• Pensions Compass
  • Jun 3, 2026

Pensions Ready Reckoner – June 2026

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PARLIAMENT

Effective Date

Effect

Recent Acts

FINANCE ACT 2026

Royal Assent 18 March 2026

 

 

The Bill was introduced in Parliament following the Budget on 26 November 2025. Inheritance Tax on certain death benefits under registered pension schemes applies for deaths on or after 6 April 2027. Click here for our Bulletin published on 19 March 2026 and here for the article in Part 1 of this Pensions Compass.

 

NATIONAL INSURANCE CONTRIBUTIONS

(Employer Pensions Contributions) Act 2026

Royal Assent 29  April 2026

The Act empowers the making of Regulations, so that with effect from 6 April 2029 employer and employee NICs apply to amounts of salary sacrificed for employer contributions where the sacrificed amount exceeds £2000.

 

PENSION SCHEMES ACT 2026

Royal Assent  29 April 2026

 

The Act includes new rules for surplus extraction for DB schemes; consolidation of DC small pots; value test for DC arrangements; large DC schemes consolidation; trustees of certain DC occupational schemes to provide retirement solutions including default investment options; and permanent structure for commercial superfunds. Click here for articles in July 2025 Pensions Compass. The Bill also facilitates relevant schemes handling “Virgin Media” issues. Click here for the article in Part 1 of February 2026 Pensions Compass and here for the article in Part 1 of this Pensions Compass.
GMP Conversion – Conversion of GMPs Act (Royal Assent 28/4/2022) Not yet in force Enables GMP conversion once relevant Regulations made. Still awaiting DWP’s Consultation on draft Regulations. Click here for article in June 2022 Pensions Compass.
Data (Use and Access) Act 2025 Royal Assent 19 June 2025 Various reforms, including strengthening powers of the Information Commissioner. Most of the Act’s provisions come into effect on dates to be appointed. Some took effect on Royal Assent including those relating to searches for data subject access requests. New provisions for the handling of data protection complaints apply from 19 June 2026. Click here for our article published 14 May 2026.
Finance Act 2025 Royal Assent 20 March 2025 Overseas transfer charge: transfers to QROPs in EEA or Gibraltar no longer excluded from overseas transfer charge; conditions of OPS and ROPs established in EEA aligned with OPS and ROPs established in rest of the world from 6 April 2025; and as from 8 April 2025, scheme administrators of registered pension schemes must be UK resistant.
Finance Act 2024 Royal Assent 22 February 2024 with effect from 6 April 2024 Replaces Lifetime Allowance with new Lump Sum Allowance and Lump Sum and Death Benefit Allowance. Click here for the article in Part 4 of June 2024 Pensions Compass.

Pensions (Extension of automatic Enrolment) (No 2) Act

2023

Royal Assent 18 September 2023 Regulations awaited.

 

NB Future Acts – Draft legislation for Finance Bill 2026/2027  expected to be published July 2026, including taxation of DB surplus paid to members.

Recent and forthcoming Regulations

Regulated Activities (Providing Targeted support)(Amendment) Order Enabling providers to give targeted support to consumers on investments and pensions. The Regulations came into force (completely) on 6 April 2026.
Collective Defined Contribution (CDC) Regulations for schemes with unconnected employers  The DWP consultation closed on 19 November 2024. Tht CDC Regulations were laid before Parliament on 27 October 2027 and  come into force on 31 July 2026.
GMP Conversion Regulations  Consultation on draft Regulations still awaited See above under Conversion of GMPs Act
Notifiable Events
Amendment Regulations
Timing unknown Additional Events to be notified to TPR and to scheme trustees (change in control of an employer, sale of material proportion of business or assets and/or granting of certain security rights). DWP’s Consultation on these proposed controversial Regulations closed on 27 October 2021 and it seems DWP have stopped work on these Regulations.  Click here to listen to our December 2021 Podcast.

