AUTHENTICATED PAYMENTS REPORT - PYMNTS.com
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April 2021 Feature Story
AUTHENTICATED
FIS on tapping delegated authentication
to tackle SCA requirements
page 7
PAYMENTS News and Trends
Experts expect biometrics to be used to verify more than
REPORT 18 billion transactions this year
page 10
Deep Dive
How delegated authentication can help merchants better
handle SCA compliance and avoid undue customer friction
page 14
ID
2 ID Authenticated Payments Report
TABLE OF
CONTENTS
WHAT’S INSIDE
page 3
A look at how fraudsters wage payments fraud and the ways that
robust payments authentication solutions can catch them in the act
and protect merchants’ bottom lines
FEATURE STORY
page 7
An interview with Nicole Jass, senior vice president of product at FIS,
on how delegated authentication can give merchants more control
over SCA compliance and why many are turning to biometrics
NEWS AND TRENDS
page 10
The latest headlines from the payments authentication world, in-
cluding how biometrics will be used to verify more than 18 billion
transactions this year and why 46 percent of U.K. customers have
abandoned transactions that require multifactor authentication
DEEP DIVE
page 14
An in-depth examination of how merchants are leveraging delegated
authentication to comply with the EU’s strong customer authentica-
tion requirements
ABOUT
page 17 Acknowledgment
Information on PYMNTS.com and LoginID The Authenticated Payments Report was
done in collaboration with LoginID, and
PYMNTS is grateful for the company’s
support and insight. PYMNTS.com retains
full editorial control over the following
findings, methodology and data analysis.
© 2021 PYMNTS.com All Rights Reserved
W h at ’s In s i d e 3
WHAT’S INSIDE
F
raud is an ever-present specter ever, which often leads fraudsters to simply pick
in the payments world, with mer- the most vulnerable targets for their schemes.
chants, banks, payment providers and This has prompted some oversight authori-
consumers all at risk of bad actors ties to enact more stringent security protocols,
pilfering their money and data. This illicit ac- with the European Union implementing strong
tivity comes in many forms and is on the rise, customer authentication (SCA) requirements
as reports of credit card fraud increased from under the revised Payment Services Directive
17,236 instances in Q1 2015 to 45,120 in Q1 2020. (PSD2) to ensure that all merchants are on the
Payments fraud in general has also skyrocketed same page.
and is expected to spike from $9.8 billion in
Merchants, banks and other payments players
losses in 2011 to $40.6 billion by 2027.
must still choose flexible, scalable and seamless
Fraudsters go to extreme lengths to keep their authentication methods for their customers
activities concealed while perpetrating their regardless of the challenges they face when
schemes, and they often steal identities or in- fighting fraud. Solutions that offer robust se-
vent new ones to execute their schemes. They curity without compromising smooth checkout
still risk detection when they make payments, experiences can benefit their operations, but
however, and this gives fraud-fighting teams a adding too many undue frictions could ulti-
prime opportunity to counter them, notably by mately cost them sales and customer goodwill.
using payments authentication.
Around the world of authenticated payments
The authentication process can take many
The EU’s SCA requirements are already having
forms, ranging from simple password entry to
an effect on the European payments industry,
more advanced biometric systems that leverage
and biometrics in particular are experiencing a
facial recognition scans or analyze the subtleties
surge in popularity. Experts predict that biomet-
of users’ typing habits. These authentication
rics will be used to verify more than 18 billion
methods can vary greatly in their efficacy, how-
transactions this year, representing more than
© 2021 PYMNTS.com All Rights Reserved
4 W h at ’s In s i d e
$210 billion. Customers appear to be largely providers must do more to comply with these
pleased with the greater implementation of such new requirements without offering friction-lad-
methods, as 76 percent say they would like to en experiences that drive off customers.
see stricter security measures like biometrics
Some of the new measures accepted under
when it comes to payments authentication.
