A. Introductory remarks and approval of the agenda

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1 CONTACT GROUP ON EURO PAYMENTS STRATEGY (COGEPS) ECB-PUBLIC 23 December 2013 SUMMARY OF THE 29TH MEETING OF THE CONTACT GROUP ON EURO PAYMENTS STRATEGY (COGEPS) held on Wednesday, 16 October 2013, from 9.30 a.m. to 6 p.m. at Sheraton Brussels Airport Hotel, Galaxy meeting room, Brussels International Airport A. Introductory remarks and approval of the agenda The Chair, Javier Santamaría (EPC Chair and Banco Santander), welcomed the participants to the meeting. The agenda item Cyber-security and payments was postponed to the meeting of March 2014 so that the results of ongoing work in the central bank community could be taken into consideration. As for the order of discussion, it was agreed that item 2 New SCT and SDD developments would be addressed in the afternoon. The Chair then asked the members to approve the agenda, which they did. B. Retail payments issues 1. Monitoring of SEPA migration For discussion Introduction: ECB The Eurosystem will present the traffic lights indicators. Members are invited to discuss the state of play of SEPA migration and the actions necessary to address issues of concern. ECB Presentation SEPA Migration Report state of play Wiebe Ruttenberg (ECB) presented the status of migration to SCT and SDD and the preparedness of PSPs, big billers, public administrations and SMEs. Migration to SCT at euro area level had steadily progressed to 52.8% in August 2013, although five countries were lagging far behind (Germany, Estonia, Ireland, Italy and Malta). Whereas the latest assessment of the preparedness of PSPs, big billers and public administrations was either successfully completed or expected to be ready in time, SMEs in

2 some countries (Germany, Estonia, Spain and France) would not be ready in time unless they greatly intensified their preparations. Migration to SDD was mostly still at single digit levels, with just four countries (Belgium, Greece, Austria and Slovenia) having reached higher levels. With the exception of Estonia, the assessment of the preparedness of PSPs was either successfully completed or expected to be ready in time. Big billers and public administrations in Germany and SMEs in five countries (Germany, Ireland, Spain, France and Luxembourg) would not be ready in time unless they greatly intensified their preparations. As before, late migration or even a big bang was a serious operational risk. End-users were responsible for their preparations and non-compliant payment orders would not be allowed after 1 February Communication and cooperation among stakeholders should be further strengthened; good examples were the clarity given by the European Commission and the ECB on conversion services, the guidance given by German authorities on the continued usability of the current e- mandate practice and the letter of the EPC on electronic mandate solutions under the SDD Rulebooks. Jean-Yves Jacquelin (Erste Bank and Chair of EPC SEPA Payment Schemes WG) commented that, while banks had been assessed positively, they might not be ready to reply to the thousands of questions they could receive from corporate clients in January. Thomas Kraft (BNP Paribas) added that test slots were no longer available to corporate clients who had not already contacted their bank. In addition to operational risk, he pointed to liquidity risk as a problem area for unprepared corporate clients. Dirk Schrade (Deutsche Bundesbank) saw no signs of mass SCT migration in Germany, although preparations had been made. The Bundesbank had indicated that it would organise a press conference on 24 October to stress the need for the banking sector to prepare for SCT migration and to reiterate that there was no Plan B. Hans Brits (De Nederlandsche Bank) reported that, in the Netherlands, SCT migration was gathering speed but in the case of SDD migration much was still to be done. Wiebe Ruttenberg asked whether the SDD D-1 option had led to positive effects in Spain and Germany. Javier Santamaria (EPC Chair and Banco Santander) replied that, although D-1 had become available in October, big billers were keeping to their original plans of migrating in November, December or even January. Dirk Schrade replied that D-1 would become available in November and big billers were now informing their customers that migration would take place in November or December. The Chair stressed that banks needed to give the same message to their corporate clients, i.e. that much hard work lay ahead and that there was no Plan B. Philippe Pellé (EC) referred to the Council conclusions on SEPA of May 2013 and asked whether the EPC could facilitate coordinated communication between banks in order to maximise the flow of information to payment service users. The EPC confirmed that it would maintain the level of its communication activities. 2. New SCT and SDD developments For information Introduction: EPC COGEPS will be informed about new developments in SCT and SDD, especially those relating to electronic mandates, the SDD fixed amount scheme, the stakeholder workshop on IBAN-only (24 Page 2 of 13

