CENTRE

Jun 10 2021

Netherlands: Dutch Approach to Crowdfunding May Compel Platforms to Operate Elsewhere in the EU

Last year, the European Union agreed upon pan-European crowdfunding rules designed to harmonize the environment for online securities offerings across all member states. Currently, each member state handles online capital formation in a different manner, regulated by national authorities thus undermining the potential for cross-border securities offerings and more efficient funding rounds. The harmonization has been described as a big win for the investment crowdfunding industry and issuers may soon raise (November) up to €5 million from 28 different member states with the backing of retail investors.

As the regulation states, any “European Crowdfunding Service Provider” or “ECSP” must receive regulatory approval from the “national competent authority” (NCA) of the member state in which they are established to list securities offerings. ECSP’s will then be able to compete across the EU and provide cross-border crowdfunding services via a notification procedure.

Supervision will be carried out by national authorities and with the European Securities and Markets Authority (ESMA) coordinating cooperation between EU member states.

At the end of last month, ESMA closed a consultation on regulating ECSPs with an expectation that standards will be adopted by the European Commission on November 10, 2021, with some additional standards following on May 10, 2022.

While the objective clearly makes sense and aligns with the mission of a single market, nuances within each individual jurisdiction may make some member states less desirable than others for ECSPs to operate and issue securities.

This past week, the Netherlands issued draft plans for the implementation and execution of crowdfunding. The approach by Dutch regulators may make the country less competitive when it comes to online capital formation be it equity offerings or debt financing, at least according to one industry insider.

Ronald Kleverlaan, Chairman, Stichting MKB Financiering & Director of the European Centre for Alternative Finance at Utrecht University, is an individual who is deeply engaged in the ECSP regulatory process. He shared his thoughts on the Dutch proposal with Crowdfund Insider:

“As mentioned [recently], the Dutch Ministry of Finance has published their proposal for implementing the ECSP regulation in Dutch Financial law. Most shocking is the (high) costs for crowdfunding platforms to apply for a license.

Costs for a crowdfunding platform can be up to €100k, excluding legal advisory costs. This is only for the (one-time) application process. On top of this, additional yearly costs are expected.

Because ECSP regulation is a European regulation, these high supervisory costs could mean that Dutch crowdfunding platforms will apply for a license in another country and still offer their services in The Netherlands.”

The Netherlands is not alone in taking a regulatory approach that may stifle crowdfunding platforms in the EU. Germany has announced regulations that have been panned by industry insiders.

As it stands now, certain liability rules for platform principles and the fact that GmbH shares (limited liability firms) are not included in the rules, Germany may hobble investment crowdfunding in Europes largest economy.

Last month, Uli Fricke, Deputy Chairwoman of the German Crowdfunding Association (Bundesverband Crowdfunding), stated:

“The current implementation of the SchwarmfinanzierungsbegleitG contradicts the goal of the ESCP-VO and puts German companies at a disadvantage compared to their European competitors. In essential points, the proposals of the grand coalition contradict the idea of the ECSP regulation: to create uniform conditions for companies that can carry out crowdfunding campaigns across Europe.”

At that time, a report in the Frankfurter Allgemeine labeled the German policy a “disaster” stating that “what the EU gives, the [German] federal government takes [away].”

Of course, individual member states enacting policy that stifles an emerging industry may benefit other countries that are more interested in boosting entrepreneurship and facilitating capital formation. Some industry insiders see an opportunity for scrappy baltic states, or other EU countries, to benefit from an opportunity for regulatory arbitrage.

It is not completely clear as to why certain EU countries may create rules counter to the spirit of the goal of harmonization and the single market. Perhaps in Germany, federal authorities are still feeling the pain of the spectacular collapse of Wirecard – once a vaunted Fintech and now no more having imploded due to fraud. Or maybe public officials simply do not have the experience or knowledge of the venture capital sector to understand its key function in raising funding for early-stage ventures and supporting entrepreneurship.

As the ESMA is still working through its role as a European regulator of ECSPs, things can still change. Or maybe more agile countries will step it up and decide to play a bigger role in the securities crowdfunding sector.

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May 05 2021

Flubot vs. Zimperium

Over the past few weeks, reports of the newest aggressive malware family to impact Android devices have made the rounds. Flubot, the credential and banking malware family, uses SMS phishing techniques to propagate to its victims, purporting to be various vendors and delivery services. The group behind this aggressive malware takes advantage of a common but effective social engineering technique.