SCA are proving highly effective at preventing
Emerging authentication requirements have not fraud. Biometrics, for example, could be the
been without their hiccups, however. Recent key to stopping up to $43 billion in identity
research reveals that 46 percent of customers fraud losses by forcing fraudsters to undergo
in the United Kingdom are at least “somewhat” exceedingly difficult tasks like spoofing facial
likely to give up on transactions that require recognition or fingerprint scans to impersonate
multifactor authentication (MFA), for example, customers online. No form of fraud prevention
due to frustration with the checkout experi- is perfect, however, and some forms of identity
ence, including weak phone signals at checkout fraud could still be a factor, as $13 billion in loss-
stands. Other European markets have witnessed es were attributed to such schemes last year.
abandonment rates of more than 25 percent for
For more on these stories and other authen-
such transactions, whereas single-digit percent-
ticated payments developments, read the
ages were measured before SCA was enforced.
Report’s News and Trends section (p. 10).
This means that merchants and their payment
© 2021 PYMNTS.com All Rights Reserved
5
EXECUTIVE
W h at ’s In s i d e
INSIGHT
How delegated authentication can help Global losses from payment fraud have
merchants meet PSD2’s SCA requirements skyrocketed from $9.8 billion in 2011 to $32.4
billion in 2020. What techniques are fraudsters
Payments fraud is a massive concern for commonly leveraging today, and how can delegated
merchants, and this fact has driven the EU authentication help?
to institute SCA mandates as part of PSD2. “Common fraudster attacks include account take-
These authentication requirements can cause overs, which are typical in the online banking space.
even more trouble for merchants, however, Other forms of fraud [include] SIM swap attacks,
as customers are sometimes faced with wherein fraudsters can deceive mobile operator
authentication frictions that drive them to agents or retail staff into sending them replacement
SIMs for the target customers’ accounts. With these
abandon their purchases. In this month’s
new SIMs, customers lose control of their mobile
Feature Story (p. 7), Nicole Jass, senior vice
phones, allowing hackers to illegally access bank
president of product at FIS, details how accounts, crypto accounts and so on.
delegated authentication can help merchants
Another insidious variation of the SIM swap at-
thread the needle between authentication and
tack is when hackers take over messaging while
convenience.
target customers still have access to their phone
Deep Dive: How putting SCA in merchants’ numbers, allowing the hackers to receive all SMS
hands can streamline authentication messages going forward.
Identity fraud is a persistent problem for With the use of FIDO for delegated authentication,
merchants, and substandard authentication merchants will be using the de facto industry stan-
protocols can dramatically exacerbate the issue. dard for strong authentication, allowing them to:
Government officials in the EU have enacted • Incorporate hardware-based biometric authen-
SCA to combat bad actors, requiring custom- tication, requiring activities or/transactions to be
ers making purchases above a certain amount authenticated with biometrics, like [customers’]
to provide two of three factors to successfully fingerprints — this could be for payments, ac-
complete their payments. Many businesses are count changes or acceptance of offers.
finding it difficult to meet these new standards, • Simplify the user experience by having a seamless
though leaning on new technologies and pro- experience controlled by the merchant that is not
cesses can help. This month’s Deep Dive (p. 14) out of band or insecure — i.e. SMS verification
explores how delegated authentication — which — or relies on banking verification with varying
user experiences.
puts the SCA onus on merchants instead of
issuers and acquirers — is enabling European • Provide increased trust, given the market migra-
merchants to navigate new requirements more tion to the use of biometrics for authentication.”
smoothly.
Simon Law
Co-founder and CEO
LoginID
© 2021 PYMNTS.com All Rights Reserved
6 W h IDa t ’ s IAnus ti d
heenticated Payments Report
BIOMETRICS
Biometrics are growing
more popular as a means
of payments authentication
under SCA.
PSD2 CONTROL
Customers are becoming Consumers desire more
frustrated with checkout control over how their
frictions associated with payments are authenticated
some of the authentication and secured.
requirements created by
PSD2.
FRAUD PASSWORDS
Biometrics could prove Knowledge-based
instrumental in preventing authentication is beginning
up to $43 billion in fraud to fall out of favor among
losses. major corporations.
