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180

THEME THE CHARTERED ACCOUNTANT

Artificial Intelligence – A Game-


Changer for Chartered Accountants

Usha Ganapathy A. Sekar Dr. Ranjith Krishnan


Subramanian Corporate Law Expert Academician
Academician

As newer technologies like Artificial Intelligence (AI) enter the business space, Chartered
Accountants must gear up to meet the challenges and seize the opportunities that present
themselves. As businesses gear up to unleash the prowess of AI in their environment,
a Chartered Accountant (CA) must understand the nature of AI and the concerns that it
may bring in. He must also envision the myriad ways in which AI could be implemented
in the accounting department of an entity – right from reconciliations through reporting
to streamlining disclosures and even beyond, to the realm of decision-support and risk
management systems in the entity. As an Auditor, a CA must look at ways to leverage
AI to increase the level of assurance – by deploying AI at various stages of the audit of
the process while reserving the responsibility of forming an opinion to himself. With the
able guidance of the ICAI, the CAs will well be able to tide over this wave of change and
emerge stronger.

Introduction performance of the business. of core banking solution


Different applications were used (CBS). Now another wave of
The world is ever-changing and for different functions; these were transformation is happening with
more so, the world of technology. operating in silos and sometimes the advent of technologies like
In the realm of accounting and enabled data export or import big data, artificial intelligence (AI),
auditing, we can say that the for use in other software. Then smart contracts, radio frequency
first wave of transformation with the advent of internet
happened with the introduction and advanced networking
of computers with software that capabilities giving rise to the An important factor
required some level of coding possibility of centralization to consider before
knowledge. The next wave came of data and applications, a
with the introduction of simple radical transformation, rather
deploying an AI tool
accounting software that does re-engineering, happened with especially in decision-
not require coding knowledge but the introduction of enterprise making settings is
is largely decentralized requiring resource planning (ERP) software understanding and
periodical manual consolidation and in the case of banking trust.
for making sense of the businesses, implementation

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identification (RFID), Internet of generative tools, self-driven cars of technology, especially a
Things (IoT), cloud computing, and creative tools. technology that can think for itself
robotic process automation (RPA) or at least learn to think for itself,
and blockchain technology. Such Towards Better Governance has its own benefits, but there are
technology comes with its own and Ease of Doing Business some matters of concern:
possibilities and challenges, Regulators too have been
which were hitherto unforeseen zealous in adopting AI tools iii. Enforcing the
by the lawmakers. The regulators to achieve better governance Stakeholders’ Right to
themselves are experimenting and regulation of entities. Explanation
with such technology and some For example, the Ministry of An important factor to consider
have already introduced them at Corporate Affairs has deployed before deploying an AI tool
least in the back end. AI in the V3 version of its MCA21 especially in decision-making
portal. As the quality of data settings is understanding and
Now as the world treads that is collected also improves trust. Explainable AI (XAI) is an
an untrodden path, the on the one hand through attempt at enhancing the trust
professionals– especially factor by helping us understand
deployment of technology like
the accounting and auditing how a decision has been arrived
XBRL, deploying AI capabilities
professionals are expected to at – a white-box approach
enables regulators to spot
be the guiding force. This article instead of a black-box approach.2
red flags earlier. This could
is an attempt to discuss the This approach to AI would
also double up as an exercise
basic elements of AI and the be better for accounting and
towards ease of doing business
various implications of AI and decision-making systems as the
the data could be pre-filled or
related technology in the areas of public as well as the regulators
cross-verified from earlier filings.
accounting and auditing. have the right to understand.
SEBI also envisages to use it for
applications like surveillance.1 In this context, the right to
Decoding Artificial explanation has been recognised
In the future, regulators may
Intelligence by the European Union in the
establish a common database or
at least inter-connectivity among General Data Protection Right
i. Necessity is the Mother of
the databases in such a way in the recital clause.3 Other
Invention - Going beyond
jurisdictions like France and
Automation that cross-verification of data
the US have also alluded to
filed with different regulators is
As Billy Ocean, a famous English and recognised this right in
Singer sung in 1985 “When the possible and any discrepancy
some circumstances. However,
going gets tough, the tough could be further investigated.
whether enforcing this right
get going”, tough times call for through legislation is beneficial or
ii. Matters of Concern in
tough decisions. During the possible is debated, as simpler
pandemic, many businesses
Usage of AI
AI systems could be amenable to
realized the need for infusing Though use of AI results in a this requirement, whereas AI tools
technology in their businesses great deal of automation, AI that operate on much-higher
in a bid to optimise utilisation cannot be regarded as mere level and layered-algorithms may
of resources both in terms of automation. Automation runs not be able to be subject to this
money and manhours. One such on a fixed algorithm wherein the just as the reason why a human
technology which has been program logic is pre-defined, being takes a particular decision
growing in leaps and bounds and when compared with AI, we may not always be easily
and found increasing adoption can say it is almost hard-coded. explained. Further, requiring
since the pandemic is Artificial However, AI, although based on explainability may stifle the
Intelligence (AI). Most of us are algorithms and human inputs, is very evolution of AI technology.
already acquainted with some designed to continuously learn However, in a larger context and
general applications of AI like and improvise. It aims to mimic in public interest, the right to
natural speech recognition, human thought processes and explanation is an important one.
advanced web search, cognitive abilities. Implementation An examination and review of
1 https://www.sebi.gov.in/reports-and-statistics/publications/aug-2021/annual-report-2020-21_51610.html
2 https://en.wikipedia.org/wiki/Explainable_artificial_intelligence
3 https://en.wikipedia.org/wiki/Right_to_explanation

