Consumer complaint received 2018-11-23
Product: Checking or savings account — Other banking product or service
Issue: Managing an account — Banking errors
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION (HI)

Dear XXXX, COMPLAINT ISSUE I am a retired XXXX XXXX XXXX. The purpose of this complaint is to provide an update and additional complaints to my active CFPB complaint # XXXX filed on XX/XX/XXXX, against UNITED SERVICES AUTOMOBILE ASSOCIATION ( USAA ). The reason I am submitting this second complaint is because USAA knowingly and intentionally engaged in fraudulent and unethical business practices in response to my original referenced complaint in an attempt to stop it. I will conclude this complaint with my requested actions listed in the conclusion section. 

BACKGROUND Please refer to my original referenced complaint for the background details but let me to provide the following key points and recap of the original complaint here which will explain the specific claims of this new complaint of engaging in fraud to stop my original referenced complaint. 

USAA provides financial services to primarily military personnel and veterans. USAA in the past was considered to be a very prestigious company but new management came in and in recent years the company has significantly changed for the worse. Based on the way it is chartered, USAA is a member owned company. USAA is also a private company with no association with the XXXX XXXX. I have been a member of USAA for 39 years and as I said I am a retired XXXX XXXX. 

Since its inception, USAAs management focused on providing quality services to their members. When the current management came in that focus changed to expanding membership and promoting a social agenda. Then as customer service at USAA took a nose dive, USAA stopped being a member of the XXXX  and established a private social media forum on their website so they could keep the unending list of complaints from their military members internal within USAA and out of public view and oversight. Within that internal USAA Member Community Forum Members can make comments or ask questions of the USAA moderators who monitor the system 24/7. Members do not use their real names on the forum for privacy reasons, they establish nicknames when they set up their social media account and the USAA moderators can identify each member by their nickname. 

USAA then started to engage in some questionable business practices which included falsely presenting their private company to be a representative of the US military in order to make their profit, increase their membership, and to use the company to give the impression to the public that the military supports their left wing liberal social agenda ( one example of which is their continued sponsorship of the XXXX with the self-bestowed sponsorship title that begins with the three words : The Official Military .... 

Then when thousands of military members complained to USAA about sponsoring an organization that goes against the militarys core values and the very questionable business practice of USAA presenting itself as a representative of the US Military to obtain free advertising from the XXXX, make their profit, expand their membership to their targeted audience, and promote their social agenda ; USAA then responded to all of those military members complaints on the community forum by ignoring them and imposing extreme forms of censorship on their members by using a bumping policy that says members are not allowed to repeat a topic on the USAA member community forum.  And when members do say things that USAA does not like or when members attempt to use the forum to their advantage then the USAA moderators delete the members comments and threaten to disconnect the members from the community forum. 

Recently, when I saw a member complaining that their original complaint was left unresolved by USAA, I replied to the affected member with the contact info for the CFPB. After doing that about four times the USAA Administrator replied to me that if I replied to another member with the CFPB contact info that she would disconnect me from the USAA community forum. Other members came to my defense and thanked me for my assistance and they condemned USAA for their censorship. All of those details and specific posts in question can be viewed in my original referenced complaint. 

At that point I decided to file a complaint against USAA with the CFPB which listed their questionable business practices with a focus on their XXXX sponsorship practices and their censorship practices against military personnel. 

CURRENT COMPLAINT THAT USAA INTENTIONALLY AND KNOWINGLY ENGAGED IN FRAUDULENT ACTIVITY TO STOP MY ORIGINAL COMPLAINT TO THE CFPB. 

Allow me to begin my second complaint by saying I consider myself to be a relatively responsible person. I am a retired XXXX XXXX XXXX, I held our Governments highest security clearance for over 20 years continuously, I was a Distinguished Honor Graduate of the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX at XXXX XXXX, N.C. ( that is the XXXX XXXX XXXX XXXX XXXX ), I have been a member of USAA for 39 years, and on the USAA Member Community social media Forum I hold the most Likes Received of any other USAA member, that being XXXX Likes Received. 

Two of the many actions I requested in my original complaint was permission from USAA to be allowed to forward the contact info of the CFPB to other members when it was apparent that their complaint was left unresolved and the second request was to request permission to start reposting our XXXX Petition once again in accordance with USAAs own company By-Laws. 

