The banking sector: crucial for convergence and integration

DISCLAIMER: All opinions in this column reflect the views of the author(s), not of EURACTIV Media network.


Well-developed financial markets are a prerequisite
for EU accession

Well-developed and stable financial markets –
defined as banks and other financial institutions as well as
capital markets – are crucial for convergence and the successful
integration of the Central and Eastern European candidate countries
(hereafter: CEE-10) into the EU and later on in EMU.

  • Real convergence and access to financing: One of
    the conditions for entry to the EU – laid down in the “Copenhagen
    criteria” – requires the CEE-10 to become functioning market
    economies where companies are able to cope with competitive
    pressure and market forces inside the EU. Access to financing is
    necessary for the required restructuring, efficient functioning and
    dynamic growth of the corporate sector.

    The private sector can finance its activities externally by
    using foreign direct investment (FDI) or by raising capital on the
    international or domestic financial markets. While FDI and access
    to international financial markets can ease the constraints of
    domestic financing, sustained high rates of investment and growth
    are unlikely to be achieved without the transmission of domestic
    savings into investment by local financial markets. The exchange
    rate risk that foreign indebtedness implies is a further limitation
    of foreign financing.

    Moreover, in the CEE-10 access to foreign and domestic financing
    has been complementary, rather than supplementary. The development
    of local financial markets has gone hand in hand with the inflow of
    foreign capital and the ongoing microlevel integration into the EU.
    As the graph shows there is a very strong correlation between
    domestic and foreign bank lending. Foreign investment in the
    banking sector and the capital markets has not only helped to
    develop the domestic financial sectors themselves, but also created
    a favourable business environment for further foreign capital
    inflows.

  • Monetary convergence: The success of economic
    policy in achieving sustainable monetary and fiscal stability
    depends strongly on the development of the financial markets.
    According to the Maastricht criteria on EMU accession, inflation,
    interest rates, budget deficit and debt levels in the CEE-10 should
    converge sufficiently with those of the best-performing EU member
    countries, and exchange rates have to be stable for two years prior
    to EMU accession. Underdeveloped capital markets and banking
    sectors could endanger fiscal stability and monetary policy
    efficiency. For example, budget deficits could increase due to the
    bailing-out of banks, and weak monetary transmission could hamper
    the stabilisation efforts of monetary authorities.

There is no normative blueprint for
well-developed financial markets. There are major differences
between the EU member states and the US, for instance, in terms of
financial indicators. In addition, international and EU financial
market regulations ensuring the development and stability of
financial markets are continually subject to change. Nevertheless,
the evaluation of the financial markets in the CEE-10 against
financial market indicators in the EU and against the fulfilment of
the present financial sector acquis communautaire can serve as a
useful measure of how well the CEE- 10 are prepared for the
challenge of EU and EMU accession.

In the CEE-10, the banking sector plays a
distinguished role. Coming from a mono-bank system with no capital
markets, most countries adopted a universal banking system in the
1990s. In this system, individuals keep their savings mainly in
banks, which are the primary source of external financing for the
private sector. Banks are also the dominant investors in the equity
and corporate debt markets.

Partly because the capital markets were
developed from scratch and partly due to the more demanding legal
and institutional prerequisites for securities markets, these
segmen ts have remained relatively underdeveloped in all transition
economies. Given the importance of the banking sector in the
CEE-10, this article will concentrate on the development of banking
in the region and the likelihood of these banks to fall into
crisis.


Rehabilitation and recapitalisation of the banking
sector as first step towards stability

Following the introduction of a two-tier banking
system, i.e. the separation of central-bank and commercial-bank
functions mainly between 1989 and 1992, the major task in the
banking sector of the CEE-10 consisted in the rehabilitation of the
banks. The new commercial banks had inherited a sizeable volume of
nonperforming loans (NPL) in their portfolios. In order to cope
smoothly with their most important economic function (financing of
investments) they had to be relieved of bad loans and recapitalised
as soon as possible. The common way to do so was to transfer the
bad loans to a state-owned consolidation bank in exchange for newly
issued government bonds. In order to stabilise the banking systems
and to prevent future problems measures had to be taken such as the
introduction of capital adequacy regulations and deposit
insurance.