3 September 2013) and the geographic scope of the schemes. EPC presentation New SCT and SDD developments Jean-Yves Jacquelin (Erste Bank and Chair of EPC SEPA Payment Schemes WG) presented four issues related to the SCT and SDD schemes. The IBAN-only workshop discussed the principles by which solution providers will be able to offer accurate tables to derive the BIC from the IBAN. The aim is to have this available by 2016 at the latest. When asked why the data provision for BIC-IBAN derivation could not become part of the Rulebooks, he answered that the Rulebooks might not be the correct place for these matters on account of enforceability issues. For a possible SDD Fixed Amount Rulebook, the EPC had waited for the discussions at the SEPA Council meeting in September. At that meeting it was felt that an SDD scheme without a right of refund might be justified for certain goods and services. Patrick Poncelet (FBE) and Gijs Boudewijn (Netherlands Bankers' Association and Chair of EPC Legal Support Group) suggested that PSD2 (Article 67) should be adapted so that there was always a right of refund, except when otherwise agreed at national level or in a framework contract. Javier Santamaria (EPC Chair and Banco Santander) pointed out that an unconditional right of refund creates the wrong perception, because the exercise of the right would have consequences, for example, due to the resulting non- or late payment. Ugo Bechis (UBI Banca and Chair of EPC Cards WG) urged the inclusion of the payment of investment fund and insurance company premiums in the list of services. Wiebe Ruttenberg (ECB) announced that a meeting would be held in November to propose a well-defined list of goods and services. An e-mandates survey showed that several services were operational but that differences between countries as regards the validity of mandates or signatures existed. In practice, cross-border direct debits, when signed electronically, are likely to face legal uncertainty. In the end, it is the debtor bank that decides on the validity of the mandate according to the legal environment of the debtor bank s country. Finally, Jean-Yves Jacquelin announced a new deadline (31 December 2014) for suggestions/changes for the 2016 Rulebooks change-management cycle. 3. SEPA governance/future of COGEPS For discussion Introduction: ECB The ECB will present the envisaged main elements of the successor to the SEPA Council, the Euro Retail Payments Board. On the basis of these main elements, as well as other developments such as the EPC s role for innovative retail payments, members are invited to have a first exchange of views on the future of COGEPS as a discussion platform for the Eurosystem and the European payments industry. Page 3 of 13

4 ECB Presentation The future of COGEPS questions for a first exchange of views Pierre Petit (ECB) referred to the draft Statute of the Euro Retail Payments Board (ERPB) as presented to the SEPA Council in September and, in particular, highlighted its mandate to identify strategic issues and work priorities which it is to address, inter alia, by setting-up ERPB working groups. The impact of these changes on COGEPS, as regards topics, types of participant and participants, was for discussion at the meeting. Javier Santamaria (EPC Chair and Banco Santander) found that COGEPS had been helpful for both sides but agreed that there was a need to start a debate on how to adapt COGEPS. Patrick Poncelet (FBE) pointed to the existence of various other groups covering cash and large value payments and retail payments, with the risk of duplicating the ERPB; the European Commission also had various groups on retail payments, such as the PSMEG. Marieke van Berkel (EACB) saw the ERPB and COGEPS as having different roles and different participants. It was proposed that, in future, COGEPS could perhaps meet less often but include the banking supervision aspect. Roger Jones (TARGET Working Group) agreed with a focus on retail payments and even expected that there would be few large-value payments issues that would have a bearing on retail payments. Ugo Bechis (UBI Banca and Chair of EPC Cards WG) mentioned the need to prepare the meetings of the SEPA Council/future ERPB better, including by involving other bodies and that the EPC would need to reflect on its future role. Gijs Boudewijn (Netherlands Bankers' Association and Chair of EPC Legal Support Group) shared the experience in the Netherlands: following the set-up of an ERPB-like payments forum, all central bank and payments industry dialogues were abandoned, only for the parties to discover later the need to continue such direct and open dialogue. Gilbert Lichter (Euro Banking Association) spoke in favour of a regular dialogue, with COGEPS as the sole body for a pan-european discussion between ECB/Eurosystem/EC and banks; it was considered that a widening of the types of participants was probably needed but that it would make the selection of individual participants more difficult. Gilbert Ernst (Banque et Caisse d Épargne de l État) called for a lean SEPA structure and a re-assessment of the various discussion fora. Among the Eurosystem participants, Dirk Schrade (Deutsche Bundesbank) was in favour of focusing on retail payments, excluding cash, and avoiding duplications. He said that dialogue with the supply side was important but that it should not be perceived as preparation for the ERPB meetings. Alexandre Stervinou (Banque de France) spoke in favour of a focus on retail but saw the ERPB as the crucial body to establish mandates for other groups. Paola Giucca (Banca d'italia) expressed a desire to reconcile the need to reduce redundancy with a wish to keep a dialogue; the discussion on the set-up of the ERPB should take this into account. Philippe Pellé (EC) acknowledged the demand for streamlining the various groups, including those of the European Commission, and said the EC would address the issue after the start of the ERPB. He supported the idea that, if there was a continued dialogue with the supply side, it should indeed cover the entire supply side. Page 4 of 13

