OPEN DATA IS ESSENTIAL FOR SMALL BUSINESS RECOVERY - In the emerging new normal, approaches to underwriting small business credit need to be ...
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OPEN DATA IS ESSENTIAL FOR SMALL BUSINESS RECOVERY In the emerging new normal, approaches to underwriting small business credit need to be reimagined Chris Evans Nihal George
Open Data Is Essential For Small Business Recovery SYLVIA’S BUSINESS LOAN APPLICATION NIGHTMARE Sylvia is a 38 year old dentist operating her own practice in the inner Sydney suburb of Surry Hills. One afternoon, Sylvia is treating a patient when her dental chair malfunctions. The chair’s suspension comes to a grinding halt, the drill stops spinning and the suction stops flowing. The chair is dead. The Consumer Data Right (CDR) The Consumer Data Right (CDR) in Australia is designed to give consumers and small businesses control over how their data can be accessed and Sylvia is a 38 shared year old securely dentistdigital through operating her own practice in th channels. The legislation and its rules are more generally referred to as Open Banking orchair’s dental chair malfunctions. The Open suspension comes to a Data, versions of which have been legislated in the United Kingdom and the European Union, and promoted through policy in Singapore, India, Japan and South Korea among others. 1. AWARENESS Under time pressure, Sylvia spends hours the st trolling through the internet looking for t a lender, not knowing how to compare them CLOSED for urgent enquiries How Consumer Data Right can help please contact 1800-JOB KEEPER Real time comparison of accurate prices and features from publicly available product reference data st operating her own practice in the inner Sydney suburb of Surry Hills. One afternoon, Sylvia is treating a patient when her Personalised The chair’s suspension comes to a grindingoffers if Sylvia halt, the consents drill stops to and the suction stops flowing. The chair is dead. spinning share her banking or related transaction data 1 AWARENESS 2. APPLICATION SylviaPanicked, has not Sylvia spends hours trolling through the internet previously been successful looking for a lender not knowing if she’s missing offers or applying how tofor a loan compare with her existing bank, so them 2 APP Sylvia throug financ the 1989 business statement has she must search for years of paper statements to be in here somewhere from Automatic multiplecomparisons banks to prove her financial Digita health• Easy comparison with automatic price searching elsewhere. Branches reopen but she • Bran • Personalized offerings aligned to individual circumstances • Switc is uncomfortable going toatone • Know the best rate available duetime any given to COVID open health concerns • Virtu How Consumer Data Right can help Digital onboarding enabled by access to Sylvia's customer, product, account ugh the internet issing offers or 2 APPLICATION Sylvia doesn’t apply for a loan with her existing bank so she must delve through years of paper statements from multiple banks to prove her 3 and transactionalASSESSMENT removing the need data on her consent forpass, Weeks a branch visitfrom the bank. Sylvia’s practice is it’s radio silence closed while she waits. She is worried that her turnover dropping financial health. Branches reopen but she is hesitant to go due to Covid-19 Virtual chat with due personalised loanthe assessment to Covid-19 will impact suggestions based on Sylvia's data Digital onboarding Whole of wallet view Transaction ching • Branch visit not needed • Link years of consistent datasets for lender fee to analyse - $350 circumstances • Switch effortlessly with automatic handling of account • No need to manually source financials from multiple accounts me opening and administration • Virtual engagement to offer personalised loan suggestions © Oliver Wyman 2
ne afternoon, Sylvia is treating a patient enquiries when her please contact and the suction stops flowing. The chair is dead. 1800-JOB KEEPER Open Data Is Essential For Small Business Recovery Sylvia is a 38 year old dentist operating her own practice in the inner Sydney suburb of Surry Hills. One afternoon, Sylvia is treating a patient w dental chair malfunctions. The chair’s suspension comes to a grinding halt, the drill stops spinning and the suction stops flowing. The chair is 1 AWARENESS Panicked, Sylvia spends hours trolling through the internet looking for a lender not knowing if she’s missing offers or how to compare them 2 APPLICATION 3. ASSESSMENT Sylvia doesn’t apply for a loan with her existing bank so she must delve She through is ofworried years that from paper statements themultiple shortbanks revenue to prove decrease her financial health. Branches reopen but she is hesitant to go due to Covid-19 3 ASSES Weeks pass closed while due to Covi she experienced due to COVID-19 will impact her assessment Automatic comparisons Digital onboarding Whole of wa • Easy comparison with automatic price searching • Branchthe visit notbusiness 1989 needed • Link years statement has • Personalized offerings aligned to individual circumstances • Switch effortlessly with automatic handling of account to be in here • No need to • Know the best rate available at any given time How Consumer Data Right can help opening and administration somewhere CLOSED • Virtual engagement to offer personalised loan suggestions for urgent enquiries please contact Automated