However, banks in most countries experienced the
accumulation of new NPL and a second or even third wave of banking
crises. The main factors behind this were lax licensing
requirements, insufficient banking regulation and failures of
implementation, and low accounting standards and supervision. This
was worsened by the lack of lending experience, politically
motivated lending to insolvent state-owned enterprises and insider
abuse.


Non-performing loans still sizeable

The cleaning-up of banks’ balance sheets
extended over most of the nineties and has not yet been completed
everywhere. In the CEE-10 bad loans today still total an estimated
average of 15% of total loans, but large differences are hidden
beneath this average figure. Estonia is on the brightest side: its
share of only around 2% of total loans is a benchmark for other
countries. The situation is also relatively good in Slovenia and
Latvia (5% and 6% of loans, respectively), followed by a
middle-ranking group of Hungary, Bulgaria and Poland. Slovakia made
a big step forward by transferring bad loans from the three big
state-owned banks to the Consolidation Bank at the end of 1999. The
cost, however, has been the worsening of its budget problem. Things
are similar in the Czech Republic. A significant amount of bad
loans was transferred to the Consolidation Bank in 2000. Romania
ranges at the bottom end of the scale (bad loans: around 35% of
total loans); it is particularly striking that the flagship
Bancorex Bank (Romanian Bank for Foreign Trade) had been
recapitalised five times before the government finally decided to
liquidate it. Asset share of

most countries. Hungary, for instance, spent
more than 10% of its GDP in three rounds of banking-sector
rehabilitation. In Slovakia, cleaning up the banking system has
even cost at least 11% of GDP so far, and an additional 1.1% of GDP
is earmarked for bank restructuring in the 2002 central budget.
Latvia Estonia


Bank privatisation almost completed

The privatisation of banks in the CEE-10 was
speeded up in recent years, but has not been completed yet.
Privatisation usually follows rehabilitation, both of which have
been realised to a different degree in the CEE-10. However, all the
countries surveyed hoped for strategic foreign investors in the
field of bank privatisation. This is particularly the case in
Estonia and Latvia, whose banking systems have been privatised
nearly completely by now. Hungary’s banking sector has been
privatised to more than 90%. Poland scores somewhere in the middle
of this ranking but is currently catching up with the top group;
its banking privatisation has advanced significantly over the last
two years. Poland – and since the economic and banking-sector
crises in 1997 also Bulgaria – have reduced the state’s share in
the banking system to less than 25% and are now preparing to go
beyond this. Yet political problems persist with regard to the sale
of PKO, the public savings bank and Eastern Europe´s biggest bank
by assets.

After the voucher privatisation in the first
half of the 1990s, the Czech Republic kept substantial minority or
majority shares in three of the four largest banks. As a
consequence, around one-quarter of the Czech banking sector
remained state-owned for a long time. The sale of the remaining
government shares in private banks started only in 1999. In June
2001, a 60% stake in Komercni Banka (the country´s second largest
bank by assets) was sold, and this was the last chapter in Czech
bank privatisation history. The privatisation of Slovak banks has
been delayed due to the same reasons as in the Czech Republic.
Until the end of last year approximately half of the Slovak banks
were still state-owned. But private ownership of Slovak banks will
rise strongly as a result of the almost complete take-over of two
of the large institutions, Slovenska Sporitelna and Vseobecna
Uverova Banka (VUB), by foreign investors under agreements
concluded in January 2001 and early July. Last in the ranking is
Romania, where half-hearted and inconsistent policy has so far
prevented a better result. While Slovakia has good chances to
successfully complete the privatisation process of the banking
sector during the year 2001, Romania will still need several
years.


Important role of strategic foreign
investors

The earlier and more decisively the EU accession
countries have opened up to foreign strategic investors, the more
efficient their respective banking systems have become. The
financial strength, know-how and expertise of Western banks
concerning business line management, marketing, risk management,
product development and technology have been essential for the fast
and stable development of the banking sector.

Consequently, Estonia and Hungary already have
relatively well developed, stable banking systems, and Poland as
well as the Czech Republic should catch up soon. In almost all
major CEE-10 countries more than 60% of banking assets are now held
by foreign groups. This provides these countries with close ties to
Western banking systems. In Bulgaria, even more than 80% of the
banking sector is now foreign-owned, according to Svetoslav
Gavriiski, president of the Bulgarian central bank. This
development will facilitate EU integration for the above-mentioned
countries. After privatising its banks, Slovenia should be able to
catch up with this group. The remaining countries are still lagging
behind, but the restructuring of the banking systems there is on
track.

