to the public for carrying on
substantially all ofits business functions;

() “consumer” means a natural person;

(B) “electronic fund transfer” means any transfer of funds, other than a transaction
originated’ by check, draft, or similar paper instrument, which is initiated through an clectronic
terminal, telephonic instrument, or computer or magnetic tape so as to order, instruct or authorize
a financial institution to debit or credit an account, Such term includes direct deposits or
withdrawals of funds, and transfers initiated by telephone.

Such term does not include-

(1) any cheek guarantee or authorization service which does not directly result in
a debit or credit to a consumer’s account;

(2) any transfer of funds, other than those processed by automated clearinghouses,
made by a financial institution on behalf of a consumer by means of a service that transfers funds
held at either banks or other depository institutions and which is not designed primarily to
transfer funds on behalf of a consumer;

(3) any transaction the primary purpose of which is the purchase or sale of
securities or commodities through a broker-dealer registered with or regulated by the Securities
and Exchange Commission;

(4) any automatic transfer from a savings account to a demand deposit account
pursuant to an agreement between a consumer and a financial institution for the purpose of
covering ari overdraft or maintaining an agreed upon minimum balance in the consumer's
demand deposit account; or

(5) any transfer of funds which is initiated by a telephone conversation between a
consumer and an officer or employee of a financial institution which is not pursuant to a pre-
arranged plan and under which periodic or recurring transfers are not contemplated;

(G) “electronic terminal” means an electronic device, other than a telephone operated by

a consumer, through which a consumer may initiate an electronic fund transfer. Such term


10
n
12
13
4
15
16
7
18
19
20
21
22
23
24

25

27
28

29

includes, but is not limited to, point-of-sale terminals, automated teller machines, and cash
dispensing machines;

(#) “financial institution” means a bank, a savings and oan association, a mutual savings
bank, a credit union, or any other person who, directly or indirectly, holds an account belonging
to a consumer;

(1D) “pre-authorized electronic fund transfer” means an electronic fund transfer authorized
in advance to recur at substantially regular intervals;

(J) “unauthorized electronic f b d transfer” means an electronic fund transfer from a
consumer’s account initiated by a person other than the consumer without actual authority to
initiate such transfer and from which the consumer receives no benefit, but the term does not
include any électronic fund transfer

(1) initiated by a person other than the consumer who was furnished with the card,
code, or other means of access to such consumer’s account by such consumer, unless the
consumer has notified the financial institution involved that transfers by such other person ax no
longer authorize;

(2) initiated with fraudulent intent by the consumer or any person acting in
conceit with the consumer; or

(3) which constitutes an error committed by a financial institution,

SECTION 4. Regulations. -
(A) The Board shall prescribe regulations to carry out the purposes of this Act. In
prescribing such regulations, the Board shall:

1) consult with the other affected agencies and take into account and allow for,
the continuing evolution of electronic banking services and the technology
utilized in such services.

2) prepare an analysis of economic impact which considers the costs and benefits
to financial institutions, consumers, and other users of electronic fund
transfers, including the extent to which additional documentation, reports,
records, or other paper work would be required, and the effects upon

. 3


10

ML

12

13

14

15

16

7

18

19

20

21

22

23

24

25

26

27

28

competition in the provision of electronic banking services among large and
small financial institutions and the availability of such services to different
classes of consumers, particularly low income consumers,

3) to the extent practicable, the Board shall demonstrate that the consumer
protections of the proposed regulations outweigh the compliance costs
imposed upon consumers and financial institutions; and

(a) any proposed regulations and accompanying analyses shall be
sent promptly to Congress by the Board.

(b) The Board shall issue model clauses for optional use by
financial institutions to facilitate compliance with the disclosure requirements of the
following section and to aid consumers in understanding the rights and
responsibilities of participants in electronic fund transfers by utilizing readily
understandable language. With respect to the disclosures required by Section 5, the
Board shall lake account of variations in the services and charges under different
electronic fund transfer systems and, as appropriate, shall issue alternative model
clauses for disclosure of these differing account terms.

(c) Regulations prescribed hereunder may contain such
classifications, differentiations, or other provisions, and may provide for such
adjustments and exceptions for any class of electronic fund transfers, as, in the
judgment of the Board, are necessary or proper to effectuate the purposes of this Act,
to prevent circumvention or evasion thereof, or to facilitate compliance therewith,
This Board shall by regulation modify the requirements imposed by this Act on small
financial institutions if the Board determines that such modifications are necessary to
alleviate any undue compliance burden on small financial ‘institutions and such
modifications are consistent with the purpose and objective of this subchapter.