credit assessment based on real time transaction data and more 1800-JOB KEEPER accurate forecasting of cash flows must delve rove her 34. DECISION ASSESSMENT Sylvia’sWeeksloanpass, The eligibility application is rejected. it’s radio silence criteria excludes from the bank. Sylvia’s practice is closed while she waits. She is worried that her turnover dropping businesses 1 2 3 ue to Covid-19 due to Covid-19 will impact the assessment Loan ASSESSM declined inAWARENESS operation for less than 12 months. APPLICATION Sylvia’s practice Panicked, Whole Sylvia spends is view hours of wallet 11 months trolling through old the internet Transaction looking for a lender not knowing if she’s missing offers or Sylvia doesn’t apply for a loan with her existing bank so she must delve through years of paper statements from multiple banks to prove her Weeks pass, it’s closed while sh fee - $350 • Link years how to compare them of consistent datasets for lender to analyse financial health. Branches reopen but she is hesitant to go due to Covid-19 due to Covid-19 • No need to manually source financials from multiple accounts How Consumer Data Right can help Automatic comparisons Digital onboarding Whole of walle • Easy comparison with automatic price searching • Branch visit not needed • Link years of c Fairer and faster credit decisions based on • Personalized offerings aligned to individual circumstances • Know the best rate available at any given time • Switch effortlessly with automatic handling of account opening and administration • No need to m real time financial performance data that will • Virtual engagement to offer personalised loan suggestions enable more accurate assessment of current performance (including e.g. COVID impacts) and future cash flow serviceability 4 DECISION Sylvia’s loan application is rejected. The eligibility criteria excludes businesses in operation for less than 12 months. Sylvia’s practice is 11 months old. Ms. Sylvia, we regret to inform 5 5. DISBURSEMENT DISBURSEMENT After multiple rejections Sylvia finally has her loan approved elsewhere. After multiple She checks her bankrejections Sylvia account obsessively, with a hefty transaction fee Loan declined the finally has funds have arrived along 6 PAYM After just 2 receives a d of her chair you that your 2 most recent her loan approved elsewhere. She checks direct debit payments for your Behaviour prediction outstanding loan were declined Transaction fee - $350 her bankmovement Smoother account obsessively, the funds have of funds Outcome p • Track aggregate spending patterns to extrapolate future outcomes • No payment delays • Proactive such and • Avoid biased rejections due toanomalies we will widerbeeconomic removingimpacts your arrived along with a hefty transaction fee • Direct account-to-account payments eliminate transaction • Receive st (such as COVID-19) dental chair from your premises costs charged to the customer upcoming to reclaim the funds. Yours d Sincerely, Mr Bank How Consumer Data Right can help Faster and lower cost payments enabled by account-to-account payments How Open Banking can help authorised at point of sale when 4 66. REPAYMENTS 5 6 write access is introduced to the CDR DECISION PAYMENTS DISBURSEMENT PAYMEN Sylvia’s loan application is rejected. The eligibility criteria excludes After multiple rejections Sylvia finally has her loan approved elsewhere. After just 2 mis pproved elsewhere. After 2 missed repayments due to bad timing businessesAfter is 11 months in operation for less payments just 2 missed old. than 12 months. due to Sylvia’s bad practice timing of direct debits Sylvia She checks her bank account obsessively, the funds have arrived along receives a defa have arrived along receives a default notice from her bank. They are taking possession with a hefty transaction fee of her chair to of direct debits of her Sylvia chair to reclaimreceives a default the outstanding debt notice from her Behaviour bank. They are taking possession prediction Ms. Sylvia, Smoother movement of funds Outcome pred • Track aggregate spending patterns to extrapolate future outcomes • No payment delays • Proactive rest of• Avoid herbiased chair Outcome toprediction reclaim rejections the and due toanomalies outstanding debt wider economic impacts • Direct account-to-account payments eliminate transaction • Receive strate (such as •COVID-19) Proactive restructuring to avoid dishonor penalties we costs regret charged to inform you that to the customer upcoming pay nsaction • Receive strategically timed ‘nudge’ notifications for your 2 most recent direct debit upcoming payments How Consumer Data Right can help payments for your outstanding loan were declined due to insufficient funds. Real time alerts from continuous connection to Howunderlying operating Open Banking can help accounts enables As such you are now in default timely nudges for upcoming payments and and must take action to clear your debt... proactive restructuring to avoid penalties Yours Sincerely, Mr. Bank © Oliver Wyman 3