This rough evaluation is given support if the
continuing active presence of international financial institutions
like the European Bank for Reconstruction and Development (EBRD) is
considered as an indicator of underdevelopment. The EBRD has
basically withdrawn from Hungary and Poland – except for some
specific sector financing – as the private sector can now do the
financing itself. On the other hand, the EBRD is still actively
present in the least developed members of the CEE-10, indicating
the reluctance of foreign private investors to enter these
markets.


Consolidation of the banking sector: old and new
driving forces

Since the beginning of the transition, the
banking sectors in the CEE-10 have gone through a substantial
consolidation and concentration process. This process has been
driven by four main factors:

1. The regulatory environment was tightened
substantially. As a result, the early nineties saw the start of a
major consolidation of the banking systems of the candidat e
countries, which eliminated banks unable to survive in the longer
term and which helped to approach the optimum banking size and
structure. The most extreme examples are Latvia and Bulgaria,
where, following banking crises in 1995 and 1997, respectively, the
number of banks dropped by more than 30%. After banking crises in
Lithuania in 1995, 20% of the Lithuanian banks were liquidated or
their operations suspended by supervisory authorities.

2. Central and Eastern European economies have
typically been characterised by small banking systems relative to
EU standards, with a high degree of systemic fragmentation. There
were, and still are, many institutions which lack adequate
financial fundamentals and work with high administrative costs and
low efficiency. Stiffer competition for low-risk corporate clients
and the need to cut costs in the over-banked environment have been
a major reason for banks to merge. Increasing competition was
largely responsible for the recent consolidation wave in the
banking sectors of Hungary and Slovenia. As a result, concentration
in the banking sector of Hungary is high, with five banks holding
more than half of the total bank assets. The number of banks in
Slovenia has also decreased sharply: from 41 at end-1995 to about
30. Nevertheless, both countries are still broadly considered to be
over-banked.

3. The consolidation process has been
accelerated by the recent world-wide wave of mergers and
acquisitions, which was especially strong in the EU in the context
of the introduction of the single currency. Consolidation has been
observed both inside the candidate countries and in the form of
cross-border mergers and acquisitions. Given that a large
percentage of the CEE-10 banking assets were acquired by Western
European banks, it is natural that M&A activity in financial
services has been among the most busy segments (see table). The
most striking example of an “externally driven” consolidation
process in the Eastern European banking systems is Estonia, where
the number of commercial banks shrank from 42 at end-1992 to only 6
to date. The Estonian banking sector is extremely highly
concentrated.  

4. Most recently, preparing for EU accession –
the adoption of stricter legislation, regulations and supervision
conforming with EU standards – has been one of the most powerful
catalysts of M&A activity in the region. For example,
compliance with higher capital requirements can be achieved by
merging with other banks.

In the next two to five years, combined pressure
from increasing competition, international M&A trends and EU
integration should lead to the acceleration of the consolidation
process. This can be demonstrated with the example of the CEE-3
(Czech Republic, Hungary and Poland), where consolidation has been
driven jointly by the last three factors mentioned above.


Financial intermediation: still much to be
desired

Although the banking sector has a clearly
dominant role over capital markets in satisfying the financial
needs of the productive sector, financial intermediation is still
very shallow in the CEE-10, i.e. the ability of the banking sector
to channel the financial savings of enterprises and households into
private investment is limited. Measured in terms of bank loans as a
percentage of GDP, the banking sectors in the CEE-10 are highly
underdeveloped compared to EU standards (see table below).

Even in the most advanced countries, like
Hungary, Poland and the Czech Republic, the outstanding amount of
loans to the private sector does not exceed 50% of GDP, which is
not much for countries with a universal banking system. Moreover,
the average amount of commercial banks’ claims on the private
sector per capita is only 15% of that in the European Union member
states, even in purchasing-power-parity (PPP) terms.

High real interest rates – indicating the cost
of capital – ca nnot be blamed for the lack of borrowing. Real
lending rates (calculated as nominal rates minus inflation) are
only 100-150 bp higher on average in the CEE-10 than in the EU
member states. The shortfall seems more likely to be the result of
excessive lending for some years followed by a credit crunch and
extreme risk aversion after the collapse of several financial
institutions and the tightening of both monetary policy and
prudential rules applicable to asset classification, valuation of
collateral and provisioning. This view is supported by figures on
the historical development of lending activities at least in some
CEE-10 countries.