(d) In the event that electronic fund transfer services are made
available to consumers by a person other than a financial institution holding a

consumer’s account, the Board shall by regulation assure that the disclosures,


20

21

22

23

24

25

26

27

28

protections, responsibilities, and remedies created by this Act are made applicable to

such persons and services.

SECTION 5. Terms and Conditions of Transfers. -

(A) The terms and conditions or electronic fund transfers involving a consumer's account
shall be disclosed at the time the consumer contracts for an electronic fund transfer service, in
accordance with regulations of the Board. Such disclosures shall be in readily understandable
language and shall include, to the extent applicable -

(1) the consumer’s liability for unauthorized electronic fund transfers and, at the
financial institution’s option, notice of the advisability of prompt reporting of any loss, theft, or
unauthorized use of a card, code, or other means of access;

(2) the telephone number and address of the person or office to he notified in the
event the consumer believes that an unauthorized electronic fund transfer has been or may be
effected;

(3) the type and nature of electronic fund transfers which the consumer may
initiate, including any limitations on the frequency or dollar amount of such transfers, except that
the details of such limitations need not be disclosed if their confidentiality is necessary to
maintain the security of an electronic fund transfer system, as determined by the Board;

(4) any charges for electronic €und transfers or for the right to make such
transfers;

(5) the consumer's right to stop payment of a preauthorized electronic fund

transfer and the procedure to initiate such a stop payment order;

(6) the consumer’s right to receive documentation of electronic fund transfers
under Section 6;

(7) a summary, in a form prescribed by regulations of the Board, of the error
resolution provisions of seotion 8 and the consumer’s rights thereunder. The financial institution
shall thereafter transmit such summary at least once per calendar year;

(8) the financial institution’s liability to the consumer under Section 10; and


10
in
12
13
4
15
16
17
18
19
20
21
22
23
24
25
26
27
28

29

(9) under what circumstances the financial institution will, in the ordinary course
of business, disclose information concerning the consumer’s account to third person.

(B) A financial institution shall notify a consumer in writing at least twenty-one (21) days
prior to the effective date of any change in any term or condition of the consumer’s account
required to be disclosed under subsection (1) of this section if such change would result in
greater cost or liability for such consumer or decreased access to the consumer’s account. A
financial institution may, however, implement a change in the terms or conditions of an account
without prior notice when such change is immediately necessary to maintain or restore the
security of an electronic fund transfer system or a consumer’s account. Subject to subsection (A)
(3) of this section, the Board shall require subsequent notification if such a change is made
permanent.

(C) For any account of a consumer made accessible to electronic fund transfers prior to
the dfective date of this Act, the information required to be disclosed to the consumer under
subsection (A) of this section shall be disclosed not later than the earlier of -

(1) the first periodic statement required by section 6 after the effective date of this
Act; or

(2) thirty (30) days after the effective date of this Act.

SECTION 6. Documentation of Transfers. -

(A) For each electronic fund transfer initiated by a consumer from an electronic terminal,
the financial institution holding such consumer’s account shall, directly or indirectly, at the time
the transfer is initiated, make available to the consumer written documentation of such transfer.
‘The documentation.shal! clearly set forth to the extent applicable -

(1) the amount involved and the date the transfer is initiated;

(2) the type of transfer;

(3) the identity of the consumer’s account with the financial institution from
which, or to which, funds are transferred;

(4) the identity of any third party to whom or from whom the funds are

transferred; and


v

10

it

12

13

14

is

16

7

18

19

20

21

22

23

24

25

26

27

28

29

(5) the location or identification of the electronic terminal involved.

(B) For a consumer’s account which is scheduled to be credited by a pre- authorized
electronic fund transfer from the same payor at least once in each successive sixty-day period,
except where the payor provides positive notice of the transfer to the consumer, the financial
institution shall elect to provide promptly either positive notice to the consumer when the credit
is made as’ scheduled, or negative notice to the consumer when the credit is not made as
scheduled, in accordance with regulations of the Board. The means of notice elected shall be
disclosed to the consumer in accordance with section 5 of this Act.

(C) A financial institution shall provide cach consumer with a periodic statement for each
account of such consumer that may be accessed by means of an electronic: fund transfer. Except
as provided in subsection (D) and (E) of this section, such statement shall be provided at least
monthly for each monthly or shorter cycle in which an electronic fund transfer affecting the
account has occurred, or every thee (3) months, whichever is more frequent. The statement,
which may include information regarding transactions other than electronic fund transfers, shall
clearly set forth -

(1) with regard to each electronic fund transfer during the period, the information
described in subsection (A) of this Section, which may be provided on an accompanying
document:

(2) the amount of any fee or charge assessed by the financial institution during the
period for electronic fund transfers or for account maintenance;

(3) the balances in the consumer's account at the beginning of the period and at
the close of the period; and

(4) the address and telephone number to be used by the financial institution for the
purpose of receiving any statement inquiry or notice of account error from the consiumer. Such
address and telephone number shall be preceded by the caption “Direct Inquiries to:” or other
similar language indicating that the address and number are to be used for such inquiries or
notices.