The Zimperium zLabs team has analyzed over 300 variants of Flubot and the URLs used to distribute them, finding that the aggressive credential stealer comes with unique features that make it stand out from many other examples of mobile malware seen in the past. The Android malware has been so effective, the UK’s National Cyber Security Centre has issued a cybersecurity warning, providing instructions for removal and reporting of any attempts.

The modern bank robbery is not happening through the front door of a building but with the path of least resistance – banking credentials. Flubot’s credential theft effectiveness comes in the form of its delivery and execution. The victim’s phone receives an SMS, instructing them to click a link to track their “package” via one of the known global shippers. The victim is redirected to a fake or compromised website where the malicious APK is downloaded and installed via side loading. The user wants to track their package and installs the application via side-loading onto the Android device – even walking the victim through the process if unfamiliar.

After installation, a window appears asking for the victim to “Accessibility Services” (a restricted capability allowing monitoring and interaction with all apps/screen content) for the application, enabling the now-installed application to take control without the user even knowing. Once the application has this permission, it uses it to get others such as READ_SMS, RECEIVE_SMS, and READ_CONTACTS. The app registers itself as the main SMS client, which will be later used to steal 2FA credentials.

A key component of credential-stealing malware is an effective command and control (CNC) capability, giving the attacked the ability to grab what they want and not be flooded with untargeted data. In the case of Flubot, the CNC backend is not hardcoded into the malware itself. Instead, it uses a Domain generation algorithm (DGA) – common in advanced desktop malware to generate the CNC URL server address. This enables Flubot to continue to evade its victim’s mobile endpoints if a security team was to block one single address.

Its effectiveness on mobile endpoints is made more so by Flubot’s capability to automate actions. After disabling Google Play Protect, the Android malware then asks to be set as the default SMS and notification tool, enabling it to continue spreading to more victims by collecting contact lists and preventing the victim from seeing the actions. From the moment the malicious application is installed, it also begins monitoring all the applications installed in the device. When a targeted application is opened, Flubot performs an overlay attack to collect user credentials and send this data back to the CNC. At the same time, Flubot uses SMS permissions to read second-factor authentication codes.

One final and very effective trick Flubot pulls on victims is collecting credit card information via a fake Google Play credit card re-verification popup. This is again performed as an overlay attack, looking just like the real popup notification. The unsuspecting victim is encouraged to fill in the necessary details without a second thought.

Flubot vs. Zimperium

Zimperium zIPS customers are protected against 100% of the Flubot variants analyzed with our zero-day, on-device z9 Mobile Threat Defense machine learning engine.

As a standard protocol, the Zimperium zLabs team checks new malware samples against not only the current machine learning model but past ones as well. In the case of Flubot, Zimperium zIPS customers were protected against this aggressive credential stealing Android malware since the first variant was first reported in February 2020.

The screenshot above highlights how Flubot samples are detected with extreme accuracy by different releases of our on-device malware classifier. In the Figure, classifiers up to 3 months back in time are displayed, but samples were detected by classifiers going back over one year.

Zimperium’s z9 malware engine is also able to correctly identify the family of malware (“banker” in this case) on device, allowing customers to create policies around specific malware types, and provide supporting forensics.

The URLs used to deliver the APK consisted 80% of compromised domains (a legitimate website whose hosting server is compromised and a malicious site is stored on it), rendering most traditional phishing prevention techniques obsolete. All reported URLs were analyzed using Zimperium’s z9 ML-based phishing engine. In this case, z9 proactively blocked over 98% of the URLs, preventing the attack chain from its inception. This adds to the layer of protection and security coverage for our customers.

To ensure your Android users are protected from this latest malware, we recommend a quick risk assessment. Inside zConsole, admins can review which apps are side-loaded onto the device that could be increasing the attack surface and leaving data and users at risk.

Remediating a Flubot Infection on Android

Non-Zimperium Customers: If you have fallen victim to the Flubot malware on your Android device, immediate action is necessary to avoid more risks. First, disconnect the device from all connections, including cellular and WiFi, by putting the device into airplane mode. Next, the most effective way to remove the Android malware is through a factory reset. This will wipe the mobile device and load a fresh, clean version of the operating system. Do not restore from backup if it was created after the malware installation. Installing all your user applications fresh from Google Play ensures that you are downloading safe, approved, and secure apps. Finally, reset all your banking passwords, enable 2FA if possible, and notify your banks to increase monitoring on your account.