Yet, the low level of savings and bank deposits
is also responsible for the lack of lending. Candidate countries
save a slightly smaller part of their GDP (21%) than their EU
counterparts (22%; see table next page). Low savings in the CEE-10
can be only partly explained by the difference in per capita GDP.
Of course, poorer countries tend to have lower saving rates, since
basic needs have to be satisfied from smaller disposable incomes.
However, the lack of banking tradition and confidence in the
financial system has also contributed to the unwillingness to save.
This is reflected by the fact that bank deposits per capita (in PPP
terms) are just 18% of the EU average. One explanation could be
that people invest their savings on the capital markets, thus banks
“collect” only a limited share of the gross savings. However, the
insignificant domestic participation on the capital markets
suggests that most of the disposable income which is left over
after consumption is still “kept under the mattress” or reinvested
individually, rather than channelled to the most efficient
investment opportunities either via the banking system or the
capital markets. Growing confidence in the financial system and
improved macroeconomic stability should attract more and more
savings into the financial sector in the years to come. However,
the future distribution between the banking system and other
segments of the financial markets remains unclear from today’s
point of view.


Banking systems in the CEE-10: prone to
crises?

In the run-up to EU accession, it seems
appropriate to closely monitor the stability of the financial
sectors in the CEE-10. Despite the benefits of stronger financial
integration into the EU, financial liberalisation and the greater
exposure to external financial market developments increase the
vulnerability of the banking sector in general. The stronger
linkage across markets and volatility in capital flows may
precipitate or trigger rapid contagion and thus increase the
probability of systemic difficulties. The international
ramifications of the Mexican liquidity crisis beginning in 1994-95,
the East Asian financial crises of 1997-98, the Russian financial
crisis of 1998, and the Brazilian financial crisis of 1999 are good
illustrations of this phenomenon.


Past experience with banking crises …

In the early stage of transition the major
region-specific causes of banking crises in the CEE were
non-performing loans (NPL) to state firms inherited from the
pre-transition period, continued pressure to extend credit to state
and former state enterprises, and an unstable macroeconomic
environment. As time goes by, however, the importance of these
transition-specific factors is fading and the situation in Eastern
Europe is becoming more similar to banking systems in other
emerging markets as well as Euroland economies. Following the
clearance of banks’ balance sheets, NPLs have become a problem for
the fiscal side rather than the banking sector; the majority of
formerly state-owned enterprises have been privatised and most
accession countries have an impressive record of macroeconomic
stabilisation.


… and future risks

For emerging markets in gene ral, theoretical
research has defined several factors which indicate the risk of a
banking crisis. Below we classify these indicators according the
level of risk they might represent in general for the EU accession
countries over the next five years. Of course differences exist,
especially in terms of financial and institutional risks. However,
as the date of EU accession approaches, converging economic
indicators and regulatory standards are likely to reduce the
remaining discrepancies.


Risks with decreasing or low relevance for the
CEE-10

  • 1. Macroeconomic risk factors:

  • Low GDP growth? We forecast positive and rather
    strong growth in the upcoming five years in all CEE-10 countries.
    The slowdown in the euro area and the world economy will dampen
    economic activity in the region, but potential growth rates are
    generally higher in accession countries than in the EU.
  • High and volatile inflation? The level and
    volatility of inflation are positively correlated, as higher
    inflation is usually accompanied by more uncertainty about future
    price developments. Given that inflation should fall throughout the
    region in line with monetary convergence with the EU, volatility
    should continue to decrease.
  • Decline in terms-of-trade? High trade deficits
    tend to accompany high GDP growth in emerging market economies.
    Strong productivity growth and increasingly diversified export and
    import structures in the CEE-10 reduce the vulnerability to
    terms-of-trade deterioration, caused for instance by the jump of
    crude oil prices.
  • Decline in export prices? The EU absorbs 60-80% of
    the exports of accession countries, and machinery and other
    highvalue- added products make up an increasing share of exports.
    The world prices of these products are relatively stable and the
    price elasticity of demand is rather limited.
  • High real domestic interest rates? The effort to
    fight stubborn inflation has often resulted in high real interest
    rates in accession countries, the most recent example being Poland
    in 2000 and 2001. Yet, as the date of EU accession approaches,
    inflation will fall further (except for countries where it is
    already close to EU levels) and catching up to EU levels in per
    capita GDP terms will become increasingly important. Therefore,
    real interest rates (nominal rates minus the inflation rate), or
    the cost of capital, should decrease as well. Equity & debt