I submitted my original complaint to the CFPB on XX/XX/XXXX and the CFPB confirmed receipt of it. On XX/XX/XXXX the CFPB confirmed they sent the complaint to USAA. On XX/XX/XXXX, the CFPB advised me that USAA had requested an additional 60 days to respond to the complaint. In a phone conversation with a CFPB rep she advised me it was actually 45 days that USAA had to respond. 

Shortly after USAA received my original CFPB complaint I started noticing a string of what we refer to as fake posts on the USAA community forum. These are posts believed to be created by the USAA Administrators of non-existent members with fictitious nicknames to give the impression it is a real military member making a comment on the forum and are posted on the forum by the moderators for different reasons but are not seen that frequently. It is easy to identify these fake posts because it is the first and only post by the fictitious member and it is generally saying something your typical military member would never say. Most members come on the USAA community forum primarily to make a complaint or to view the current complaints and support other members making a complaint. 

I noticed that many of these most recent fake posts were being placed in the strings of back and forth discussions I was having with other members and a number of these fake posts were very insulting, using words such as XXXX, incompetent, and questioning combat veterans XXXX status. 

It became apparent to me that a specific USAA Administrator by the name of XXXX XXXX was posting these fake posts in my discussions with the intent of provoking a response from me that USAA could then use to justify disconnecting me from the member community forum in response to my filing the CFPB complaint. It was apparent to me that this particular USAA Administrator was behind this effort because of knowing her censorship practices and style in the past on the forum and in one of the fake posts she actually replied to it as herself. 

The second very questionable practice on the part of USAA in this effort to create fraudulent accounts and target me was that in those fake accounts, the civilian USAA Administrator presented herself to be a military service member and a combat veteran. I would like to point out here that there is a federal statue which prohibits someone from falsely pretending to be military personnel. And the motive behind this fraudulent act was for a major corporation to stop a complaint which included the possibility of a violation of federal law. Please see the US Code below on this topic.

18 USC 912 - Military personnel or DOD employee of the United States Whoever falsely assumes or pretends to be military personnel or DOD/or employee acting under the authority of the United States or any department, agency or officer thereof, and acts as such, or in such pretended character demands or obtains any money, paper, document, or thing of value, shall be fined under this title or imprisoned not more than three years, or both. 

PROOF OF MY CLAIM I am very confident and will provide very strong evidence below that USAA Administrators ( specifically a USAA Administrator by the name of XXXX XXXX ) knowingly and intentionally engaged in this fraudulent and unethical activity. I will do so by listing each of the suspected fake posts below. Again, members do not use their real names on this community forum for privacy reasons, instead each member creates a nickname when he or she creates their forum account. USAA can then identify each member by their nickname. Each suspected fraudulent post in question below has a nickname which is suppose to be a real USAA member. At the conclusion of this complaint, I will ask USAA to confirm to the CFPB ( a federal agency with reach into law enforcement investigations ) and under penalty of perjury that the specific nicknames of the posts in question listed below are in fact real USAA members and are not USAA employees or family members of USAA employees. That confirmation request of USAA does not involve the disclosure of any privacy information on any individual, that request that I will make of USAA at the conclusion of this complaint simply requests a confirmation that those nicknames in question are authentic USAA members with the understanding that appropriate federal oversight authorities in the future may want to confirm that these are in fact real members who actually sent out the below posts in question. 

I will ask that specific request of USAA and I am very confident that USAA will not come back to me and the CFPB in this complaint and provide that specific confirmation because I am very confident that the posts listed below were created by USAA Administrators as fraudulent accounts, impersonating military service members in violation of US Code, and targeting my discussions with other members in response to my original referenced complaint with the ultimate goal of disconnecting me from the forum.

I felt this most recent fraudulent activity on the part of USAA started to cross the line into illegal activity and I felt it was important to prove the specific intent of this entire fraudulent scheme on the part of USAA, which was to disconnect me from the USAA community forum.

So I responded to one of their fake posts ( which is listed below ) with a factual response in which I even used the terminology in a recent legal opinion from a Federal Judge on the topic of censorship on social media forums, whos legal opinion stated : You can not shut someone up because you dont like what theyre saying. And after replying to that fake post with a factual response, later that day USAA permanently disconnected me from the USAA community forum. 