Extension of Automatic Enrolment Regulations

 

Timing uncertain

 

See above under Pensions (Extension of Automatic Enrolment) (No. 2) Act 2023

 

Transitional Regulations relating to the change in Normal Minimum Pension Age (NMPA) from age 55 to age 57 on 6 April 2028

 

Consultation on draft Regulations awaited

Important Regulations to ensure the change in NMPA on 6 April 2028 works fairly. HMRC Newsletter 180, April 2026, gives some information on the new regulations.
HMRC further Regulations re abolition of the lifetime allowance and calculating the new Lump sum Allowances Regulations expected to be made by Summer 2026. These Regulations cover various outstanding queries on the calculation of the Lump Sum Allowance and the Lump Sum Death Benefit Allowance. These Regulations were laid in Parliament in early June 2026.
HMRC Regulations on information sharing between PRs, PSAs and members in context of IHT on certain pension benefits and unused pension pots. HMRC short Technical Consultation published 18 May 2026. Click here for the article in Part 1 of this Pensions Compass
Retained EU Law Regulations Made on 17 September 2024 and came into force on 18 September 2024 The provisions enabling the UK courts to depart from retained EU case law more easily are revoked whilst the present government considers its position
Regulations under Pension Schemes Act 2026 Taking effect gradually during 2027 and onwards Numerous Regulations are expected underpinning the headline changes in Pension Schemes Act 2026. Click here for the article in Part 1 of this Pensions Compass.

Regulations under the

NIC (Employer Contributions) Act 2026

By 6 April 2029 These Regulations will be consulted on and will provide the detailed machinery for applying and calculating the £2000 cap.in relation to sacrificed contributions.
Authorised Surplus Payments Charge (Variation Rate) Order 2024 6 April 2024 Reduces the amount of tax due on authorised surplus repayment from 35% to 25%. Click here for the article in Part 1 of December 2023 Pensions Compass.
Regulated Activities Amendment Order – Operators of pensions dashboards 11 March 2024 The Order authorises the Financial Conduct Authority to regulate commercial operators of pensions dashboards. Such operators must either be or become authorised by the FCA.
Pensions Dashboards Amendment Regulations 2023 9 August 2023 The December 2022 Regulations specified statutory connection deadlines. However, there were IT connection problems. The August 2023 Pensions Dashboards Amendment Regulations amended the December 2022 Regulations and specify a single statutory connection deadline of October 2026 with staging to be included in Guidance as published on 25 March 2024. Click here for the article in Part 3 of June 2024 Pensions Compass and here for the article in Part 4 of February 2026 Pensions Compass.

 

FROM THE COURTS

RECENT DECISIONS

TUPE Transfers

McKavney v Serco Group

High Court

10 March 2026

The High Court upheld the Pension Ombudsman’s conclusion that the TUPE Transfer did not amount to the member being “compulsorily retired from service by his Employer due to redundancy or reorganisation” within the meaning of the particular scheme rules.  Click here for the article in Part 2 of this Pensions Compass.

Data Protection

Spurgeon & others v Capita

High Court

9 February 2026

Many scheme members alleged data breaches by the scheme’s administrator Capita, following a cyber attack on Capita in 2023.  The High Court dismissed Capita’s action to strike-out these claims.

Footnote:  another case on data security, albeit in the retail rather than pensions field, is the “DSG” case.  On 19 February 2026, the Court of Appeal decided the retailer was required to take appropriate security measures to protect data from unauthorised access, regardless of whether people could be identified from the data obtained by the hackers.

Settlement of issues and Rectification

Places for People Group Retirement Benefit Scheme

High Court

19 December 2025

The High Court “blessed” the proposed settlement of issues including some Virgin Media section 37 issues; and ordered Rectification of various scheme documents including certain documents incorrectly executed.

Interpreting amendment power

3i plc v Decesare

High Court

21 November 2025

The High Court decided that the scheme’s amendment restriction not to diminish the “accrued rights or interests” of members in respect of “benefits already provided” did not apply to future service benefits. This paved the way for proposed amendments.

Pensions Liberation

Brambles v Harvey

High Court

14 November 2025

High Court upholds Pensions Ombudsman decision re test for trustee dishonesty and that the trust was a single trust, not separate sub trusts.

Corporation Tax (CT) deduction disallowed

A D Bly v HMRC

Court of Appeal

14 November 2025

Deduction disallowed for employer contributions to an unfunded unregistered pension scheme. The Court of Appeal decided the main purpose was to obtain a CT deduction and therefore the contributions were not an allowable business expense, decisions of lower Courts upheld.