Not a Zimperium customer? Contact us today for a free mobile risk assessment.

About Zimperium

Zimperium, the global leader in mobile security, offers the only real-time, on-device, machine learning-based protection against Android, iOS and Chromebooks threats. Powered by z9, Zimperium provides protection against device, network, phishing, and malicious app attacks. For more information or to schedule a demo, contact us today.

Flubot vs. Zimperium

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Apr 29 2021

Australian senate committee calls for national blockchain land registry

An Australian senate committee has published a report calling for a blockchain-based national land registry, better clarity over laws relating to smart contracts, and continued efforts to establish international standards for DLT.

The Select Committee on Australia as a Technology and Financial Centre’s second interim report offers 23 recommendations spanning blockchain, consumer data, and corporate taxation.

Five recommendations deal specifically with blockchain and digital assets, including that the Council of Financial Regulators Cyber Working Group takes into account international data standards.

The committee recommended that National Cabinet consider supporting a blockchain-powered national land registry as a pilot project for Commonwealth-State cooperation on “RegTech’ to highlight ways to streamline administrative processes in both the public and private sectors.

“The committee was particularly impressed with the potential for blockchain to drive efficiencies in the area of land registries, and is recommending that this issue be further explored in the context of the National Cabinet.”

Zooming out, the committee noted there was a need for more clarity and certainty in digital asset regulations, and highlighted concerns from industry stakeholders regarding “the uncertain status” of smart contracts under Australian law.

Despite hearing about the concerns, the committee didn’t hear many solutions:

“While the committee heard extensive evidence on the need for such regulation, it heard less on concrete ideas for how this regulation should best be crafted.”

Instead it recommended the Australian Government “consider how best to improve clarity with respect to the standing of smart contracts.”

The report called on the Department of Industry, Science, Energy, and Resources, or DISER, to publish regular updates on the progress of the National Blockchain Roadmap and to to review and update the roadmap as the space evolved.

Moving forward, the committee plans to review how capital gains are applied to cryptocurrency transactions, and give deeper consideration to the regulatory implications of central bank digital currencies and stablecoins during the final phase of its inquiries.

Australian senate committee calls for national blockchain land registry

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Dec 05 2020

How is Fintech Developing During COVID? The Global COVID-19 Fintech Market Rapid Assessment Study Answers Your Questions

The Cambridge Centre for Alternative Finance (CCAF) released a report this week entitled The Global Covid-19 Fintech Market Rapid Assessment Study. The report seeks to better understand the development of Fintech during a time of a global pandemic. The research was supported by the UK Foreign, Commonwealth and Development Office (FCDO) and the Ministry of Finance of Luxembourg.

Produced in partnership with the World Bank and the World Economic Forum, the study tallied responses from almost 1400 Fintechs around the world. While the results are interesting to anyone engaged in financial services, policymakers and regulators should find the study particularly useful as they look to enable access to services that help consumers and businesses in an economy that is in the midst of a profound digital transformation.

Bryan Zhang, co-founder and Executive Director of the Cambridge Centre for Alternative Finance, stated:

“This study reveals a global Fintech industry that has been largely resilient in spite of COVID-19. Nonetheless, its growth must be interpreted with nuance and in the context of unevenness, and the opportunities for the industry should be juxtaposed with the challenges it faces.”

COVID-19 is accelerating change in how people interact with financial services said James Duddridge MP, the UK’s Minister for Africa at the Foreign, Commonwealth & Development Office (FCDO).

“Whilst it is encouraging to see the growth reported by Fintechs in the study, there are also cautionary indicators that some firms are suffering a deterioration in their financial position and are concerned over their ability to raise capital in the future,” said Duddridge. “This is something that the Fintech community should be mindful of given the significant economic opportunities that Fintech presents.”

In a public statement by CCAF, the authors noted that 60% of surveyed firms have either launched new products or revamped existing ones. However, the growth is highly uneven and Fintechs are still facing significant headwinds from certain operations as well as fundraising.

Regulation is key. The study states that there is a need for more regulatory and governmental support in light of COVID-19.