© 2021 PYMNTS.com All Rights Reserved
Fe at u re S t o r y 7
FEATURE STORY
FIS ON TAPPING DELEGATED
AUTHENTICATION TO
TACKLE SCA REQUIREMENTS
© 2021 PYMNTS.com All Rights Reserved
8 Fe at u re S t o r y
The deadline for compliance with PSD2’s SCA SCA’s ups and downs
mandate passed earlier this year, starting a new SCA is meant to combat the dizzying array of
era for payments authentication in Europe. All schemes used for payments fraud, many of
electronic payments — with the exception of which entail bad actors exploiting unforeseen
certain low-value transactions — now require authentication system weaknesses to pose
MFA via the use of passwords, text-based codes as legitimate users. Fraudsters can even be
or biometrics, and merchants and payment inadvertently grandfathered into new payment
providers are still working to grasp the full scope systems if they have managed to bypass se-
of this new standard. curity measures before such systems are put
These new authentication measures are intend- in place, Jass said.
ed to counter evolving fraud threats, but they “One of the biggest problems we ran into was
have introduced a layer of complication into that fraudsters would actually go and enroll the
everyday electronic payments. Balancing SCA stolen credit card in [our payments authenti-
requirements with seamless customer expe- cation system],” she explained. “Fast-forward
riences has been a battle for businesses of all three or four years, where we have moved to
sizes, as friction-induced customer abandon- automatic cardholder enrollment and risk-
ment could counteract any potential benefits based monitoring, [and] we still see examples
from mitigating fraud losses. where the fraudster is able to take advantage
“Customer friction with authentication is one of customer authentication tools through social
of the biggest complaints that we hear from engineering, [Internet Protocol address] spoofing
merchants, banks and cardholders about SCA,” and other account takeover tactics.”
Nicole Jass, senior vice president of product A blanket MFA requirement such as SCA is de-
at FIS, said in a recent interview with PYMNTS. signed to make each user play by the same
“Anytime you introduce any level of friction in rules without allowing fraudsters to sneak by
the checkout flow, there is concern around on exceptions, but these one-size-fits-all reg-
customer abandonment.” ulations can come at a high price: customer
SCA’s implementation may be well-intentioned, convenience.
but merchants and payments providers have “The rules and regulations set forth by PSD2
struggled to see the mandate’s value. Many have are complex and require constant diligence to
been turning to delegated authentication to help ensure full SCA compliance is met,” Jass said.
them seamlessly and securely handle this new “Merchants are trying to control the checkout
requirement without frustrating customers. experience as best they can in an effort reduce
cardholder abandonment.”
© 2021 PYMNTS.com All Rights Reserved
Fe at u re S t o r y 9
SCA regulations do permit merchants to
take advantage of delegated authentication
methods to control their checkout experiences
and reduce customer friction. Many retailers
that decide to take SCA compliance into their
own hands are quickly shifting from leverag-
ing traditional MFA methods like passwords
to incorporating more seamless options like
biometrics.
Delegated authentication strikes a balance
Delegated authentication allows merchants
to tackle user authentication rather than
rely on their payment providers’ verification
methods. This enables them to better tailor their
authentication methods to their customers’
preferences, keeping friction to a minimum. Jass “If issuing banks start to see an increase in
said biometric options are a particular favorite fraud associated with delegated authentica-
for merchants. tion transactions, they can easily opt out of
the delegated authentication program, which
“Delegated authentication can be a great solu-
will reduce merchants’ opportunities to offer
tion for [clients] looking to create that seamless
superior authentication experiences,” she ex-
approach to authentication,” she said. “With our
plained. “Issuers who are subjected to higher
authentication tools, we are helping our clients
rates of fraud can be subject to penalties and
facilitate delegated authentication through the
fines by the national PSD2 regulators and even
various mobile wallets, which then allows the
risk losing their banking licenses if the proper
merchant to take advantage of the biometrics
steps are not taken to ensure fraud is kept
that are available via the mobile wallet.”
under control.”
Delegated authentication’s continued success
It is therefore incumbent on merchants to make
does require some buy-in from issuing banks,
certain that their delegated authentication pro-
Jass said. Too much fraud could result in banks
grams keep fraud in check. Failure to do so
suspending their delegated authentication ser-
could see them relinquish their authentication
vices, sending merchants back to square one
control to issuers, which could ultimately cost
when it comes to reducing customer friction.
them customers.