So to state the bottom line at this point, after 39 years of being a member of USAA, after having posted over 1,800 posts on the USAA community forum, and after having received XXXX Likes Received from my fellow military members ; within days after I submitted my original referenced complaint to the CFPB, USAA PERMANENTLY DISCONNECTED ME FROM THE USAA MEMBER COMMUNITY FORUM. And the significance of this second complaint is that USAA did so by intentionally using fraudulent and unethical business practices to disconnect me which included creating fraudulent member accounts, pretending to be real members then from those accounts posting insulting comments including the words XXXX, incompetent, and questioning military members XXXX status. This entire fraudulent activity was with the intent to stop my original complaint which identified not only a number of questionable business practices but the possibility of a violation of federal law on the part of USAA, which in my opinion can be construed as obstruction of justice of any possible and future law enforcement investigation that may be initiated by the CFPB. 

If USAA did not like my factual comment then all they had to do was edit it or delete it, which they do on a regular basis given the high degree of frustration that members have when communicating to USAA. One short example of this point is that when you go on the community forum and do a search of the one specific topic of USAA XXXX, there are 235 results.

So to prove the specific intent of this fraudulent scheme by USAA, I had to basically sacrifice myself on the community forum but this in no way stops any part of the requests listed in my original referenced complaint because there are other USAA members who will follow on with the actions and requests I listed in my original referenced complaint. I do not wish to list those members in this complaint because the very questionable employees at USAA will likely start targeting them just as USAA targeted me. I will be happy to provide those names of the other members to the CFPB by phone. The bottom line point here is that all of the requests in my original complaint remain active and applicable and will be acted on either by myself or fellow USAA members, depending on each specific requested action listed in my original CFPB complaint. There will also be new requests of USAA listed at the conclusion of this complaint. 

EXAMPLES OF THE FRAUDULENT POSTS CREATED BY USAA At this point I will reference below some of the suspected fraudulent posts that USAA likely created and placed in back and forth discussions I was having with other members to provoke a response from me that they could then use to justify disconnecting me from the community forum. Keep in mind the vast majority of the members who come on the USAA community forum do so to make a complaint against USAA or support others who are making a complaint against USAA. Please note in all of the fake posts below there are specific indicators that they are fake posts : 1 ) Those were the only posts ever created by these fictitious members as confirmed in their profiles. We never heard from them before that post and we never heard from them after that post.

2 ) They all say things that no military member would say to another military member who is simply stating a complaint to USAA. Certainly not based on my experience of being on this community forum.

3 ) Oddly enough as well, each one of the fake posts have trademark intentional misspellings.

FAKE POST 1 : ( NOTE : I was having a back and forth discussion with a real member by the nickname XXXX who was making a complaint to USAA on behalf of his adult children who were affected by Hurricane Michael. Then the USAA moderator posted the following insulting comment in that discussion using the fictitious nickname of XXXX XXXX XXXX : POST STRING BEGINS From : XXXX XXXX XXXX 2 weeks ago As is the case with most people that complain about service while millions of others have no issues it typically comes back to the individual not following instructions and being incompetent. Youeven in your own narrative do not define who " they '' is in receving the check. You also sound like a busy body complaining to USAA about your " kids '' while they can't even follow directions correctly. 

( NOTE : Then A_Dad replied to that very questionable post in which this senior member himself stated that post from XXXX XXXX XXXX was from a USAA employee. Below was A_Dads response to the fictitious post. ) : From : XXXX Friday Dear Keyboard Warrior ( AKAOccasional Contributor from Phoenix ), I'm not sure I understand your point of view, but let 's look at your response a little closer, becauseI am convinced that you are an employee of USAA expressing your true feelings about USAA customers expectations of quality service during a disaster, behind a shield of anonymity. This hostility is slowly becoming openly displayed when talking with the USAA Rep on the phone. My " Kids '' are far more willing to overlook rude behavior than I am. I take a little pleasure in confronting internet bullies, or those with the stones to do it. 