(D) In the case of a consumer’s passbook account which may not be accessed by
electronic fund transfers other than pre-authorized electronic fund transfers crediting the account,

7


10
in
12
13
14
1s
16
17
18
19
20
21
22
23
24
25
26
21
28
29

a financial institution may, in lieu of complying with the requirements of subsection (C) of this
section, upon presentation of the passbook, provide the consumer in writing with the amount and
date of each such transfer involving the account since the passbook was last presented.

(B) In the case of consumer’s account, other than a passbook account, which may not be
accessed by electronic fund transfers other than pre-authorized electronic fund transfers crediting
the account, the financial institution may provide a periodic statement on a quarterly basis which
otherwise complies with the requirements of subsection (C) of this Section.

(®) In any action involving a consumer, any documentation required by this section to be
given to the consumer which indicates that an electronic fund transfer was made to another
person shall he admissible as evidence of such transfer and shall constitute prima facie proof that

such transfer was made.

SECTION 7. Pre-authorized Transfers. -

(A) A preauthorized electronic fund transfer from a consumer's account may be
authorized by the consumer only in writing, and a copy of such authorization shall be provided to
the consumer when made. A consumer may stop payment of pre-authorized electronic fund
transfer by notifying the financial institution orally or in writing at any time up to three (3)
business days preceding the scheduled date of such transfer. The financial institution may require
written confirmation to be provided to it within fourteen (14) days of an oral notification if, when
the oral notification is made, the consumer advised of such requirement and the address to which
such confirmation should be sent.

(B) In the case of pre-authorized transfers from a consumer's account to the same person
which may vary in amount, the financial institution or designated payee shall, prior to each
transfer provide reasonable advance notice to the consumer, in accordance with regulations of

the Board, of the amount to be transferred and the scheduled date of the transfer.

SECTION 8. Error Resolution. -
(A) Ifa financial institution, within sixty (60) days after having transmitted to a consumer
documentation pursuant to this Act, receives oral or written notice in which the consumer

8


10
a
2
13
4
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29

(1) sets forth or otherwise enables the financial institution to identify the name
and account number of the consumer;

(2) indicates the consumer's belief that the documentation, or, in the case of
notification pursuant to Section 6, the consumer’s account, contains an error and the amount of
such error; and

(3) sets forth the reasons for the consumer’s belief (where applicable) that an error
has occurred, the financial institution shall investigate the alleged error, determine whether an
error has occurred, and report or mail the results of such investigation and determination to the
consumer within ten (10) business days. ‘The financial institution may require written
confirmation to be provided to it within ten (10) business days of an oral notification of error if,
when the oral notification is made, the consumer is advised of such requirement and the address
to which such confirmation should he sent. A financial institution which requires written
confirmation in accordance with the previous sentence need not provisionally re-credit a
consumer’s account in accordance with subsection (C) of this section, nor shall the financial
institution be liable under subsection (B) of this section if the written confirmation is not
received within the ten-day period referred to in the previous sentence.

(B) If the financial institution determines that an error did occur, it shall promptly, but in
no event more than one (1) business day after such determination, correct the error, object to
Section 9, including the crediting of interest where applicable.

(©) Ifa financial institution receives notice of an error in the manner and within the time
period specified in subsection (A) of this Section, it may, in lieu of the requirements of
subsections (A) and (B) of this Section, within ten (10) business days after receiving such notice
provisionally re-credit the consumer’s account for the amount alleged to be in error, subject to
Section 9, including interest where applicable, pending the conclusion of its investigation and its
determination of whether an error has occurred. Such investigation shall be concluded not later
than forty-five (45) days after receipt of notice of the error. During the pendency of the
investigation, the consumer shall have full use of the funds provisionally re-credited.

(D) If the financial institution determines after its investigation pursuant to 0 subsection
(A) or (C) of this section that an error did not occur, it shall deliver or mail to the consumer an

9


wv

20

21

22

23

24

25

26

27

28

29

explanation of its findings within three (3) business days after the conclusion of its investigation,
and upon the request of the consumer promptly deliver or mail to the consumer reproductions of
all documents which the financial institution relied on to conclude that such error did not occur.
‘The financial institution shall include notice of the right to request reproductions with the
explanation of its findings.