Open Data Is Essential For Small Business Recovery THE PROMISE OF OPEN DATA For consumers and businesses, Open Data should unlock materially smoother, faster and more innovative experiences. Processes that were previously paper-based and cumbersome can now become digital and instant. Customer onboarding and account switching can be completed in a few clicks. Brand new services such as subscription management and behaviour-based offers can become more common. While the use cases are far and wide across industries and segments, the common denominator is that they lead to better customer outcomes. In the context of the COVID-19 pandemic, a critical opportunity that we believe Open Data must enable is easier, faster and more robust access to credit for small businesses. Historically, obtaining small business credit products from lenders has been challenged by manual processes, long timeframes, and high rejection rates. While fintechs and some leading banks invested to address these challenges pre-crisis, few have been able to continue lending at scale. Despite substantial government support, new loans to non-financial businesses are down 2.2% from March to August this year according to APRA. We believe that real-time secure access to business financial performance data through Open Data can be a key enabler of sustainable credit for small businesses post COVID-19. As Sylvia’s business loan application journey above illustrates, Open Data can unlock more digital customer experiences, real-time and verified data across providers as well as faster and more accurate credit assessment and monitoring. While some of these experiences can be provided now, they are expensive to build and not all players have access to the data required to deliver them. Off to a slow start Australia’s CDR regime went live on 1 July 2020 following eight months of industry testing with early data recipients and the major banks (see exhibit 1). CDR will first apply to the banking sector followed by telecommunications and energy sectors. There remains, however, a general lack of customer awareness of the potential benefits of the CDR. The CDR ecosystem is still immature and is largely discussed in just banking and technology circles. While a few early adopters have started to experiment, the current challenging economic context means that take-up at major financial institutions has been slower than hoped. A key barrier to utilisation of CDR is the process to become an Accredited Data Recipient (ADR). Companies seeking to receive data needed to be accredited by the Australian Competition and Consumer Commission (ACCC), which has high standards for technical, business and customer readiness. These standards come with costs and therefore needs a clear commercial case. With oversight shifting from the ACCC to the Treasury recently, there will be renewed emphasis on increasing awareness and participation in the CDR ecosystem. © Oliver Wyman 4
Open Data Is Essential For Small Business Recovery Exhibit 1: Overview of key CDR milestones from 1 July 2020 July 2020 November 2020 July 2021 CDR goes live. Major Major banks make All other non-major banks banks (ANZ, NAB, CBA, available account and and lenders are required WBC) make available transaction data for home to allow customers to account and transaction loans, personal loans and share product, account data for deposit accounts, mortgage offset accounts and transaction data for debit and credit cards to all banking products Accredited Data Recipients Source: ACCC, timeline simplified for illustration While there are many use cases for the first implementations of CDR, those that address existing business problems and customer experiences are likely to be prioritised over creating new capabilities. UNLOCKING SMALL BUSINESS CREDIT IN THE NEW NORMAL 2 in 5 small businesses expect reduced ability to pay operating expenses over COVID-19 Source: Australian Bureau of Statistics Access to credit is the lifeblood of small business COVID-19 has brought an unprecedented change to our definition of “normal”. Australia’s GDP is expected to decline by over 5% in 2020 and small businesses have been especially hard hit. The recovery may be long and will vary significantly by sector and region. Our research with small businesses in Q1-Q2 this year raised that access to credit and managing cashflow are the most pressing needs across sectors. Small business owners highlighted that visibility and control over expenses and cash reserves (>70% did not have this), quick and easy access to credit to overcome short term cash needs (most either had loan applications rejected or felt the process took too long) and collecting payments on time (>50% of invoices were paid late) were three factors critical to their survival and recovery. © Oliver Wyman 5
Open Data Is Essential For Small Business Recovery Accordingly, there is an increasing need for lenders to help by providing greater access to capital. Small businesses require capital both to sustain cash flows in the short term, as government support is withdrawn, as well as to deliver business model changes required to address behavioural shifts that the pandemic has accelerated. These include a step change in the adoption of digital payments, e-commerce and virtual ways of working that are changing the way services for small businesses need to be provided. I need instant decisions to fund shortfalls in my cashflow. I was hoping the government guarantee would allow lenders to offer more affordable loans but I can’t justify the cost. It’s just too high. Hairdressing salon owner When the government announced its AU$40 billion SME loan guarantee scheme in March 2020 business owners were hopeful the stimulus package would provide quick, simple access to affordable credit. By July, the well-intentioned economic support had not