Enforcing debts against pension benefits

Zubarev v Singh

High Court

3 September 2025

The wording in the personal pension schemes could not be regarded as protecting pension benefits in the same way as under section 91 (5) Pensions Act 1995 which applies to occupational pension schemes. The court also considered the timing impact of third-party debt Orders.

Meaning of SPA (State Pension Age) in scheme rules

Spirit (Legacy) Pension Trustees Limited v Alexis      

High Court

1 September 2025

                  

Disagreeing with the Pensions Ombudsman, the High Court ruled the particular SPA wording meant SPA was static – the SPA when the scheme rule was adopted and not the SPA when the member subsequently retired

 

 

 

 

Settlement of Issues

KO UK Pension Trustees v Coca Cola               

High Court

8 August 2025

The Court “blessed” the proposed variation of a buy-in contact and proposed use of scheme surplus.  Click here for the article in Part 3 of February 2026 Pensions Compass

 

Data Protection

Farley v Paymaster (trading as Equiniti)

Court of Appeal

22 August 2025

Some 400 police officers were sent annual benefit statements containing personal data including dates of birth and national insurance numbers; these were sent to out -of -date addresses.

Claims were brought for compensation. In February 2024 the High Court struck out the claims as having no real prospect of success. On 11 July 2024 the Court of Appeal concluded that one of the grounds was reasonably arguable. On 22 August 2025 the Court of Appeal decided that proof that incorrectly addressed benefit statements were opened and read was not needed. Case remitted to High Court to decide whether in each case there was any damage to be compensated.

Footnote – on 10 November 2025 Paymaster was granted permission to appeal to the Supreme Court on whether the police officers had a reasonable basis for compensation, with a realistic prospect of success at trial. The Supreme Court hearing is listed for 7 and 8 October 2026.

TPR Contribution notice upheld

against director and shareholder

Pelgrave v TPR     

Upper Tribunal High Court

1 August 2025

Another win for TPR under the Pensions Act anti-avoidance provisions. Click here for the article in Part 1 of October 2025 Pensions Compass.

Creditor’s rights against SIPP benefits

 

Century Property v Aldiss

 

High Court

24 June 2025

High Court ordered judgment could be enforced against SIPP benefits. (Not possible where occupational pension scheme – see Manolete Partners v White, below).

Correction of scheme document by Court by interpretation

 

Renishaw v Ross Trustees

 

High Court

23 May 2025

Where the language has clearly gone wrong and it is clear what was meant, the Court can correct a document as matter of interpretation – so the Court corrected the drafting of a money purchase underpin, having considered a confidential Counsel’s opinion.

Equality Act 2010

 

 For Women Scotland Ltd v Scottish Ministers

 

Supreme Court

16 April 2025

Supreme Court decides that references to ‘man’ ‘woman’ and ‘sex’ in the Equality Act 2010 and key provisions in Gender Recognition Act 2004 refer to biological sex, not ‘certificated sex’ of an individual under a gender recognition certificate.

Scheme sanction charges (Finance Act 2004)

Morgan Lloyd Trustees v Revenue and Customs Commissioners

Upper Tribunal 25 March 2025

The Upper Tribunal upheld most of the tax charges against the scheme administrators in respect of unauthorised payments made to the sponsoring employers (purchase of intellectual property rights for inadequate value). The Upper Tribunal decision also ruled on time limits and the conditions on which scheme administrators can be discharged from liability for scheme sanction charges.

Limitation – continuing duty not upheld

Philips v National Grid Gas

High Court

24 March 2025

Although the court held there was no continuing duty, it decided that the action could continue due to the employer’s failure to obtain a promised further medical opinion.

Amendments (schemes’ merger)

Arcadia Group Pension Trustees Limited v Smith

High Court 3 February 2025

The High Court approved the proposed merger of 2 registered pension schemes and reviewed scheme trustees’ fiduciary duties in context of the proper purposes of the scheme. Click here for the article in Part 4 of April 2025 Pensions Compass.
Creditor’s right to enforce pension drawdown dismissed
Manolete Partners PLC v White
Court of Appeal
15 November 2024
Whether the Court should direct a member, a former director of a company, to draw his pension to satisfy a judgment debt owing to a creditor  for breach of director’s duties. On 16 March 2023 the High Court so ordered saying that section 91(2) Pensions Act 1995 was no bar as the member was to be paid his pension, albeit it would then be used by his creditor. On 15 November 2024 the Court of Appeal reversed the High Court’s decision, holding that such an order infringed section 91(2) Pensions Act 1995 which says that an order cannot be made to restrain a member from receiving a pension due under an occupational pension scheme. The position seems to be different in relation to enforcing a debt against SIPP benefits – See also Century Property v Aldiss, High Court 4 June 2025.