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THEME THE CHARTERED ACCOUNTANT

the rightness of the decisions of the Information Technology adopting AI relevant to the
made by the AI systems by an Act, 2000, which deals with business context.
information systems auditor compensation for failure to
instead of seeking an explanation protect data, “Information Applications of AI in
is also proposed as an Technology (Reasonable security Accounting
alternative. Under the Consumer practices and procedures
and sensitive personal data Having discussed some basic
Protection Act, 2019, Consumer
or information) Rules, 2011” aspects of AI, now let us look at
Protection (E-Commerce)
have been issued. These Rules some specific use cases of AI in
Rules, 2020 have been issued
provide for procedures to handle accounting and compliance for
to address the issues arising
sensitive personal data or businesses:
in e-commerce.4 These Rules
require an explanation of the information.5 Under the proposed
i. Reconciliation Process
main parameters based on which Digital Personal Data Protection
Bill, 2022, unauthorised use of A significant use case of AI in
rating of sellers is made, in plain
data may constitute a “personal accounting is reconciliation – be
language. If a platform uses AI
data breach”.6 Under the it bank reconciliation or inter-
to rank goods or sellers, the
proposed Digital India Act, 2023, company reconciliation for group
requirements under these Rules
measures to regulate as well as entities or for creditors and debtors
must be factored in. It must also
to foster innovation in AI and balance confirmation processes.
be understood that explainability
other emerging technologies are If done manually as it is done at
is crucial for the developers and
being proposed.7 NASSCOM has present in many businesses, it is
businesses to ensure that the AI
also come up with Guidelines on time consuming and laborious
system is working as expected, as one witnesses the problems
not just in terms of the decision Generative AI.8 On 14th June,
2023, the European Parliament of duplicate entries, mismatched
taken but in terms of the way in entries, partially-entered invoices,
which the decision is arrived at, approved its position on the
world’s first AI Act under which tax aspects, accounting errors
which is necessary to build the and other inconsistencies. This
required level of trust to deploy it AI systems are classified based
on the risks they pose: from can be overcome with machine
for the intended purposes. learning (ML) technology that
unacceptable risk, high risk,
generative AI and limited risk, uses predefined matching rules
iv. Ethical Concerns and and which learns based on the
Regulatory Measures based on which obligations for
providers will be imposed under results of the datasets. This will
One of the ethical concerns in the rules.9 It, inter alia, seeks enable more reliable and timely
the use of AI is regarding data to ban using of AI for purposes disclosures of related party
protection and privacy. With like biometric surveillance and transactions.11 Such features are
the deployment of AI and Big recognition of emotions, and now available in ERP software as
Data analytics, an entity may requires generative AI to disclose well as in the form of applications
unintentionally or intentionally that the content is AI-generated.10 that can be deployed on existing
process sensitive data in an software or popular cloud-based
unauthorised way and that may While all these concerns still applications.
intrude on privacy interests. The remain and are addressed
lawmakers and regulators, the to some extent with evolving ii. Managing Related Party
world over, are still grappling with laws, businesses have already Transactions
the implications of AI and the started exploring the possibilities Another potential application
security and privacy concerns. that could open a floodgate could be in the very process of
At present, under section 43A of opportunities for them by identifying and understanding
4 https://consumeraffairs.nic.in/sites/default/files/E%20commerce%20rules.pdf
5 https://www.meity.gov.in/writereaddata/files/GSR313E_10511%281%29_0.pdf
6 https://www.meity.gov.in/writereaddata/files/The%20Digital%20Personal%20Data%20Potection%20Bill%2C%202022_0.pdf
7 https://www.meity.gov.in/writereaddata/files/DIA_Presentation%2009.03.2023%20Final.pdf
8 https://nasscom.in/ai/responsibleai/images/GenAI-Guidelines-June2023.pdf
9 https://www.europarl.europa.eu/news/en/headlines/society/20230601STO93804/eu-ai-act-first-regulation-on-artificial-intelligence
10 https://www.europarl.europa.eu/news/en/press-room/20230609IPR96212/meps-ready-to-negotiate-first-ever-rules-for-safe-and-transparent-ai
11 https://www.groupsoftus.com/insights/using-machine-learning-ml-in-sap-for-reconciliation/