realized its potential with just 15,600 new business loans worth AU$1.5 billion issued. While the government guarantees half of the potential losses, lenders are exposed to the remaining amount, a risk that is particularly heightened due to lack of visibility into future cashflows. This lower utilization highlights the issues for small business credit on both the supply and demand side. On one hand, business owners need speed and certainty on any credit decision. They cannot afford to wait for weeks for a decision in the current climate and are uncomfortable taking on additional credit that might also require personal collateral to secure. Many also prefer not to pay the higher rates that non-bank lenders offer as an alternative. On the other hand, lenders want to provide credit, but are challenged to efficiently collect the data required to make a fast, robust lending decision. Where some lenders have enabled digital collection of data (for example through screen scraping), underlying models and processes will still need to change to develop a view of the current and potential future performance of the small business in the “new normal”. While updates to the scheme were introduced from October, it remains to be seen whether increasing the loan size, tenure or security requirements will do much to address these challenges in the short term. © Oliver Wyman 6
Open Data Is Essential For Small Business Recovery Credit assessment needs to change There is a growing challenge for lenders to originate and manage credit in the “new-normal”. Existing credit assessments are typically backwards looking and calibrated on a historical period of very little financial stress (in Australia). This means their ability to efficiently assess the ongoing viability and credit worthiness of businesses using traditional approaches, often anchored on accounting metrics and more qualitative assessment of business performance, will be materially lower than before. Ongoing government support schemes such as JobSeeker, JobKeeper, Government backed loans, interest and principal holiday periods, and tax write-offs add significant complexity to any assessment of financial viability. From a practical perspective, this means that the time and cost of assessing credit for small businesses is only set to increase unless new data and ways of assessing viability can be incorporated. The CDR provides direct transaction level access to operational and credit accounts that allow lenders to secure real time information on how a company has managed its cost and revenue profile through the crisis. Utilisation of this data and capability will be essential for bridging the supply and demand challenges of cost and complexity vs. speed and transparency for small business lending. Open data has already started to be used to solve lending problems, as shown in Exhibit 2 Exhibit 2: The first CDR powered loan approval, 1 July 2020 3,000 transactions Next morning A few hours securely shared 20 seconds 2 minutes applicant for RAB credit with Regional to complete to undertake electronically team to approve Australia Bank in data collection categorisation accepted the the loan just a few seconds loan offer Source: Basiq, Regional Australia Bank © Oliver Wyman 7
Open Data Is Essential For Small Business Recovery REIMAGINING CREDIT WITH CDR The CDR in Australia is providing a timely and much needed opportunity for lenders to upgrade the efficiency and effectiveness of their credit assessment and management processes. While there are many beneficial applications of the CDR, we observe two important use cases related to credit in the short term: Exhibit 3: Illustrative viability assessment of a department store A department store could see up to 4x variation in liquidity requirement based on how the economy recovers Recovery Scenarios Affordability Assessment Outcome $'00M 6 5 4 3 Smart and 2 Affordable also lucky 1 0 -1 -2 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2020 2021 Years: 19 20 21 22 23 24 25 26 $'00M 5 4 3 2 Plausible but 1 Maybe pessimistic affordable 0 -1 -2 -3 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2020 2021 Years: 19 20 21 22 23 24 25 26 $'00M 4 3 2 1 Economic 0 Not crisis affordable -1 -2 -3 -4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2020 2021 Years: 19 20 21 22 23 24 25 26 Illustrative cases of COVID-19 Free Cash Flow not usable Able to pay the debt and partial lockdowns to pay the debt Not able to pay the debt Free Cash Flow usable Total new debt to pay the debt Source: Company filings; Oliver Wyman Analysis © Oliver Wyman 8
Open Data Is Essential For Small Business Recovery Use Case 1 Next-gen credit decisioning It will be challenging to assess credit decisions going forward by looking at the prior year financials of a business and making a qualitative assessment of its ability to compete. Assessment in the new normal needs to form a view of both how the business is performing now, using up to date, granular financial information (such as transaction level cash flow data) as well as how it will be able to service its debt going forward. CDR will provide access to digital, verified, up to date financial account information (up to seven years of historical data) that enable forward looking estimates of loan serviceability based on granular cash flow analyses of cost profiles, revenue seasonality, diversity and concentration under future sector recovery scenarios. As the