© 2021 PYMNTS.com All Rights Reserved
10 N e w s & Tr e n d s
NEWS AND TRENDS
PAYMENTS AUTHENTICATION are also likely to value biometric systems’ en-
hanced security capabilities, as 76 percent in a
UNDER PSD2 global survey said they would like to see stricter
Biometrics growing more popular as a means security measures for payments.
of payment authentication under SCA
Customers express frustration with PSD2
The European payments industry marked regulations
a milestone earlier this year as PSD2’s SCA
Recent research shows that some consum-
regulation went into effect and banned
ers are not yet completely MFA, despite its
merchants and card issuers from taking risk-based
recent growth in the payments space. One
approaches to card-not-present (CNP) trans-
customer sentiment survey found that MFA
actions. This means that payment providers
challenges were frustrating enough to prompt
are now legally required to offer MFA for these
46 percent of U.K. customers to give up on
transactions. Such measures typically hinge
transactions that required it, for example. Other
on verifying factors that meet two out of three
European markets have experienced abandon-
criteria: knowledge, possession and inherence.
ment rates of more than 25 percent for such
A payment could satisfy the SCA mandate by
transactions, a steep rise from the single-
requiring a knowledge-based password and a
digit percentages measured before SCA was
text message-based code in the customer’s
enforced.
possession, for example.
Experts have recommended several moves that
The third category, inherence, is largely fulfilled
merchants and payments processors can make
by biometrics, which have become far more
to improve customer experiences and reduce
common in the payments authentication space
churn, however. The most prominent example is
in recent years. Experts predict that biometrics
a system called transaction risk analysis (TRA),
will be used to verify more than 18 billion trans-
which can grant businesses exemptions from
actions this year, representing a total payments
SCA regulations if they meet certain criteria.
value of more than $210 billion. Consumers
© 2021 PYMNTS.com All Rights ReservedN e w s & Tr e n d s 11
Companies with fraud rates that are 0.01 percent saying such measures will be used to verify
or lower can be exempt from SCA regulations the vast majority of payments within the next
for purchases of €500 ($590 USD) or less, for decade. Biometric measures are predicted to
example, with slightly higher fraud rates allowing ultimately supplant password and username
exceptions for progressively smaller ticket sizes. combinations, which are often leaked in data
Communication between merchants and banks breaches and exploited by fraudsters before
is also key for smooth customer experiences, customers are aware that their data has been
as redundant authentication checks can lead compromised.
to slow and frustrating checkout processes.
Customers are almost unanimous in desiring
more payment authentication control
PAYMENTS AUTHENTICATION
Customers’ growing appreciation for biometrics
TRENDS AMONG CUSTOMERS is part of a larger shift toward greater control
Customers grow more receptive to biometrics over banking and payments authentication, ac-
to secure transactions, study finds cording to recent data. A PYMNTS study found
The pandemic has dramatically shifted how that 97 percent of customers want more control
consumers complete their daily transactions, over their mobile banking apps’ authentication
helping popularize contactless payments and processes but that just 42 percent of customers
other digital methods Businesses have been can currently choose which transactions they
rolling out innovations that cater to this trend, wish to authenticate. Only 37 percent have a
and a recent survey found that 61 percent choice regarding which authentication process
of company executives altered their digital they wish to use when verifying payments.
transaction processes over the past year. The
The study found that customers widely associ-
pandemic has also driven payments fraud, how-
ate authentication control with greater security,
ever, with providers scrambling to secure their
and 49 percent of respondents said that au-
transactions and protect themselves and their
customers. Some consumers were previously
skeptical of biometric methods’ data security,
but the danger of fraud has caused many to
change their opinions, with 55 percent of busi-
nesses stating that customers trust them more
with their data than they did two years ago.
Executives project biometrics to become the
dominant payment authentication method
within the next several years, with 85 percent
© 2021 PYMNTS.com All Rights Reserved12 N e w s & Tr e n d s
BUSINESSES IMPROVE
PAYMENTS VERIFICATION
Passwords are falling out of vogue for payments
security
thentication control gave them peace of mind. Numerous organizations have begun to ac-
Customers favored biometric options when knowledge that passwords alone offer
allowed to choose their authentication methods, inadequate security and are thus reducing their
as 80 percent of facial recognition users and dependence on them. Experts predict that
77 percent of fingerprint scan users said these more than 60 percent of large corporations will
methods were satisfactory and easy to use. halve their reliance on passwords by 2022, and
86 percent of security executives say that they
Biometrics could halt $43 billion in fraud losses would ditch passwords entirely if allowed to do
One of the most widespread types of fraud in so. Data also suggests that users are growing
the payments space is identity fraud, in which frustrated with passwords due to their security
bad actors either steal customers’ identities or vulnerabilities as well as the friction they create.