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AI in Accounting

Better
Managing screening of
Inventory Timely Management
Reconciliations Related Party vendor and
Management Reporting Accounting
Transactions customer
profiles

complex group structures of This necessitates technological alia, by screening vendor and
large conglomerates. Larger intervention both by the customer profiles from various
businesses usually arrange conglomerates for making sources and assess counter-
their ownership and control continued sense of the strategy as party default risks. This could
structure, business models and well as for better risk monitoring also ease complexities involved
transactions in the form of a by the various stakeholder groups in some disclosure requirements
complex web of group entities of these entities, especially the under the Schedule III to the
spread across geographies, lenders. For the businesses, Companies Act, 2013 like tracing
often in layers of entities, and AI tools could help in better of transactions with defunct
sometimes, wherever permitted, compliance and in making companies or disqualification
with cross-holdings or cross- complete and timely disclosures status of directors at least to the
control, formal and informal. The of related party transactions under extent of disqualification arising
group structures may or may not the applicable laws. out of a defaulting company
fall strictly under the definition under sub-section (2) of section
of related party as per the As far as stakeholders like the 164 of the Companies Act, 2013
applicable laws. lenders are concerned, they by comparing them with the
need to be able to have the database of Ministry of Corporate
Hence, the regulators world big picture of the entire group Affairs.
over are requiring increasingly to follow the money trail and
comprehensive compliance and understand whether the funds For financial sector entities, the
disclosure in respect of related have been deployed for the efforts towards understanding the
party transactions, as they are a stated purposes or whether they group structures and activities
significant indicator of the level are being siphoned off to benefit through AI as described in the
of good corporate governance. certain members of the promoter previous para could double up
In India, for instance, for listed group. Here AI could help towards strengthening fraud risk
companies, the definition of banks and financial institutions management and anti-money
‘related party’ and ‘related in understanding the overall laundering measures. It could
party transactions’ has been control structure, business model
widened to a great extent under and the consolidated financial
the SEBI (Listing Obligations strength of the borrowers with AI tools can
and Disclosure Requirements) complex group structures. This potentially be used
Regulations, 2015, so much will be a crucial information while for fraud risk mitigation,
so that even transactions with evaluating funding proposals and inter alia, by screening
arrangements – both initial and
third parties “the effect of which vendor and customer
is to benefit a related party”, ongoing.
profiles from various
or transactions of the listed
company or its subsidiaries on iii. Screening Profiles to sources and assess
the one hand with the related Manage Risks counter-party
parties of either on the other AI tools can potentially be used default risks.
hand are covered12. for fraud risk mitigation, inter
12 https://www.sebi.gov.in/legal/regulations/feb-2023/securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-
regulations-2015-last-amended-on-february-07-2023-_69224.html