(&) If any action under this Act, the court finds that -

(1) the financial ‘institution did not provisionally re-oredit a consumer’s
account within the ten-day period specified in subsection (C) of this section, and the financial
institution (a) did not make a good faith investigation of the alleged error; or (b) did not have a
reasonable basis for believing that the consumer’s account was not in error; or

(2) the financial institution knowingly and willfully concluded that the
consumer’s account w as not in error when such conclusion could not reasonably have been
drawn from the evidence available to the financial institution at the time of its investigation, then
the consumer shall be entitled to treble damages.

(&) For the purpose of this section, an error consists of -

(1) an unauthorized electronic fund transfer;

(2) an incorrect electronic fund transfer from or to the consumer’s account;

(3) the omission from a periodic statement of an electronic fund transfer
affecting the consumer’s account which should have been included;

(4) a computational error by the financial institution;

(5) the consumer's receipt for an incorrect amount of money from an
electronic terminal;

(6) a consumer's request for additional information or clarification
concerning an electronic fund transfer or any documentation required by this Act; or

(7) any other error described in regulations of the Board.

SECTION 9. Consumer Liability.-

(A) A consumer shall he liable for any unauthorized electronic fund transfer involving
the account of such consumer only if the card or other means of access utilized for such transfer
was an accepted card or other means of access and if the issuer of such card, code, or other

. 10


10
u
2
13
4
15
16
17
18
19
20
21
2
23
24
25
26
27
28

29

means of access has provided a means whereby the user of such card, code, or other means of
access can be identified as the person authorized to use it, such as by signature, photograph or
fingerprint, or by electronic or mechanical confirmation. In lesser of-

(1) One Thousand Pesos (P 1,000.00); or

(2) The amount of money or value of property or services obtained in such
unauthorized electronic fund transfer prior to the time the financial institution is notified of or
otherwise becomes aware of, circumstances which lead to the reasonable belief that an
unauthorized electronic fund transfer involving the consumer’s account has been or may be
effected. Notice under this paragraph is sufficient when such steps have been taken as may be
reasonably required in the ordinary course of business to provide the financial institution with the
pertinent information, whether or not any particular officer, employee, or agent of the financial
institution does in fact receive such information. Notwithstanding the foregoing, reimbursement
need not be made to the consumer for losses the financial institution establishes would not have
‘occurred but for the failure of the consumer to report within sixty (60) days of transmittal of the
statement (or in extenuating circumstances such as extended travel or hospitalization, within a
reasonable time under the circumstances) any unauthorized electronic fund transfer or account
error which appears on the periodic statement provided to the occurred but for the failure of the
consumer to report any loss or theft of a card or other means of access within two (2) business
days after the consumer learns of the loss or theft (or in extenuating circumstances such as
extended, travel or hospitalization, within a longer period which is reasonable under the
circumstances), but the consumer’s liability under this subsection in any such case may not
exceed a total of Ten Thousand Pesos (10,000.00) or the amount of unauthorized electronic fund
transfers which occur following the close of two (2) business days (or such longer period) after
the consumer learns of the loss or theft but prior to notice to the financial institution under this
subsection, whichever is less.

(B) In any action which involves a consumer’s liability for an unauthorized electronic
fund transfer, the burden of proof is upon the financial institution to show that the electronic fund
transfer was unauthorized, then the burden of proof is upon the financial institution to establish
that the conditions of liability set forth in subsection (B) of this Section have been met, and, if

i


10
i
12
13
4
15
16
17
18
19
20
2
22
23
24
25
26
21
28

29

the transfer was initiated after the effective date of this Act, that the disclosures required to be
made to the consumer under Section 5 were in fact made in accordance with such section.

(C) In the event of a transaction which involves both an unauthorized electronic fund
transfer and an extension of oredit to an agreement between the consumer and the financial
institution to extend such credit to the consumer in the event the consumer’s account is
overdrawn, the limitation on the consumer’s liability for such transaction shall be determined
solely in accordance with this section.

(D) Nothing in this section imposes liability upon a consumer for an authorized electronic
fund transfer in excess of his liability for such a transfer under other applicable law or under any
agreement with the consumer’s financial institution

(©) Except as provided in this Section, a consumer incurs no liability from an

unauthorized electronic fund transfer.