Rectification:

Ballard v Buzzard

High Court

4 November 2024

The High Court accepted that a signature on behalf of the employer to a rule change could in the circumstances be accepted as also being a trustee’s signature

Cohabitation under the LGPS rules

Thomas v Southwark Council

High Court 31 October 2024

Successful appeal against Pensions Ombudsman’s determination re meaning of cohabitation.  Click here for the article in Part 1 of December 2024 Pensions Compass.
Validity of amendments in absence of section 37 actuarial written confirmation
Virgin Media v NTL Pensions
25 July 2024
Virgin Media asked the High Court to decide whether certain scheme amendments relating to revaluation were valid. It was argued the scheme amendments affecting contracted -out benefits should have been accompanied by written actuarial confirmation under section 37 Pension Schemes Act 1993. The Court was asked to assume there was no actuarial confirmation. On 16 June 2023 the High Court decided that, in the (assumed) absence of written actuarial confirmation, the amendments in question were void. On 25 July 2024 the Court of Appeal unanimously upheld the High Court’s decision.  Click here for the article in Part 3 of October 2024 Pensions Compass and here for the update in Part 4 of July 2025 Pensions Compass on Announcement 5 June 2025. Click here for the article in Part 1 of February 2026 Pensions Compass on the Government’s “Virgin Media” amendments to the Pension Schemes Bill, reflected in the finalised Pension Schemes Act 2026.
Employer’s appeal about alteration powers
BBC v BBC Pension Trust & Another
9 July 2024
On 28 July 2023 the High Court decided that, based on the scheme rules, members’ “interests” extend to future benefits as well as past. On 9 July 2024  the Court of Appeal unanimously upheld the High Court decision. Click here for the article in Part 3 of October 2024 Pensions Compass.

Final salary underpin

Avon Cosmetics v Dalriada & Others

17 January 2024 and 19 February 2024

Using “severance” principles the High Court upheld the switch to CARE benefits for future service, but for past service members should receive the better CARE and Final salary linked benefits underpin. On 19 February 2024 the Court approved a compromise agreement as to the underpin’s effect. Click here for the article in Part 5 of March 2024 Pensions Compass.

 

 

Newell Trustees v Newell Rubbermaid

High Court

23 January 2024

 

In context of conversion to money purchase, the High Court upheld the final salary underpin but based on actuarial value. Click here for the article in Part 5 of March 2024 Pensions Compass on this interesting decision.

 

 

FROM THE COURTS

FUTURE CASES

Scheme amendments

Verity Trustees Ltd v Wood

High Court

February 2025

Application by the sole trustee of the Pensions Trust requesting Court directions about restrictions on the scheme’s amendment power. This MAJOR case lasted many weeks. It involves the scope and effect of a scheme amendment power. The High Court was also asked ancillary questions about the Court of Appeal’s Virgin Media decision, see above. Due to the complexity and amount at stake, judgment in Verity is not expected until Spring 2026 at the earliest. It may be the Court will not rule on Virgin Media issues.
Various Part 7 Claims against Verity Trustees Ltd We understand some employers participating in the Pensions Trust have brought claims against the trustee alleging breach of duty, and that these claims have been stayed pending the outcome of the above High Court proceedings.

Value of Investments

Legal and General

Assurance and Others v Glencore PLC

High Court

2025

Following Glencore admitting in the US courts various violations, L&G and 4 of its funds have lodged a Part 7 claim against Glencore  we understand judgment has been given but has not yet been released.

NB. Supreme Court hearing listed for 7 and 8 October 2026 – see above under “Recent Decisions” in “Farley”

PENSIONS OMBUDSMAN

RECENT DECISIONS

Incorrect distribution of scheme death benefits

Mrs R – Wellcome Trust Pension Plan

18 March 2025

The PO decided the scheme trustees had not made sufficient appropriate enquiries about who was financially dependent on the deceased member.  Matter remitted back to the scheme trustees to decide again.