create new ones to make fraudulent purchases. The average online user manages approximate-
Identity fraud losses totaled $56 billion last ly 120 accounts, and 65 percent report being
year, with digital identity scams resulting in $43 irritated by lockouts that stem from mixing up
billion in losses and traditional identity fraud passwords or entering them incorrectly.
accounting for the remaining $13 billion. Recent
Authentication methods such as biometrics or
research shows that biometrics could be the key
alphanumeric codes texted to users are begin-
to tackling digital ID fraud, however, as fraud-
ning to supplant passwords, however, as both of
sters would need to spoof a facial recognition
these newer methods are difficult for fraudsters
or fingerprint scan to impersonate customers
to fake and do not rely on users’ memories.
online — an exceedingly difficult undertaking.
Experts do not expect passwords to disappear
This could help guard the many consumers who
anytime soon, though, with 85 percent of IT
are transacting from home and using the web to
professionals saying that passwords will likely
access critical funding, such as unemployment
stick around in some capacity despite their
benefits and stimulus payments.
security risks and potential inconvenience due
simply to inertia and reluctance to embrace
new systems.
© 2021 PYMNTS.com All Rights ReservedN e w s & Tr e n d s 13
More than half of businesses say eCommerce Payments authentication provider LoginID
cybersecurity is a key short-term goal raises $6 million in seed funding round
Businesses are undertaking initiatives to im- Passwordless payment authentication solu-
prove their cybersecurity as eCommerce tions are on the rise in the cybersecurity space,
becomes the dominant retail channel. A and many providers are working with inves-
recent survey of retailers and eCommerce tors to develop and improve their technologies.
merchants found that 57 percent of respon- Payment authentication provider LoginID, for
dents considered cybersecurity improvements example, recently announced that it raised $6
as one of their top three short-term business million in seed funding from various sources,
goals, with 48 percent saying they are plan- including Fabrice Grinda from FJ Labs, Will Wang
ning digital risk management efforts and 41 Graylin from OV Loop, Indigo Technologies and
percent saying that these efforts were already ROAM Data. This news comes after the company
underway. One example of these initiatives is announced that it had been Universal Authen-
network segmentation, which involves retailers tication Framework-certified by Fast Identity
keeping financial data and personally identifiable Online (FIDO), a conglomerate of technology
information (PII) isolated from the rest of the firms looking to eliminate passwords altogether.
network so data theft attempts can be more
LoginID plans to leverage the funding to
easily stopped.
accelerate its biometric payment authentica-
These moves toward cybersecurity come as tion solutions using application programming
businesses acknowledge the massive threat interfaces (APIs) and software development kits
that payments fraud poses to the retail indus- (SDKs). Its technology is accessible on iOS- and
try. Thirty-four percent of respondents cited Android-capable devices, and its co-founder
cybersecurity concerns as their top eCommerce and CEO Simon Law said in a recent PYMNTS
challenge, for example, beating disruption by interview that passwordless authentication can
industry rivals, poor customer experiences and boost conversion rates by reducing customer
automation challenges. friction.
© 2021 PYMNTS.com All Rights Reserved14 Deep Dive
DEEP DIVE
HOW MERCHANTS CAN regulation’s standards is easier said than done,
however, and businesses must confront several
NAVIGATE THE INS AND OUTS obstacles to ensure that they are in compliance.
OF SCA COMPLIANCE
The following Deep Dive explores the fraud
Customer authentication has become
threats that led to the institution of SCA, the
critical as more and more of the world’s
measures necessary to satisfy its requirements
economy moves online, with digital banking,
and the challenges businesses must meet to
eCommerce and other web-based transactions
ensure compliance.
forming an ever-larger share of the global money
flow. The United States Census Bureau found How fraud forced the EU’s hand
that eCommerce, for example, had risen to 16
Untenable increases in payment fraud over the
percent of total retail sales in Q2 2020, up from
past decade have led to SCA’s implementation,
just 0.6 percent in 1999. This share is expected
with global fraud losses more than tripling
to grow further, and each digital transaction
from $9.8 billion in 2011 to $32.4 billion last
must be authenticated and secured lest fraud-
year. Many of these fraud instances occur when
sters swindle merchants and customers out of
bad actors steal customers’ identities or invent
their money and data.