SECTION 10. Liability of Financial Institutions -
(A) Subject to subsections (B) and (C) of this Section, a financial institution shall
be liable to a consumer for all damages proximately caused by -

(1) the financial institution’s failure to make an electronic fund transfer, in
accordance with the terms and conditions of an account, in the correct amount or
in a timely manner when properly instructed to do so by the consumer, except where -

(a) the consumer’s account has insufficient funds;

(b) the funds are subject to legal process or other encumbrance

(c) such transfer would exceed an established credit limit;

(@) an electronic terminal has insufficient cash to complete the
transaction; or

(e) as otherwise provided in regulations of the Board.

(2) the financial institution’s failure to make an electronic fund transfer due to
insufficient funds when the financial institution failed to credit, in accordance with the terms and.
conditions’ of an account, a deposit of funds to the consumer’s account which would have
provided sufficient funds to make the transfer.

12


10

i

12

13

14

is

16

7

18

19

20

21

22

23

24

25

26

27

(3) The financial institution’s failure to stop payment of a pre-authorized transfer
from a consumer's account when instructed to do so in accordance with the terms and conditions
of the account.

(B) A financial institution shall not be liable under subsection (B) (1) or (2) of this
Section if the financial institution shows by a preponderance of the evidence that its action or
failure to act resulted from -

(1) an act of God or other circumstance beyond its control, that it exercised
reasonable care to prevent such a31 occurrence, and that it exercised such diligence as the
circumstances required; or

(2) a technical malfunction which was known to the consumer at the time he
attempted to initiate an electronic fund transfer or, in the case of a preauthorized transfer, at the
time such transfer should have occurred.

(©) In the case of a failure described in subsection (A) of this Section which was not
intentional and which resulted from a bona fide error, notwithstanding the maintenance of
procedures reasonably adopted to avoid any such error, the financial institution shall be liable for

actual damages proved.

SECTION 11. Issuance of Cards or Other Means of Access. ~
(A) No person may issue to a consumer any card, code, or other means of access to such
consumer’s account for the purpose of initiating an electronic fund transfer other than -
(1) in response to a request or application therefore; or
(2) as renewal of, or in substitution for, an accepted card, code, or other means of
access, whether issued by the initial insurer or a successor.
(B) Notwithstanding the provisions of subsection (1) of this section, a person may
distribute to a consumer on an unsolicited basis a card, code, or other means of access for use in
initiating an electronic fund transfer from such consumer’s account, if -

(1) such card, code, or other means of access is not validated;

13


10

a

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

(2) such distribution is accompanied by a complete disclosure, in accordance with
Section 5, of the consumer's rights and liabilities which apply if such card, code, or other means
of access is validated;

(3) such distribution is accompanied by a clear explanation, in accordance with
regulations of the Board, that such card, code, or other means of access is not validated and how
the consumér may dispose of such code, card, or other means of access if validation is not
desired; and

(4) such card, code or other means of access is validated only in response to a
request or application from the consumer, upon verification of the consumer’s identity.

(C) For the purpose of subsection (B) of this Section, a card, code, or other means of

access is validated when it may be used to initiate an electronic fund transfer.

SECTION 12. Suspension of Obligations. - If a system malfunction prevents the
cfiectuation of an electronic fund transfer initiated by a consumer to another person, and such
other person has agreed to accept payment by such means, the consumer’s obligation to the other
person shall be suspended until the malfunction is corrected and the electronic fund transfer may
be completed, unless such other person has subsequently, by written request, demanded payment

by means other than an electronic fund transfer.

SECTION 13. Compulsory Use of Electronic Fund Transfers. - No person may -

(A) condition the extension of credit to a consumer on such consumer’s repayment by
means of pre-authorized electronic fund transfers; or require a consumer to establish an account
for receipt of electronic fund transfers with a particular financial institution as a condition of
employment or receipt of a government benefit.

SECTION 14. Waiver of Rights. - No writing or other agreement between a consumer
and any other person may contain any provision which constitutes a waiver of any right
conferred or cause of action created by this Act. Nothing in this section prohibits, however, any
writing or other agreement which grants to a consumer a more extensive right or remedy or

14


greater protection than contained in this subchapter or a waiver given in settlement of a dispute

or action.

SECTION 15. Separability Clause. - If any provision, or part hereof, is held invalid or
unconstitutional, the remainder o€ the law or the provision not otherwise affected shall remain

valid and subsisting accordingly.

SECTION ,161 Repeating Clause. - Any law, presidential decree or issuance, executive
order, letter of instruction, administrative order, rule or regulation contrary to or inconsistent

with, the provisions of this Act is hereby repealed, modified or amended

SECTION 17. Effectivity Clause. - This Act shall take effect fifteen (15) days after its
publication in at least two (2) newspapers of general circulation,

Approved,