5 The Chair concluded that the future of COGEPS was part of the discussion on SEPA governance but that there was some support for maintaining a regular dialogue with a focus on electronic retail payments between the Eurosystem and the supply-side of the payments industry. 4. Legal proposals in the area of retail payments For discussion Introduction: Commission COGEPS will be informed about the Commission s proposals on the revised Payment Services Directive (PSD2), the Interchange Fee Regulation, the Directive on Bank Accounts and other (upcoming) legislative proposals. Members are invited to discuss the impact of these proposals on the European (retail) payments landscape. - Philippe Pellé (EC) provided the latest information on the process for the revised Payment Services Directive and the Regulation on Interchange fees for card-based payment transactions, which the European Parliament had decided to address simultaneously. Its plan was to decide on amendments in the ECON committee on 20 February and vote in the Plenary in April. However, to meet the Parliament s schedule, and to achieve adoption in the first reading in this session of the Parliament, it would be necessary for the Council to take a position in February. As the Council had not made such plans and was busy with other dossiers, it seemed more likely that adoption would be by the end of Card schemes and card processing separation and the SEPA Cards Processing Framework For information Introduction: EPC The 6th SEPA Progress Report called for the separation of card schemes from card processing and for the development of a SEPA Cards Processing Framework and/or a technical interoperability framework between processors. The Eurosystem took positive note that the Cards Stakeholders Group s Processing Task Force had started working on principles addressing explicit or implicit hurdles to a more integrated and competitive card processing market. EPC Presentation SEPA Cards Processing Schemes and Processing Separation Ugo Bechis (UBI Banca and Chair of EPC Cards WG) presented the work as started earlier this year by a Task Force of the Cards Stakeholders Group (CSG). He stated that the scope was to define principles or business requirements for card transaction processing in SEPA that could be laid down in a framework. He stressed that these principles would have a strong relationship with the requirement of a separation of Page 5 of 13

6 the card scheme and processing, which is included in the EPC s SEPA Cards Framework. Moreover, the Task Force would define standardisation requirements, which could become part of the CSG Volume. Philippe Pellé (EC) asked when the framework would be implemented. Ugo Bechis responded that the TF work was expected to be spelled out at CSG Volume level in Cards standardisation - functional and security requirements For discussion Introduction: EPC Members are invited to discuss, from a strategic perspective, two topics related to cards standardisation: First, COGEPS will be informed about the results of the public consultation on the SEPA Cards Standardisation Volume Book of requirements (v7.0) and the plans to release a stable version for market implementation in Second, the Eurosystem will present its latest views on cards functional standardisation. Members are invited to discuss the main issues hampering further harmonisation and migration to pan-european implementation specifications. EPC Presentation The SEPA Cards Standardisation Volume Public Consultations and next steps Ugo Bechis presented the results of the public consultation on the Volume, which has been divided into Books to allow for easier maintenance. He highlighted that the consultation had been successful in terms of the high number of comments (2,002) from 44 organisations representing different types of stakeholders. Most comments were related to the definitions (Book 1), functional requirements (Book 2) and implementation guidelines (Book 6). Once approved by the CSG (7 November), as endorsed by all five sectors of the CSG, and formally adopted by the EPC Plenary (12 December), it would be published. However, for the functional and security requirements for remote card payments (e.g. internet payments and m-payments), the work was not yet stable and would continue in Upon a question as to what was meant by labelling, he explained that it was the process of qualifying the conformance of implementation specifications with the functional requirements in the Volume, in other words, how a standardisation initiative would check whether the technical description it developed met the standardisation requirements included in the Volume. On the basis of a set of labelled implementation specifications, a manufacturer of payment terminals or cards would develop and produce new terminals or cards that should be able to pass successfully the Volume-conformant functional testing and certification processes, as well as functional type approval by the card schemes. The present Volume foresees labelling on the basis of self-assessments; it was under discussion whether labelling should be certified by a third party, as was the case for implementation specifications for the security requirements in the Volume. Page 6 of 13