POST ENDS ( Note : Below are the three other posts from this XXXX XXXX XXXX on that one day and on that one day only. We never heard from this fictitious member before or after these few insulting posts on that one day. Lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this XXXX XXXX XXXX is a real USAA member and not a USAA employee or USAA employee family member. ) FAKE POST 2 From : XXXX XXXX XXXX a week ago Wow so you win the XXXX of the week award! You openly admit in a post that your husband is complict in insurance fraud. " The man had fallen off a 6 foot ladder at his home and used my husband to make medical calims and usaa paid them. '' You openly admit to knowing of insurance fraud occuring and do not notify USAA or law enforcement, which makes you complict. A mere {$50.00} montly increase makes your mortgage unaffordable ... ... maybe you shouldn't be a home owner. 

FAKE POST 3 From : XXXX XXXX XXXX a week ago Well maybe it's because this is USAA not XXXX and since you were approved anyway why don't you just chill out and be happy. 

FAKE POST 4 From : XXXX XXXX XXXX a week ago Seriously you are MAILING CHECKS in for deposit. You know this is XXXX and not XXXX right. Why don't you take a lookin the mirror and bring yourself up tothe current century! 

POSTS END __________________________ FAKE POST 5 On XXXX XX/XX/XXXX, the USAA Administrator very likely behind this entire scheme of creating fraudulent posts ( XXXX XXXX ) created a fake post with a one line comment then actually replied to it as herself ( XXXX XXXX, USAA Administrator ) with another one line comment to the fake post she had just created. What is of such intentional stoking with this fake post on the part of this particular Administrator is that this woman is notorious for imposing censorship on the military members on this forum and she has basically shut down all discussions on this so called member community forum with her USAA bumping paragraph that tells members they are not allowed to repeat a topic on the member community forum. Given this censorship background by this XXXX XXXX, she then likely creates the first post below ( saying how wonderful it is to have a discussion on the forum ) and then she responds as herself ( USAA Administrator ) saying how she looks forward to her wonderful discussions. Please see below the actual fake post from XXXX ( the fictitious account name ) and then responded to by XXXX XXXX as herself. 

FAKE POST 5 BEGINS ( Note : The first post is the fake post from the fictitious member ) Title : Thanks From : XXXX Saturday I will have to thank you for allowing me to join your lovely discussion ( Note : Then XXXX XXXX replied to the above fake post as herself. This post is clear evidence of XXXX XXXX direct involvement in this fraudulent scheme ). 

XXXX XXXX USAA Administrator yesterday HIi @ XXXX! 
We are so glad you are here! Looking forward to your posts! 

END OF FAKE POST 5 ( Note : What makes it so obvious that the above post is a fake post from this XXXX is that it was the only post ever posted from that fictitious member ( based on her profile ) and there was never any other discussion from her after saying how nice it was to join your lovely discussion. The two of them never said another word to each other. XXXX XXXX was simply trying to stoke a response from me by posting a comment of extreme hypocrisy in talking about having wonderful discussions while she has imposed such extreme forms of censorship on so many military members who were trying to simply speak the Truth about USAAs questionable business practices. Lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this XXXX is a real USAA member and not a USAA employee or family member of a USAA employee. 

FAKE POST 6 ( Note : The fake post below was from the fictitious account of XXXX and in this post the USAA employee who very likely created this fake post below, replied to a real military member who was making a complaint and who stated he was a XXXX veteran. The USAA employee who created this fake post with the fictitious nickname of XXXX replied to the real military member by questioning his XXXX status. NEVER, would a military service member disparage another military service member who stated he was a XXXX veteran. Only a very questionable USAA employee would create a fake post and then from that fake post insult a XXXX veteran. Lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this XXXX is a real USAA member and not a USAA employee or family member of a USAA employee. 

FAKE POST 6 BEGINS From : XXXX 2 weeks ago He forgot to mention his XXXX rating is probably a whopping 10 %. Everyone wants to be a war hero. If he worked fir me in the military I would send him to budget counseling so he could learn how to manage money instead of blaming others. Since the owners of USAa are the accoubt holders what he did was point fingers at real XXXX veterans, military retirees, and widows. He ought to be ashamed of himself. 