data is provided in digital form, manual verification tasks are reduced and opportunities for automation are increased. This will provide a positive experience for both the lender and the small business. The small business will have a loan assessment that would require materially less paperwork, a faster time to decision, and an assessment that takes into account their latest financial performance. The lender would have a materially more efficient data collection process, lower operational risk, more granular, accurate and up to date financial information, and the ability to overlay future recovery scenarios in a consistent and efficient manner at the point of credit decision. Use Case 2 Proactive portfolio monitoring One of the biggest challenges that lenders are wrestling with through the crisis is how to build an accurate, current picture of their small business portfolio health. Understanding which businesses are struggling or require credit support is impossible to do efficiently without access to holistic, up to date, granular business financial performance data. Even lenders that act as the main financial institution (MFI) for the small business (i.e. they provide the small businesses primary transaction account) cannot comprehensively do so as they would not know if the business has other financial service products or accounts at another financial institution, let alone have up to date data on them. The CDR aims to provide ongoing real-time access to all customer permissioned transaction, savings and credit products by next year. Access to this information will enable lenders to generate real-time reporting and analyses of small business financial performance based on transaction data. It also enables more accurate, proactive predictions of potential hardship and customer support requirements, reducing costs for the customer and improving risk outcomes for the lender. © Oliver Wyman 9
Open Data Is Essential For Small Business Recovery IMPERATIVES FOR LENDERS As small business lenders reset their strategic priorities in the new normal, credit innovation leveraging CDR should be at the top of the agenda. We recommend three actions to get started: • Prioritize use cases along the credit journey based on impact and return on investment (ROI). Assess how your baseline capability serves existing or target customers’ credit needs. Identify CDR use cases that resolve gaps along the customer journey and increase business efficiencies. Develop a use case roadmap and business case based on customer impact metrics e.g. cost of acquisition, time-to-yes and ROI e.g. revenue uplift, NPL reductions, lower recovery costs. • Secure accreditation as a Data Recipient in the CDR ecosystem. To become an Accredited Data Recipient (ADR), there are specific technical and security standards required to be compliant. This requires an ongoing program of work to keep up with evolving CDR standards. Running proof of concepts in a simulated CDR environment enables faster testing of internal and customer experiences prior to accreditation. • Design forward looking credit platform and capabilities. Double down on investments in the capabilities required to implement identified use cases such as transaction-based credit models using machine learning, scenario-based cash flow and liquidity forecasting, and real time portfolio monitoring with early warning signals. For many this will likely also include the identification and deployment of new technology and data capabilities to enable real time ingestion of the CDR data services. Interview with Jill Berry — Co-Founder and CEO of Adatree Adatree is an Australian regtech that offers an Open Banking industry sandbox to explore a full ADR experience as well as a Data Recipient Platform with the technical components needed to participate in the CDR ecosystem. What use cases enabled by CDR are you seeing lenders implement across the small business credit journey? Can you give an example of what one looks like? We see lenders become a part of the CDR to implement three main use cases: credit assessment, credit monitoring, and customer onboarding. Let’s take Bill, the owner of the local pizza restaurant who wants to expand into four new postcodes. Bill applies for a business loan through a digital non-bank lender. The non-bank lender is an ADR and Bill gives permission for them to access his data. Bill applied for the loan through a digital app, consenting for the ADR to access his data. The lender can see up to seven years’ worth of transaction history, and while Bill’s credit score isn’t great, they believe he has capacity to pay the loan since they look at all of his transactional behaviours. Within a few days, Bill’s application has been approved. His onboarding is quick and paperless. © Oliver Wyman 10