7 7. E-commerce payments For discussion Introduction: ECB The Eurosystem will present its views on market developments in e-commerce payments. New payment solutions, often by new types of providers, seek to address the specific requirements of the e-commerce environment. In addition, payment integrators provide a comprehensive service to web merchants. Compared with traditional bricks-and-mortar commerce, the relationship between bank and merchant seems to be different in e-commerce. Members are invited to provide their views. ECB Presentation E-commerce payments Iddo de Jong (ECB) presented the results of a recent Eurosystem analysis on developments in e- commerce payments, against the background of the growth of e-commerce and possible payment-related blocking factors in general or specific obstacles to cross-border transactions. One key finding was the recognition of three layers: traditional payment instruments as offered by scheme owners and PSPs, payment solutions offered by PSPs and other providers, and the set of payment options offered by online payment integrators. He suggested that the Eurosystem would change its focus towards the level of payment solutions, as well as that of online payment integrators, which were the main providers to web merchants. In the discussion, several participants pointed to successful solutions for e-commerce payments, such as those used by Amazon and app-stores and as offered by PayPal or locally. It was generally considered that payments were not the biggest problem for (cross-border) e-commerce, rather the difficulties in the phases before and after the payment, e.g. returns of goods, subsequent payment returns and how to contact the customer. Others saw payments as a significant problem for e-commerce and traditional payment instruments as unsuitable because of fraud or a potential customer s perception of security issues. Banks were the main providers of such payment instruments and were trusted for taking deposits, but faced the possibility of being used as the basic infrastructure for the value-added services of other providers. Some participants underlined the need for multi-stakeholder, cooperative standardisation efforts for e-commerce payment solutions offered by PSPs and other providers, given that there were thousands of providers of payment accounts. Various participants saw e-commerce payments as a topic for the ERPB or a dedicated forum meeting, given that web-merchants and consumers, as well as the specialised providers, were not represented at the meeting. It was agreed that the topic should be proposed for the ERPB s list of work priorities. Page 7 of 13

8 8. European Forum on the security of retail payments (SecuRe Pay) For information Introduction: ECB COGEPS will be informed about the upcoming publication of the Final Recommendations for the security of payment account access services and on the upcoming public consultation on the Draft Recommendations for the security of mobile payments, as well as about the other work streams. Moreover, COGEPS will be informed on the process for implementation and enforcement of the Final Recommendations for the security of internet payments (1 February 2015) and the role of overseers, national banking supervision authorities and the European Banking Authority therein. - Pierre Petit (ECB) announced that the public consultation on the Draft Recommendations for the security of mobile payments was about to be launched. Moreover, the Final Recommendations for the security of internet payments were being implemented by the individual prudential supervisors and overseers and would be enforced as of 1 February 2015 on the basis of comply or explain. On the Recommendations for the security of payment account access services, which were being finalised after the public consultation earlier this year, he stressed that SecuRe Pay addressed the security aspects only and was not responsible for other considerations with regard to the provision of the service or for the development of the legal framework. However, it was noted that the legislative proposal for the revised PSD contained a mandate for a European Banking Authority Guideline which, if based on the recommendations, would support enforcement. Ugo Bechis (UBI Banca and Chair of EPC Cards W G) called for more attention to the question of how, in the online environment, the legal location of the payer, payee and providers was determined, as this affected the rules applicable to the payment, the security requirements, as well as policing. Patrick Poncelet (FBE) noted that, contrary to earlier statements, the draft PSD2 did not contain specific provisions for the security of payment account access services. He asked how the results of the public consultation on the Recommendations for payment account access services would be made available. Philippe Pellé (EC) provided a detailed explanation as to how legitimate security concerns have been addressed in the proposed PSD2 and mentioned that the European data protection authorities had taken a positive view of the restriction of data access in the draft PSD2, which went further than for the general data protection safeguards. Pierre Petit answered that the final report would be accompanied, as before, by an outcome note. Page 8 of 13