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THEME THE CHARTERED ACCOUNTANT

help in setting up better Early the analyses instead of only a an audit of financial statements
Warning Signals as required sample is also available when AI is to give an opinion on whether
under the Reserve Bank of is coupled with Big Data. Entities the reporting requirements as per
India’s (RBI) Master Direction on have been able to gather data the applicable financial reporting
Frauds, and in better reporting of from various sources but if they framework have been met. Under
transactions required under the are unable to make sense of the the provisions of the Companies
provisions of the Prevention of data or they are unable to focus Act, 2013, the duty of the auditor
Money Laundering Act, 2002. on the information needs, they here is to express an opinion on
end up in a state of being Data- whether the financial statements
iv. Inventory Management Rich-Information-Poor (DRIP). present a true and fair view of
When it comes to inventory Introduction of AI here will help the affairs of the company. The
management, a combination of an entity to make sense from the auditor while arriving at this
AI together with RFID could help raw data and focus on obtaining opinion by obtaining reasonable
track, manage and account for relevant information, which can assurance on whether the
inventory on an almost real-time become actionable inputs to financial statements are free
basis, thereby enhancing the the management. Right from from material misstatements,
reliability of accounting records. automating repetitive decision- whether due to fraud or error,
Use of RFID combined with making to risk mitigation, AI can is required to evaluate whether
smart contracts and AI can help be used. However, it should be the audit evidence obtained is
establish a seamless trust-based remembered that periodic human sufficient and appropriate. In
supply chain management intervention is necessary to this process of collecting and
system. This will again go evaluate and judge the reliability evaluating sufficient appropriate
towards better accounting and of such AI-based decision- audit evidence, an auditor must
reporting. making systems. be mindful of the impact of AI.

v. Timely Reporting Role of AI in Audit Process Let us look at the impact of AI on


auditing from two angles:
AI can also optimize Record- As eloquently described in
to-Report (R2R) process 1. Understanding an
“SA 200: Overall Objectives of
leading to more reliable and the Independent Auditor and environment that uses AI
timely preparation of financial the Conduct of an Audit in and automation
statements. Often delay in Accordance with Standards on 2. AI as a tool in the audit
obtaining data at the grassroot Auditing”, the overall objective of process
level leads to delay in reporting.
This can be overcome by
introducing technologies like
RFID, big data and AI, to
automate and expedite recording
of transactions at the point of
origin of the transactions.

vi. Management Accounting


AI has applications not only
in financial accounting but
also in cost and management
accounting. When it comes to
better internal reporting systems
and decision-making systems,
AI, IoT, RFID and Big Data
analytics could play a great
role in culling out hidden cost
behaviours, demand patterns
and in making more realistic
forecasts. The possibility of
using the entire population for