    2. Financial risk factors:

  • Asset price declines? Stock markets have little
    impact on the domestic economy in the CEE-10 as market
    capitalisation is low, the largest listed companies are
    multinationals, and most equity is held by foreign portfolio
    investors. Therefore, even a large drop on the stock exchange would
    have an only limited effect on the local banking system. Other
    asset prices, e.g. real estate prices, are likely to catch up
    further to EU levels.
  • Large maturity/currency mismatches in bank
    liabilities?
    The Russian crisis and several banking
    emergencies gave a strong incentive in almost all the CEE-10
    countries to strengthen regulations in this area. Moreover, EU
    financial regulation and the new Basel II rules, which will most
    likely be adopted upon EU accession, deal extensively with the area
    of limiting concentration of risk exposures.
  • Fixed exchange rates? There is a widespread view
    that fixed exchange rate regimes increase the probability of a
    banking crisis. The link between pegged rates and surges in capital
    inflows exacerbates the problem of adverse external macroeconomic
    conditions. On the other hand, floating introduces an element of
    exchange rate risk that moderates capital inflows. Six of the
    CEE-10 have floating regimes or very wide flotation bands for their
    currencies. The exceptions are the Baltic states and Bulgaria – all
    small countries with relatively flexible labour markets, hi gh
    capital reserves and a supportive policy environment.
  • Inadequate preparation for financial
    liberalisation?
    Following liberalisation, capital flows
    tend to overshoot, thus increasing volatility on financial markets.
    Moreover, financial liberalisation releases pent-up demand for
    credit, and bank managers may not have the expertise to evaluate
    the risks in the new deregulated environment. Yet, most accession
    countries have already opened up their banking sectors and capital
    markets to foreign competition, i.e. foreign banks are present and
    banking knowhow has increased significantly.
  • Government involvement and loose controls on connected
    lending?
    Loan decisions of state-owned banks are much more
    likely to be subject to explicit or implicit government direction
    than those of privately owned banks. ” Connected lending” refers to
    loans extended to banks’ owners or managers and to their related
    businesses. The risks are primarily ones of lack of objectivity
    (sometimes even fraud) in credit assessment and undue
    concentrations of credit risk. However, most countries have nearly
    completed the privatisation of their banking sectors and have
    regulations on the maximum exposures that their banks can assume
    vis-à-vis a single borrower or connected set of borrowers.


Risks with high relevance for the CEE-10:

  • 1.
    Macroeconomic risk factors:

  • Expansionary monetary and fiscal policies?
    Transition costs (structural reforms, bailing out of banks and the
    costs of implementing the EU acquis), and the efforts to catch up
    to EU per capita GDP levels put continuous upward pressure on
    spending and downward pressure on central bank rates. That harbours
    risks, especially before important elections.
  • Large scale of private capital flows? Investment
    opportunities are vast in the accession economies as these
    economies will grow continuously and become more and more
    integrated with the EU economies. This naturally attracts large
    capital inflows. Moreover, EU accession requires complete capital
    account liberalisation, which increases the exposure to
    volatility.
  • Real exchange rate appreciation? We expect the
    candidates’ currencies to continue to be supported by the inflows
    of direct and portfolio investment. In flexible exchange rate
    regimes there have even been cases of nominal appreciation versus
    the EUR as a result of strong capital inflows. Given the inflation
    difference between the accession countries and the euro zone this
    results in real appreciation (except for Latvia and Lithuania).

    2. Financial risk factors:

  • Lending booms? Growth in lending has been low in
    most CEE- 10 countries since the mid-1990s, and mostly concentrated
    on the big creditworthy companies. High growth and an increasingly
    competitive banking environment are presently pushing banks to the
    retail lending sector (SMEs and households). The lack of experience
    in credit risk assessment and in building the appropriate
    regulatory framework carries the risk of over-lending cycles.
  • Lack of deep bond and derivative markets? The lack
    of deep markets can act as a handicap for banks which are in
    pressing need of liquidity. Derivative markets are also necessary
    so that banks can directly or indirectly hedge risk exposures for
    their borrowers.