Open Data Is Essential For Small Business Recovery Within the first four months of paying down the loan, the lender notices some red flags in Bill’s finances since they actively monitor his transactions as an ADR. They actively reach out to him to offer financial assistance so they can improve Bill’s situation and fix it before things get any worse. After 1.5 years, the lender automatically identifies a better product for Bill based on the CDR data they can access and offer him a more suitable alternative, based on his actual behaviours. This new product saves Bill a substantial amount each month and the lender is rewarded with ongoing loyalty from Bill. While the CDR is in its infancy in Australia, it is pretty easy to see an example like the one above coming to life. Innovative lenders are taking on CDR as an amazing opportunity to leverage vast amount of data to better service customers and grow their business. What impact do you see these use cases having on the industry — customers as well as lenders? CDR will transform the way industries offer credit and both lenders and their small business customers will benefit greatly. Cash flow is critical to small business survival, and sometimes access to credit when businesses need it can be difficult to get. Maybe their credit score isn’t where it needs to be, or the lengthy application process or red tape is a barrier? CDR will both speed up the time to get credit and broaden the scope of people accessing credit. CDR will enable lenders to create their own ‘credit score’ for small businesses based on up to seven years worth of financial data. No longer having to rely on potentially out of date credit scores means lenders can increase the reach of customers they may not have targeted before and can be more confident in a small businesses ability to repay due to greater transparency of their financial situation. The reduction of this credit risk and the financial implications of the reduction in bad debt will drastically transform the industry. Access to this data will be available to any ADR, making the opportunity ripe for new entrants into the market. In addition, the automation of the process will have a dramatic cost saving effect. This is a win-win situation. Businesses will access credit when they need it most in a quick, simple and secure way, and they can be helped should they get into financial trouble. Innovative lenders can acquire customers, understand customers’ actual behaviours, better manage their front and back books, and create significant cost efficiencies through process improvement and automation. What hurdles should ADR aspirants be prepared for and how can they be overcome? I think the main hurdles are around becoming part of the CDR ecosystem and actually becoming accredited as an ADR. If you did want to do things yourself, costs can run into the millions just for technical and security readiness from examples we have seen. © Oliver Wyman 11
Open Data Is Essential For Small Business Recovery It isn’t just about being accredited; it is about maintaining it too, with keeping up to date on technical and security standards for e.g. when joint accounts and more complex scenarios are introduced. The time needed to understand the legislation, the software and security expertise required to become an ADR and the ongoing software and engineering costs can be a barrier to entry for some organisations. One of the best ways to overcome these barriers is to partner with an out-of-the-box Open Banking Provider like Adatree. At Adatree we have created technology solutions for organisations to comply with the CDR and access Open Banking easily. We offer a turnkey software solution for organisations to give them security, reliability and adherence to the legislation that is quick and cost efficient, at least 90% cheaper than building it yourself. Integrating into Adatree’s one API enables you to focus on your customer value propositions instead of compliance. The Open Banking future is upon us and organisations that do not want to get left behind need to start thinking today about how CDR will enhance their business and help them grow their future. © Oliver Wyman 12
Oliver Wyman is a global leader in management consulting that combines deep industry knowledge with specialised expertise in strategy, operations, risk management, and organisation transformation. For more information, please contact the marketing department by phone at one of the following locations: EMEA Americas Asia Pacific +44 20 7333 8333 +1 212 541 8100 +65 6510 9700 AUTHORS Chris Evans Partner Chris.Evans@oliverwyman.com Nihal George Principal Nihal.George@oliverwyman.com Copyright © 2020 Oliver Wyman All rights reserved. This report may not be reproduced or redistributed, in whole or in part, without the written permission of Oliver Wyman and Oliver Wyman accepts no liability whatsoever for the actions of third parties in this respect. The information and opinions in this report were prepared by Oliver Wyman. This report is not investment advice and should not be relied on for such advice or as a substitute for consultation with professional accountants, tax, legal or financial advisors. Oliver Wyman has made every effort to use reliable, up-to-date and comprehensive information and analysis, but all information is provided without warranty of any kind, express or implied. Oliver Wyman disclaims any responsibility to update the information or conclusions in this report. Oliver Wyman accepts no liability for any loss arising from any action taken or refrained from as a result of information contained in this report or any reports or sources of information referred to herein, or for any consequential, special or similar damages even if advised of the possibility of such damages. The report is not an offer to buy or sell securities or a solicitation of an offer to buy or sell securities. This report may not be sold without the written consent of Oliver Wyman. Oliver Wyman – A Marsh & McLennan Company www.oliverwyman.com
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