Duty to properly investigate potential death benefit beneficiaries

Ms N – Reassure Personal Pension Plan

25 September 2025

A salutary reminder to identify all potential beneficiaries, to be alert to fraud and to make all appropriate enquiries. The complaint was upheld and the matter remitted to the scheme administrators to have another go! The deceased member died in 2018 – some 7 years later the distribution of death benefits remained unsettled.

Suspension of spouse’s pension

MSE – NHS pension Scheme

16 July 2025

PO dismissed widow’s complaint that the suspension conflicted with her rights under the European Convention on Human Rights, incorporated into UK law by the Human Rights Act 1998.

Recovery of overpayments by recoupment from future pension payments

Mr and Mrs D and Trustees of BIC UK Pension Scheme

20 June 2025

The PO decided it was inequitable for the scheme trustees to recover the lion’s share of the overpayments.  Paragraphs 41 to 55 of the PO’s decision gives useful guidance on the PO’s general approach to recovery of overpayments.

Complainants must act in good faith

Mrs N – Teachers Pensions Scheme

5 September 2025

The Pensions Ombudsman dismissed the member’s complaint. The initial pension statement was expressively stated to be an ”interim award” and that the scheme was awaiting employer confirmation.
Statutory and discretionary Transfers to scam schemes The PO has made various decisions on member attempts to recover losses in fraud and other circumstances.

 

PPF

 
 PPF Levy changes DWP has considered changes to the PPF legislation e.g. to enable ‘nil’ PPF levies if appropriate. Relevant provisions are in the Pension Schemes Act 2026. On 11 September 2025 the government announced provisions to abolish the PPF Administration Levy and these provisions are also in Pension Schemes Act 2026.
PPF Levy Rules for 2026/2027 The PPF’s Consultation on the Levy rules closed on 5th January 2026. The zero conventional PPF Levy for 2026/2027 is reflected in Pension Schemes Act 2026. The PPF will continue to levy what it expects to be a low Levy for alternative covenant schemes.

DWP

DWP Policy on scale measures in Pension Schemes Act 2026 The 9th March 2026 Guidance sets out the DWP’s policy principles on the Act’s scale measures, as an overview ahead of Consultation on proposed Regulations. TPR’s Guidance on the same date complements DWP’s Guidance, see below.
Consultation on Retirement CDC schemes On 23 October 2025 the DWP issued its Consultation on its policy proposals for Collective Defined Contribution schemes for pensioner members only. This would enable individuals with DC pots to transfer their pots at retirement into a pooled fund with subsequent adjustments based on eg investment returns. Such schemes are likely to operate within Master Trusts or unconnected multi- employer schemes. The DWP Consultation closed on 4 December 2025.
Trust – based pension schemes: Consultation on strengthening Trustee boards and Governance On 15 December 2025 DWP published its Consultation. This is prompted by the likely emergence of new types of schemes in the next few years, scheme consolidation, and other changes in the pensions landscape such as the government’s promise to produce Guidance on fiduciary duty in the context of wider factors including systemic risk (such as climate change). The Consultation closed on 6 March 2025.
   
Small Pots Delivery Group Report On 24 April 2025 the group report was released, setting out plans and a timetable for consultation re consolidation of small deferred DC pots (click here for the article in Part 3 of July 2025 Pensions Compass). Provisions are now in the Pension Schemes Act 2026.

Treasury

DB Surplus – new statutory power to pay to employers See the provisions in the Pension Schemes Act 2026. Click here for the article in Part 2 of July 2025 Pensions Compass.
Government Pensions Review (Mansion House Reforms) Part 1 of the Pensions Review was published on 29 May 2025, see above under Pensions Investment Review. Part 2 of the Pensions Review started in July 2025 including the announcement of a new Pensions Commission.

TPR

TPR Guidance re AI

On 20 May 2026 TPR published its expectations for how trustees should govern the uses of artificial intelligence.

TPR Guidance re Virgin Media remediation

On 26 March 2026 TPR published guidance to scheme trustees including that “You will normally need to seek advice and confirmation from your legal adviser…”

Footnote – the Financial Reporting Council also published useful advice in January 2026, finalised May 2026.