Overall, 12 out of 13 Fintech sectors reported year-on-year growth for the first half (H1) in 2020, compared to the same period in 2019, prior to the pandemic. On average, firms reported growth in transaction numbers and volumes of 13% and 11%, respectively. The impact of COVID-19 on market performance was found to be uneven across industry sectors, geographies and depending on the levels of economic development as well as COVID-19 stringency in a given jurisdiction.

Digital Payments, Digital Savings, Wealthtech, and Digital Asset Exchanges, all reported year-on-year growth in transaction volumes in excess of 20%, whereas Digital Banking, Digital Identity, and Regtech sectors showed more modest growth increases around 10%.

The only sector reporting a decline during the period was Digital Lending, which saw an average 8% decrease in transaction volumes.

Growth of Fintech in Emerging Markets or Developing Economies (EMDEs), saw an average increase in transaction numbers and volumes of 15% and 12% year prior. This is compared to 11% and 10% for firms from Advanced Economies (AEs).

Geographically, the highest transaction growth regions were the Middle East & North Africa (MENA) (40%), North America (21%), and Sub-Saharan Africa (21%). This contrasts the 13% transaction growth seen in Latin America and even slower growth in Europe and the Asia-Pacific region.

The data indicates that Fintech markets with high stringency COVID-19 lockdown measures averaged transaction growth 50% higher than those in low stringency countries.

While growth remains positive, COVID-19 still presents external risks for Fintech firms, as well as the operational and funding challenges. Approximately 40% of firms surveyed indicated that they have either introduced or are in the process of introducing enhanced fraud or security measures as a response to business conditions under the pandemic.

Other operational challenges include a 4% increase in agent or partner downtime and a 6% increase in unsuccessful transactions, queries or access requests. Fintechs also reported a 6% in expenses related to onboarding and a 9% rise in data storage expenditure.

Caroline Freund, World Bank Global Director for Finance, Competitiveness and Innovation, noted that Fintech has shown its potential to close gaps in the delivery of financial service.

It’s clear COVID-19 has disrupted the global economy with lasting implications for corporates and consumers added Matthew Blake, Head of Financial and Monetary Systems, World Economic Forum.

Crowdfund Insider had some additional questions after reviewing the report. First and foremost, where does establishment finance stand in all of this. Are they falling behind? Are they keeping pace?

Karsten Wenzlaff, co-author of the Study, and Research Affiliate, CCAF & Alternative Finance Researcher at the University of Hamburg, said:

“Since this study was specifically focused on Fintech activity, we did not capture their data since it was out of scope. However, what we can see is that Fintechs are increasing their collaboration with traditional finance stakeholders and vice versa. COVID-19 has pushed these two groups closer together rather than pushing them further apart. This study, and previous CCAF research, have highlighted the increasing synergies between the traditional and the ’alternative’; and this trend seems to persist.”

The agility of Fintechs has long been a key characteristic in the ability of these firms to quickly pivot and adapt. So is it correct to assume that digital-first finance that iterates quickly is beneficial for both consumers and businesses. Is that correct to assume?

Tania Ziegler, Lead of Global Benchmarking-CCAF, Lead Author of the study, concurred:

“Yes, I would think so. We see a lot of added functionalities and new tools being experimented with. Our study found that more than two thirds of all Fintechs surveyed had made at least two or more changes to their existing product suite, and around 60% had also introduced or launched at least one new product! Certainly, COVID-19 has shown that FinTechs are not shielded from large shocks, but at the same time can pivot their processes, terms and products very quickly.

While agility can be beneficial it is always a balancing act when it comes to regulatory requirements. As was noted in the report, Fintechs need more support from policymakers. So are regulators a bottleneck when it comes to change? Are the people in positions of power creating too much regulatory friction?

Ziegler diplomatically said yes:

“As shown in the Global COVID-19 Fintech Regulatory Rapid Assessment Study that was conducted in parallel by the CCAF and World Bank, we know that regulators globally are trying to evaluate and implement new tools, such as sandboxes and innovation offices, as well as support core regulatory activities. That said, our market study did find that on balance, most Fintech verticals had not yet received regulatory support. Overall, most firms reported urgently needing ‘faster authorization for new activities’ followed by streamlined product or services approvals, and then those which face client onboarding – simplified CDD, support for remote onboarding, etc. Now, interestingly firms in Emerging Markets tended to already utilise regulatory support more than those in Advanced economies, yet they also reported ‘urgently needing’ support at much higher rates. The study found that nearly half of all firms in EMDEs urgently needed regulatory support, with particular emphasis on faster authorization (just shy of 50%) and streamlined approvals (40%).”