END OF POST ___________________________ FAKE POST 7 XXXX XX/XX/XXXX Title : " You kept our skies clear. '' From : XXXX XXXX Saturday I was talking to a USAA Lady in the US. I said I only served at a desk on XXXX. She said : " You kept our skies clear. You kept out seas clear, ''. I thought about it. And then I wept. No one had ever said what I had done was worthwhile. 

END OF POST __________________ Again, I have been viewing military members comments on this USAA community forum for a long time. This is in No Way you would ever see a comment like this from an actual USAA military member. There is no mention of any specifics such as the organization or the USAA Ladys name, and anyone who serves in the XXXX theater refers to the continental US as the mainland, not the US. Lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this XXXX   XXXX is a real USAA member and not a USAA employee or USAA employee family member. ) ________________________ SUSPECTED FAKE POST 8 ( Note : Below is a suspected fake post and if it is, this particular post is an example of a USAA employee who is falsely presenting herself to be a XXXX XXXX XXXX combat veteran. Again, it was the only post by this member. Let me add here that this post goes back to the US Code paragraph I referenced at the beginning of this complaint about people falsely presenting themselves as military service members. Lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this XXXX acct. is a real USAA member and not a USAA employee or USAA employee family member. ) Title : Let 's talk about finances and investments. 

From : XXXX 's acct. 
5 hours ago Hello to all the members of the USAA banking and services. I was wondering what things to invest and or start saving for the upcoming holidays? I would greatly apprciate it and thanks for your service to our country and I myself served 20 yrs, I am a XXXX XXXX   XXXX American Veteran. So it's great to share our knowledge as we are Band of Brothers and Sisters of Armed Forces. 

END OF SUSPECTED FAKE POST 8 ___________________________ Let me just state again that based on my experience of reading comments on the USAA community forum and running the USAA Member XXXX Petition which about 2,000 members responded to with comments, the above post is in no way  reflective of what a XXXX XXXX XXXX combat veteran would say if he took the time to come on the USAA community forum. Please read a sample of REAL POSTS just below from 10 REAL COMBAT VETERANS, the last of which is from a REAL 100 % RATED COMBAT VETERAN, and you get a much better understanding of what REAL COMBAT VETERANS say to USAA. 