TPR Guidance on new scale requirements for DC master trusts TPR’s Guidance on 9 March 2026 complements the DWP Guidance on the same date, see above.  TPR’s aim is to give schemes a heads-up for developing credible growth plans.
TPR and Financial Conduct Authority (FCA) joint consultation on the VFM (value for money) framework for trust and contract-based DC default arrangements The Consultation opened on 9 January 2026 and closed on 8 March 2026. The government will consider the responses in connection with regulations under the Pension Schemes Act 2026. For contract – based schemes the FCA will amend the FCA’s handbook.
Revised Administration Guidance On 9 December 2025 TPR published its revised administration guidance to help trustees and administrators deliver high quality services. This replaces TPR’s previous guidance entitled Administration of a DC Scheme, and applies to all scheme types.
TPR Consultation on its Enforcement Strategy.

The Consultation opened on 16 September 2025 and closed on 11 November 2025. TPR describes its proposed new Enforcement Strategy as a “deliberate move towards smarter, collaborative, and risk- based interventions that deliver real-world results.”

Footnote: In February 2026 TPR sent a warning notice to Smiths News Plc saying it is considering a financial support direction against Smiths News and others re a former subsidiary of Smiths News

TPR decision re surplus – Littlewoods Pension Scheme On 3 June 2025 TPR published the terms of its Determination modifying scheme rules of the Littlewoods Scheme to give the trustees power to return surplus to the employer on the winding up of the scheme.
DB Schemes Statements of Strategy On 28 May 2025 TPR announced it would provide statements of strategy spreadsheets and was launching its “Submit scheme valuation” digital service. Click here for the article in Part 2 of October 2024 Pensions Compass
DB Schemes: Employer Covenant Guidance TPR published its guidance on 4 December 2024 and published its finalised views on 28 May 2025 as part of its response to its Consultation on Statements of Strategy.
DB Scheme Fast Track submission tests and conditions On 2 November 2024 TPR publish the fast – track rules for DB schemes with Valuation dates on or after 22 September 2024.

HMRC

IHT and Pensions On 11 May 2026, HMRC published a technical note. On 18 May 2026, HMRC issued a Technical Consultation on draft information sharing regulations and on various ancillary forms. Later this year/early next year, there will be further guidance and updating of HMRC’s Tax Manuals. Click here for the article in this Pensions Compass.
Abolition of Lifetime Allowance Further Regulations clarifying various aspects of the Abolition and the Lump Sum Allowance and Lump Sum Death Benefit Allowance are expected soon.
Tax treatment of DB surplus shared with members The draft legislation for Finance Bill 2026/2027 is expected to include new tax provisions re the tax treatment of surplus shared with members.
Modernising and mandating tax adviser registration Finance Act 2026 requires registration of tax advisers who interact with HMRC on behalf of clients. Further Guidance from HMRC is expected.

PENSIONS DASHBOARDS

Staging Guidance Originally issued by DWP on 25 March 2024 and subsequently updated. Click here for the article in Part 3 of June 2024 Pensions Compass and here for the article in this Pensions Compass. The first schemes have met their April 2025 staging dates. As 2026 progresses it remains to be seen whether relevant schemes continue to meet their Staging Guidance as the number of schemes seeking connection builds in line with the Guidance. The deadline for all relevant schemes remains 31 October 2026 as per the legislation.
Voluntary Connection Guidance July 2025
Data Protection Impact Assessment Issued by the Pensions Dashboard Programme, June 2025. This includes descriptions of how systems will work in practice.
PASA’s Toolkit for AVCs Guidance from PASA re practicalities of connecting to dashboards re AVCs.
Pensions Dashboards Programme (PDP) –  Technical Standards Technical Standards have been published relating to reporting, data, and connection, containing mandatory requirements for the interaction of parties and their interaction with the PDP’s central digital architecture. On 28 January 2026 a Consultation on updating the Reporting standard was issued. The Consultation closed on 30 April 2026.
TPR’s Pensions Dashboards Compliance and Enforcement Policy On 5 September 2024 TPR published its Policy in this area including examples of TPR’s approach in 4 scheme scenarios.
TPR – Updated Guidance and Checklists for trustees On 23 April 2026, TPR issued updated Guidance and Checklists in connection with Pensions Dashboards.

This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.

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