9 C. Cash related issues 9. Experiences with the new banknote series For information Introduction: ECB COGEPS will be informed about the experiences following the launch of the EUR 5 note as the first denomination of the new banknote series. - (ECB presentation will not be circulated) Armin Greif (ECB) gave a precise report on the launch of the new 5 banknote on 2 May 2013 and the lessons learnt. A survey held in July 2013 showed that the general public was well aware of the new series and that most had already come across the new 5 note. The survey pointed to a saturation rate of 38% for August, above the level forecast for that month, indicating that the pace of replacement is progressing faster than planned and suggesting that, by the end of December 2013, it is likely to be higher than the year-end forecast of 68%. The main lesson learnt is the non-acceptance of the new 5 banknote by various machines and the negative media coverage that followed. For the launch of the new 10 note, known stakeholders will be contacted, information will be given on the need to adapt machines accepting banknotes for payments, and the availability of testing facilities will be improved. The launch of the new 10 banknote will be after the summer of Leonor Machado (Caixa Geral de Depositos and Chair of EPC Cash WG) highlighted some concerns about the launch of the new 5 note, such as a lack of information and limited testing facilities, which had already been shared with the ECB. Javier Santamaria (EPC Chair and Banco Santander) asked about the improved durability of the individual banknotes versus the shorter horizon for the whole series. Armin Greif confirmed that due to technological advances, the life-cycle of new banknotes series was expected to be shorter. 10. Report from the EPC Cash Working Group For information Introduction: EPC COGEPS will be informed about the latest developments at the level of the CWG. EPC presentation Report from the EPC Cash Working Group Leonor Machado (Caixa Geral de Depositos and Chair of EPC Cash WG) discussed the public consultation organised by the EPC on the document Improving the efficiency of the handling of cash Cash cycle models, which was the outcome of joint work with ESTA; a final version will be ready for Page 9 of 13

10 approval at the upcoming EPC Plenary meeting. She went on to describe some of the EPC s other activities, including its participation in an ATM/IBNS joint project entitled Best Practices for ATM replenishment and its contribution to a common detection principle for the ink used to stain banknotes. She noted that these two projects were on the agenda of the Interoperability in the cash cycle team, comprising the ATMIA, the EPC, ESTA and EURICPA. Thomas Kraft (BNP Paribas) referred to a German study on the costs of cash, which showed that these were EUR 14 billion in Germany, compared with EUR 1.4 billion for cards. He wondered whether this would not be a topic for the new ERPB. Dirk Schrade (Deutsche Bundesbank) pointed out that the particular study was sponsored by MasterCard. Wiebe Ruttenberg (ECB) argued that, for cash, the issues to address were more logistical and therefore more local by nature, but that the ERPB would nevertheless address the social costs of payments, including cash. Hans Brits (De Nederlandsche Bank) supported the need to include cash aspects in the discussion on euro retail payments. D. Large-value payments issues 11. Update on ongoing TARGET2 work For information Introduction: ECB COGEPS will be informed about the adaptation to T2S and the implementation of ISO ECB Presentation Update on TARGET2 developments Patrick Papsdorf (ECB) presented an update on TARGET2 developments; comments from Roger Jones (Chairman of the TARGET Working Group) had already been included. Preparations on the TARGET2- side for the start of TARGET2-Securities (T2S) were progressing well. Inter alia, two challenges were still being addressed: legal aspects regarding the finality of T2S-related payment instructions and the use of tokens for accessing the T2S GUI in order to meet IT-security requirements. The migration of TARGET2 to ISO planned for November 2017 is on schedule, with the General Functional Specifications to be delivered by the so-called 3CB by end-october The presentation concluded with a mention of the successful phase-out of the Proprietary Home Accounts of the Deutsche Bundesbank last month. 12. Report from the TARGET Working Group For information Introduction: TWG COGEPS will be informed about the latest developments at the level of the TWG. - Page 10 of 13