TEN REAL POSTS FROM REAL COMBAT VETERANS TO USAA BEGINS : __________ XXXX  XXXX XX/XX/XXXX USAA, You see, like many who serve it stands for the ultimate sacrifice for as aCommander in XXXX, the flag was draped over seven of my Soldiers as they left XXXX in body bags. They arrived home to grieving family who universally were comforted by the honor of having our nations colors draped over their coffin. You bet, it's emotional and personal for me ... .as it is with most who serve. 
_________ XXXX XXXX XXXX XXXX  I fully support this petition. I will never forget those men in my platoon who died in XXXX, however, by its actions USAA has forgotten them. USAA 's moto " We know what it is like to serve '' is a joke on us who did serve. 
XXXX XXXX Contributor XXXX USAA 's continuing sponsorship of the XXXX put it on the side of those trampling the flag and spitting on the graves of the fallen. XXXX had a choice to end the defamation or stand by these XXXX XXXX. They chose dishonor over valor.I know what tratorism looks like. I hope USAA leadership has similar strong associations. XXXX XXXX __________ XXXX XXXX XXXX XXXX I've been a member of usaa for 13 years would hate to leave but after seeing this highly paid athletes disrespect our flag for what I fought for in XXXX and XXXX. Makes me upset. As my creed says " never will I embarrass my country ''. XXXX. Usaa reduce or cut sponsorship for __________ XXXX-XXXX  Occasional Contributor XXXX USAA .... please stop sponsorship with the XXXX immediately They're disrespecting those that have served, died and were seriously wounded serving our Great nation. This is the ultimate sign of disrespect. 
We in the military have served for these freedoms. But we also have the right to disagree with your message and not let our pocketbook endorse it. I can't allow my pocketbook to endorse an organization ( XXXX ) that allows the ultimate sign of disrespect to the DOD Fallen and wounded and people that have served. 
Please review immediately your sponsorship and let all members know what direction USAA will proceed with. I need to know if I need to end an approximately 20 year relationship with USAA and look for another Banking company that is more in line with my personal beliefs and Freedoms. 
_________ XXXX XXXX XXXX XXXX XXXX I respectfully request that USAA sever all ties with the XXXX XXXX XXXX. As a 22 year XXXX XXXX Vet with 6 combat tours I feel I can not support any company that supports the XXXX __________ XXXX  XXXX XXXX XXXX  As a XXXX, Purple Heart Veteran, I find it appalling that USAA continues to run adds during XXXX Games. YOU are supposed to support us patriots not the rich prima donnas that insult us. Get with it USAA before I transfer all my accounts else where. Semper Fi! 
XXXX XXXX XXXX XXXX XXXX  Stop supporting the XXXX and terminate immediately any financial relationship USAA has with the XXXX and its subsidiaries. 
__________ XXXX Lightgrunt Contributor XXXX Members of my family have served this country through every war from the Civil War to my service in Global War on Terrorism. Sponsoring the XXXX through these protest is a slap in the face to everyone who has sacrificed time with family blood sweat tears and their lives not to mention what the wives children parents sacrifice to continue to support the XXXX shows complete disrespect for what all of us have sacrificed for I know they have a right to their opinion but to disrespect what we have done is unacceptable to many of us who have missed births graduations and have shed our own blood for their rights no one knows better than we do I thought more of USAA than that I hope this will be rectified they do not deserve the support and you are not honoring us by continuing sponsorship __________ XXXX XXXX You are NOT honoring me, any other veteran, anyone XXXX XXXX or anyone who died in service to this country by sponsoring our enemies! And anyone so disrespectful of my country, my flag or my brothers in arms is my enemy! 
I am planning a return to the United States shortly, the decision to continue to support the XXXX is the final straw. 
I am XXXX XXXX XXXX XXXX, XXXX and XXXX  XXXX. ( Funny how getting parts shot and blown off your body can do that to you huh? ) I can not just jump on a plane and fly home to change banks. NO! I have to bring someone with me to help me with daily activities. You do understand XXXX right? 
This is going to be very arduous, painful and expensive. My anger will get me through it. It is certainly WORTH it to me! I lost a lot of friends in service to the US. EVERY ONE of them would do the same if they were alive today! 
So, go ahead, try to placate us with smooth sounding rhetoric and talking points. Tell us ALL about how much you like us. NOT going to change my mind! The only thing that will change my mind is you cut ALL ties, across the board, with the XXXX. NOW END OF REAL POSTS FROM REAL COMBAT VETERANS ___________________________ BACK TO FAKE POST 8 With that sample of ten Real Posts from Real Combat Veterans let us review one more time the very likely fraudulent post very likely from a USAA Administrator in which she creates a fraudulent account ( XXXX  acct. ) and falsely presents herself to be a Combat Veteran who is XXXX XXXX   XXXX, in violation of US Code 9 : Title : Let 's talk about finances and investments. 
From : XXXX 's acct. 
5 hours ago Hello to all the members of the USAA banking and services. I was wondering what things to invest and or start saving for the upcoming holidays? I would greatly apprciate it and thanks for your service to our country and I myself served 20 yrs, I am a XXXX XXXX   XXXX XXXX Veteran. So it's great to share our knowledge as we are Band of Brothers and Sisters of Armed Forces.

END OF SUSPECTED FAKE POST 8 ___________________________ Allow me to once again reference the US Code Statute on the topic of falsely pretending to be a military service member : 18 USC 912 - Military personnel or DOD employee of the United States Whoever falsely assumes or pretends to be military personnel or DOD/or employee acting under the authority of the United States or any department, agency or officer thereof, and acts as such, or in such pretended character demands or obtains any money, paper, document, or thing of value, shall be fined under this title or imprisoned not more than three years, or both. 

Again, lets just see if USAA comes back in their reply to the CFPB and confirms under penalty of perjury that this nickname of XXXX acct. is a real USAA member and not a USAA employee or USAA employee family member. ) XXXX SAMPLE OF USAA MEMBER COMPLAINTS ABOUT USAA CENSORSHIP ON THEIR MEMBERS Before I start my concluding comment and list the new actions requested of USAA in this second complaint, allow me to provide just a few member comments on USAA Censorship of its members from both the USAA Community Forum on their website and from USAAs XXXX page. 

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