fake ones, with the latter practice — synthetic
Securing these transactions using customer identity fraud — being notoriously difficult to
verification and authentication is a high pri- catch because no victim can report a stolen
ority for governments working to protect their identity. These issues appear to be pervasive,
citizens and economies from fraudsters. One too, as more than half of all Europeans are
such example is the European Union’s SCA re- concerned about their identities or personal
quirement, which went into effect this year data being stolen or misused by cybercriminals.
and aims to ensure that merchants, payment Twenty-four percent fear that their bank account
providers and other entities are utilizing robust or payment card details will be hijacked.
customer authentication measures. Meeting the
© 2021 PYMNTS.com All Rights ReservedDeep Dive 15
The risk of identity fraud has grown more pro-
nounced over the past year due to the pandemic
as well as surges in online and CNP transactions
as consumers shop from home more frequently.
PYMNTS’ research revealed that more than 72
percent of consumers now use credit cards
when they shop online, but this activity can also
open them up to various fraud types, including
identity theft or phishing. Experts predict that
payment fraud losses could hit $40.6 billion
by 2027, for example, a 25 percent increase
over 2020.
This well-founded fear of fraud has forced the
EU to step up its authentication standards for
merchants, FIs and other payments companies.
Some businesses are finding these new mea-
sures particularly difficult to meet, however.
How merchants can respond to SCA’s game-
changing nature
SCA requires most merchants, card issuers,
banks and other players in the financial and
retail spaces to require two-factor authenti-
cation for purchases over a certain amount.
Transactions of less than €30 ($35.19 USD)
are typically exempt, but authentication can
be required for low-value transactions if a
customer makes five or more that exceed a
total value of €150 ($175.94 USD) within a short
time frame. This authentication can involve two
of the following: a code sent to a customer’s
smartphone, a password or a biometric check
like a fingerprint.
© 2021 PYMNTS.com All Rights Reserved16 Deep Dive
This new authentication requirement may be point-of-purchase operations and potentially
effective in reducing fraud rates, but not all boost sales.
verification tools are created equal. Biometrics
Delegated authentication can also confer other
can be fast and seamless, but many compa-
benefits on merchants and issuers, as kicking
nies are largely relying on either passwords
verification to the latter often adds an extra
or text codes due to their banks’ or payment
step into the checkout process for customers,
providers’ limitations, which can both result
creating friction that could result in cart aban-
in friction-filled customer experiences. A cus-
donment. Keeping SCA responsibilities in-house
tomer might have a weak cellphone signal at
prevents merchants from routing customers to
the checkout counter, for instance, or an online
issuers’ domains, giving retailers more control
purchase might require a physical card reader
over the experience and sparing issuers from
that a customer does not have handy.
taking on the task.
Encouraging more widespread adoption
SCA is here to stay in Europe despite the
of seamless authentication methods like
challenges it brings for retailers, eCommerce
biometrics could be accomplished using
marketplaces and other merchants. Delegated
delegated authentication, a facet of SCA that
authentication could offer one way for mer-
allows merchants to take customer verifica-
chants as well as their issuers and acquirers to
tion into their own hands rather than relying
mitigate these obstacles and even thrive within
on their banks’ existing protocols. This means
the new authentication paradigm.
that merchants can not only independently
explore verification options like biometrics but
also organically fold these options into their
© 2021 PYMNTS.com All Rights Reserved17
ABOUT
PYMNTS.com is where the best minds and the best content meet on
the web to learn about “What’s Next” in payments and commerce. Our
interactive platform is reinventing the way in which companies in pay-
ments share relevant information about the initiatives that shape the
future of this dynamic sector and make news. Our data and analytics
team includes economists, data scientists and industry analysts who
work with companies to measure and quantify the innovation that is at
the cutting edge of this new world.
LoginID aims to be the global leader in protecting user identity, providing
ID
users secure control over personal information. LoginID’s FIDO2-certified
one-touch biometric authentication solution gives businesses a secure
authentication tool that can be easily and quickly integrated through an
API or SDK onto any website or mobile application. With low operating
costs and rapid integration, LoginID empowers businesses with the tools
needed to efficiently scale their platforms.
We are interested in your feedback
on this report. If you have questions
or comments, or if you would like to
subscribe to this report, please email
us at feedback@pymnts.com.
© 2021 PYMNTS.com All Rights Reserved18
DISCLAIMER
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