Another challenge is fragmentation. Different firms providing similar services can interact with users, as well as other firms, if there is a consistent rule book to follow. We asked the report authors if any best practices are emerging from around the world and what should policymakers do to manage this challenge.

Ana Fiorella Carvajal, Lead Financial Sector Specialist at the World Bank Group, said indeed this is critical:

“… policymakers [must] strike the right balance so that they do not stifle innovation, but at the same time ensure that consumers are protected, and that financial markets remain sound. And precisely the best way to do that is by looking at the risks embedded in the activities that Fintech firms conduct as the guiding principle to determine the level of regulation and supervision that would apply to them. So, rather than a one-size-fits-all approach, the idea is to have a regulatory approach that is tailored to the type of activities conducted and proportionate to the risks they entail. This means, for example, that the approach and regulatory requirements that would apply to a Fintech in the digital payments space would be different than those that apply to an equity crowdfunding platform, because the activities are different and so are the risks.”

Ziegler said that interestingly, the study is not suggesting greater fragmentation of the Fintech industry. Rather, they are observing Fintechs broadening their customer base, and establishing new ways of operating.

“On balance, firms are making changes to their existing products and services, and launching new ones, at fairly high rates. Changes to existing activities tend to focus on how they engage with their existing and new customer base, mostly to make processes easier or to change their pricing structures. Changes to the way that firms processed their fees or positioned their pricing structure were among the top tweaks – in the face of COVID-19 firms have had to be flexible with their payment terms. We also observed firms releasing new services or launching new products. In some cases this was adding new components to existing offerings, and in other cases this was launching totally new streams. Where it relates to the latter, this is where regulators may have to become more reactive, to create faster or more efficient ways for firms to license new products or streamline their approval processes to reflect the increasing demand from new users.”

She added that firms in emerging markets tend to already utilise regulatory support more than those in advanced economies, but they also reported better/faster support at much higher rates.

“We found that these firms urgently needed regulatory support on faster authorization (just shy of 50%), streamlined product or service approvals (40%) and regulatory support for e-KYC (39%).”

So what should policymakers do, in general, to encourage innovation while maintaining sufficient protection protocols?

Carvajal said that while the individual measures are country-specific, in general policymakers need to work on two main fronts:

(i) expanding and improving the financial and technological infrastructure of the country, and

(ii) implementing legal and regulatory frameworks that support the delivery of digital financial services, along with the tools to monitor and supervise FinTech activities as appropriate.

“With regard to the latter, it is critical that such frameworks are proportionate to the risks posed by Fintech so that they don’t stifle innovation, but at the same time ensure that risks to consumer protection, integrity and financial stability are well managed,” Carvajal stated.

Ziegler explained that they have seen that Digital Payment firms have been the biggest beneficiaries of the most proactive regulatory support with a focus on e-KYC:

“Despite this, the study did show us that Fintechs, in general, are not yet able to benefit from additional regulatory support, especially as it relates to client onboarding, authorization and licensing for new products, or streamlined approval processes. From the Regulatory study, we found that none of the surveyed Regulators had any plan to stall innovation initiatives, such as Sandboxes or Innovation offices. But what our study really pointed to is that firms aren’t placing an emphasis on regulatory innovation tools, but rather core-regulatory support or supervisory procedures. In order for them to service their clients, their needs relate far more to day-to-day, but highly critical, core regulatory support,” Ziegler explained.

The report may be downloaded here or it is available below.

CCAF The Global Covid-19 FinTech Market Rapid Assessment Study v0_5

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Dec 01 2020

Cambridge Centre for Alternative Finance, World Bank and World Economic Forum Present Global Study on COVID-19 Impact on Fintech

The Cambridge Centre for Alternative Finance (CCAF), along with its partners the World Bank and the World Economic Forum, hosted a presentation this week outlining its findings in a study reviewing the COVID-19 pandemic and its impact on the Fintech industry.