    3. Policy and institutional risk factors:
     

  • Weaknesses in the accounting, disclosure and legal
    framework?
    Over the past few years, the accession
    countries made a big step forward with regard to the creation of
    the legal framework governing both the commercial banks’ activities
    and the institutions’ supervision of their compliance with the
    regulations. But as in the fields of bank rehabilitation and
    privatisation, the overall results achieved so far still fall short
    of the mark. Not all of the ten countries have issued regulations
    to an adequate degree that conform with EU and BIS requirements.
    While Estonia, Hungary and Lithuania deserve praise in this
    respect, Poland, the Czech Republic, Latvia and Slovakia still have
    shortcomings with regard to the requirements. A further problem is
    to put the new legislation into practice. Implementation is still
    very weak in Slovakia. A major reason is that the legal framework
    has been amended many times, thus creating uncertainty. For the
    same reason, the enforcement of the new legislation is questionable
    in the Czech Republic. Here too, Estonia and Hungary stand in
    positive contrast to other countries. The implementation of
    supervision is as far ahead as that of regulations in these two
    countries. So far, the good progress during the past few years
    concerning the establishment of the necessary institutions has been
    the greatest success. It is unsatisfactory, however, that in some
    countries supervision is not (yet) consolidated. Moreover, the
    political and financial independence of the supervisory agencies is
    not secured. Especially in Romania, effective banking supervision
    remains constrained by political interference. Even Estonia and
    Hungary face the same problem. Moreover, even if all countries
    surveyed have established a deposit insurance system, it has been
    extended only to reputable institutions and not (yet) to all
    banks.


Summary and conclusions

  • Well-developed financial systems play a crucial role for both
    real and nominal convergence. While foreign direct investment is
    likely to remain the prominent source of financing for the
    catching-up process, its volume will continue to be strongly
    correlated to the development of domestic financial markets. Strong
    foreign investment in the banking sectors and capital markets of
    many CEE-10 countries have enhanced the domestic financial sectors
    and created a good business environment for further foreign capital
    inflows.
  • The banking systems in most candidate countries are highly
    integrated with the EU market through the prominent role played by
    foreign (and predominantly EU) banks in these markets. After the
    rehabilitation and privatisation of local banks, consolidation and
    integration will be the main driving forces of banking sector
    development in the coming years. The cleaning-up of banks’ balance
    sheets and the privatisation process should be finished in the next
    two to three years.
  • According to most conventional indicators, the banking systems
    in the CEE-10 lag far behind the EU average. The banking sector is
    still playing only a small role in the intermediation of savings
    and loans. However, striking differences exist between the
    individual countries. For example, credit claims on the private
    sector average 91% of GDP in the EU, while they vary between 7 and
    almost 50% of GDP in the CEE-10. However, there is no normative
    blueprint for well-developed financial markets and EU averages are
    not necessarily the best benchmark for the CEE-10.
  • In most CEE countries there is a sizeable gap between gross
    national savings and bank deposits. The large amount of money
    remaining outside the banking system is either directly reinvested
    in existing businesses or kept “under the mattress”.
  • Growing confidence in the f inancial system and a record of
    macroeconomic stability should attract more money into the
    financial sector. However, the distribution of these resources
    between the banking system and the domestic capital markets remains
    unclear.
  • Risks to the stability of the banking system are manageable
    today. In the early stage of transition the major region-specific
    causes of banking crises in the CEE countries were nonperforming
    loans (NPL), continued pressure to extend credit to state
    enterprises, and an unstable macroeconomic environment. NPLs and
    their fiscal fall-out are still a problem – adding up to an
    estimated average of 15% of total loans in the CEE-10 – but have
    largely become a fiscal problem instead of a systemic risk.
  • There are two groups of factors that could, if they emerge at
    the same time, lead to a financial crisis in an accession country.
    Structural deficiencies, i.e. low accounting standards or the lack
    of deep derivative markets, still hinder the proper functioning of
    the banking sector. Even more importantly, new risks linked to the
    catching-up process have occurred, e.g. lending booms to households
    and SMEs under conditions of weak accounting and risk
    assessment.

 

 

 

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