11 Roger Jones (Chairman of the TARGET Working Group) reported on several developments affecting the large value payments operations and liquidity management of banks. He said that it was a pity that the option to use TARGET2 s ICM module also for some T2S-related interactions was no longer supported. He pointed out that the Basel Committee on Banking Supervision had a natural interest in cash, as the lack thereof was the main reason why a bank went bankrupt. The Committee had developed the Liquidity Coverage Ratio (LCR) to address requirements in this domain. However, it was deepening the applicability to intraday positions, which had a great impact on multi-country banks, not least because of different accounting practices around the world and time zone issues. There could also be complications stemming from collateral being used to raise liquidity. For the euro area, the TWG was investigating, in conjunction with the ECB, whether TARGET2 statements and or its CRSS database could be of assistance. E. Any other business Francisco Tur Hartmann (ECB) provided an update on the collection of payment and other statistics. He pointed out that it was now foreseen to adopt an ECB Regulation on statistics. In addition, various guidelines would deal with the more practical issues. The review would include the current ECB Guideline on monetary, financial institutions and markets statistics (ECB/2007/9). The Regulation would be directly applicable to the reporting agents. It would apply as of June 2015 with the reporting over the second half year of In response to a question on whether the location of the payer was included, he replied that statistics other than those based on the location of the PSP were deemed in the merits and cost procedure that had been followed as too costly to collect. When asked about the purpose of national statistics vis-à-vis the SEPA developments, he answered that national breakdowns were still desirable in order to assess payment behaviour and developments at country-level. Next meeting(s) of COGEPS (to be confirmed closer to the actual meeting dates): 11 March 2014 in Frankfurt With no other business brought forward, the Chair closed the meeting and thanked the participants. Page 11 of 13

12 List of participants COGEPS, 16 October 2013 Chair EPC Chair and Banco Santander Co-Chair European Central Bank SANTAMARIA, Javier PETIT, Pierre Banking Industry Banque et Caisse d Épargne de l État/State and Savings Bank Luxembourg BNP Paribas Caixa Geral de Depositos and Chair of EPC Cash WG DNB and Chair of EPC M-Channel WG EPC Secretary General Erste Bank and Chair of EPC SEPA Payment Schemes WG Euro Banking Association European Association of Co-operative Banks (EACB) European Banking Federation (FBE) FBF Netherlands Bankers' Association and Chair of EPC Legal Support Group OP-Pohjola Group Rabobank Nederland EPC Vice Chair and Raiffeisen Zentralbank Österreich TARGET Working Group The Bank Association of Slovenia UBI Banca and Chair of EPC Cards WG ERNST, Gilbert KRAFT, Thomas MACHADO, Leonor FLATRAAKER, Dag-Inge GOOSSE, Etienne JACQUELIN, Jean-Yves LICHTER, Gilbert VAN BERKEL, Marieke PONCELET, Patrick RAGUENES, Jérôme BOUDEWIJN, Gijs SNELLMAN, Jussi BUSSEMAKER, Ineke GALL, Günther JONES, Roger PIRNAT, Matevž BECHIS, Ugo Eurosystem Nationale Bank van België/Banque Nationale de Belgique Deutsche Bundesbank Eesti Pank Central Bank of Ireland Bank of Greece Banco de España Banque de France Banca d'italia Central Bank of Cyprus De Nederlandsche Bank WATERKEYN, Axelle SCHRADE, Dirk OLT, Rainer O RIORDAN, David FOTOPOULOS, Panagiotis GORJON, Sergio STERVINOU, Alexandre GIUCCA, Paola NICOLAOU, George BRITS, Hans Page 12 of 13

13 Oesterreichische Nationalbank Banco de Portugal Banka Slovenije Národná banka Slovenska Suomen Pankki Finlands Bank European Central Bank European Central Bank (part of the meeting) European Central Bank (part of the meeting) European Central Bank Rapporteur COGEPS BURGER, Christiane EGREJAS FRANCISCO, Jorge ANKO, Simon HOLIČKA, Peter KEMPPAINEN, Kari RUTTENBERG, Wiebe GREIF, Armin PAPSDORF, Patrick TUR HARTMANN, Francisco DE JONG, Iddo Observers European Commission Magyar Nemzeti Bank Banca Naţională a României Sveriges Riksbank PELLÉ, Philippe BARTHA, Lajos VARTOLOMEI, Razvan EDHOLM, Sara Page 13 of 13