The survey was launched several months back when it became clear that COVID-19 was quickly becoming a global health crisis compelling lockdowns and remote work in an attempt to slow the spread of the highly infectious disease. Fintech platforms have been dramatically impacted by the coronavirus with many experiencing accelerated growth as part of the overall digital transformation occurring in financial services. The Global Covid-19 Fintech Market Rapid Assessment Study surveyed approximately 1400 Fintechs operating in a diverse range of financial services to gauge how the pandemic has impacted digital financial services firms. The CCAF survey held three specific goals:

First, the research looked at the impact of the global pandemic on Fintech markets – understanding how Fintechs are performing financially based on their operating model and jurisdiction among other criteria
Second, they studied the responses of these organizations in shifting their products and operations throughout the pandemic – seeking to understand how these companies are dealing with remote working measures and a more digitized economy
Finally, to identify issues Fintechs are facing on a regulatory front

As one may anticipate, the Fintech industry is performing pretty well during the health crisis with the singular exception of online lending that saw an 8% decline in activity when comparing H1 2020 to H1 2019. CCAF reports that this sector experienced an approximate 10% increase in defaults as borrowers struggled as the coronavirus spread – understandable in light of the economic challenges.

According to the report, the top sectors of Fintech in regards to percentage growth in transactions are as follows:

Digital custody – 36%
Digital asset exchange – 33%
Digital savings – 26%
Wealthtech – 24%
Digital payments – 21%

Anecdotally, there have been some prominent examples of the rapid rise in Fintech services as consumers and businesses were forced to adapt to a new way of existence. Digital payments that are contactless is a clear winner. The Robinhood phenomenon has enticed a new generation of investors to trade online.

Regarding how the various regions are performing the UK was the only sector that saw a transaction volume decline – perhaps due to the oversized impact of digital lending. Otherwise, all other reviewed regions experienced an increase led by the MENA region (Middle East North Africa) rising by 40% and followed by North America and South America (both increasing by 21%).

It is interesting to note that jurisdictions that experienced more stringent COVID protocols such as remote work requirements and business closures, saw higher digital finance transactions. CCAF said that “the higher the COVID-19 stringency, the higher the adoption of Fintech services. The increased adoption is not necessarily caused by the pandemic, but there is a direct correlation between strict lockdowns and increased adoption of Fintech services.”

Many Fintechs launched new products or adjusted services due to the pandemic, adjusting product supply as demand increased or changed.

Regulatory challenges remain a hurdle as many Fintechs indicated they are in need of more regulatory support and faster approvals for financial services.

CCAF said that retail facing Fintechs, in particular Digital Payments, Lending, and Banking, were among the most agile verticals to implement changes to their offerings with a vast majority making changes.

Regarding capital formation, CCAF reported that approximately 40% of “Digital Capital Raising Platforms” indicated that they had been hosting COVID-specific offerings – something Crowdfund Insider has reported on in the past.

One area that may be viewed in a disappointing light is that government entities have been slow to leverage the agility of Fintechs to deliver services during COVID as some governments instituted business support programs to backstop the sliding economy.

A panel followed the presentation of the data generated by the survey with some interesting comments emerging.

Blythe Masters, the former CEO of Digital Asset – now at Motive Partners, noted that while the US is a highly developed country there are still 55 million people or 22% of the population that are unbanked or underbanked. A pretty astounding number. Regardless, Masters said that COVID has accelerated digital transformation in financial services by at least 5 years and perhaps up to 10.

Jon Frost, Senior Economist, Innovation & the Digital Economy, Bank of International Settlements, added that there is a risk of a digital divide and there is some work that needs to be done – alluding to the fact that certain demographics or regions lack access to digital financial products.

Fragmentation in products, more specifically Regtech, is inhibiting growth, said Robert Wardrop, co-founder and Director at CCAF.

Ana Fiorella Carvajal, Lead Financial Sector Expert at the World Bank Group, said please streamline the regulation and provide faster authorization – especially in emerging markets.

And what about the growth in digital assets and digital custody? Masters believes that a maturing industry with more institutional involvement is aiding sector growth. She said that over 8% of Americans own or have owned Bitcoin – a percentage that is increasing.

What is obvious is that Fintech adoption is accelerating and the digitization of finance is inevitable. COVID is acting as an accelerant fueling this digital transformation that bodes well for consumers as well as business – beyond some avoidable hurdles.

The full report will be released later this month. Stay tuned.

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