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rights in respect of such internal Accounts is appropriately made,
AI can help analyse controls, just as he needs to be and whether the schedules and
the financial aware of it for the purpose of disclosures generated by the AI
information of the clients checking any tampering of edit are comprehensive and reliable.
log too. AI deployment in Internal While assessing the controls
and assess the areas in the inventory management
Controls could be in the form of
where the potential risk input controls, enhanced user- environment that uses RFID and
of material misstatements based access controls, processing AI, the auditor may check how the
is the highest. controls and logic, and output data from RFID scanners interacts
controls. The consistency of the with the AI logic and how it is
logic throughout the reporting implemented in the ERP system.
period shall also be checked. It
i. Understanding an may also be relevant to insist on The entire audit team needs to
environment that uses AI an audit of the AI tools and the have hands-on knowledge of AI
environment from an Information tools which are deployed in the
An audit of an entity involves client entities and evaluating those
performing risk assessment Systems Auditor.
in the process of audit execution.
procedures to have a clear
understanding of the entity and After performing a test of
controls to evaluate whether ii. AI as a tool in the audit
its environment, including the process
adequacy and effectiveness internal controls are operating
effectively to prevent or detect a. AI in Statutory Audit
of the entity’s internal controls
material misstatements, an engagements
in place. “SA 315 – Identifying
and Assessing the Risk of auditor may plan his substantive An auditor can himself / herself
Material Misstatement through procedures – a test of details use AI tools in the audit process.
Understanding the Entity and its and substantive analytical While an audit is neither an
Environment” provides guidance in procedures. investigation nor is it an exercise
this regard. Further, a “Report on towards giving an absolute
For example, in the R2R process assurance, deployment of AI in
the Internal Financial Controls over
– the auditor must understand auditing could help provide an
Financial Reporting” is mandated
how AI processes information even higher level of assurance
under sub-section (3) of section
as part of the test of controls, than may otherwise be possible.
143 of the Companies Act, 2013
and thereafter select a suitable At the elementary level,
for prescribed classes of entities.
sample and test aspects like generative AI can help arrive at
In case of an entity using an ERP whether the correct General some useful basic checklists
software embedded with AI/ML Ledger (GL) Account is selected, which can be improved to
capabilities, it is likely that the whether taxation aspects like TDS greater detailing based on the
internal control processes could and GST have been correctly requirements of the assurance
involve AI components. Here it captured, whether grouping of GL levels required.
becomes imperative to understand
how AI is used to enforce controls,
preferably in a white-box manner,
or at least an evaluation of the
logic with test cases. The auditor
should not only check the initial
set of predefined rules, but also
the logic with which the AI tool
learns. Hence, the auditor must
be careful here if any attempts at
overriding the internal controls had
been made and understand the
response of the system to such
attempts. The auditor must also
be very much aware of who has
the super-user or administrator

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THEME THE CHARTERED ACCOUNTANT

AI can help analyse the financial AI can also help the auditor and transactions in the Report on
information of the clients his team perform an engagement Transfer Pricing as required
and assess the areas where quality control review as required under section 92E of the Income
the potential risk of material under “SQC 1 – Quality Control Tax Act, 1961, use of AI as a tool
misstatements is the highest. for Firms that Perform Audits comes in handy.
While the auditor may himself be and Reviews of Historical
subject to at least some degree Financial Information, and Other With big data, AI analytics can
of familiarity bias, the AI tool, is Assurance and Related Services greatly help the internal auditor
more likely to be free from such Engagements”, by assessing the in measuring the effectiveness
bias. The auditor may then apply appropriateness of the opinion of the internal controls in a
more substantive procedures in arrived at based on the audit comprehensive manner, although
the areas so identified. evidence collected. adequacy may be something that
will be best left to the judgment
AI may also help in determining Specifically, the auditor will be in of the internal auditor based on
materiality and in the a better position to give his / her the results of the analysis thrown
assessment of whether an opinion on the various matters by the AI. Areas of internal control
identified misstatement is covered under the Companies weaknesses can be identified in a
material in the context of the Auditors’ Report Order, 2020, much better manner.
entity. The auditor can then especially in respect of related
come with an optimized audit party transactions, material As far as forensic audit and
strategy and plan and perform uncertainty in respect of meeting investigations are concerned,
the audit in a better way. AI may the liabilities, and also with respect samples could be chosen on a
also help with sampling of test to whether the terms of the loans more scientific basis with the
cases for audit by choosing a and guarantees provided by the help of AI. Better samples would
sample free from bias thereby company are prejudicial to the lead to better information for
reducing sampling risk. interests of the company. arriving at conclusions. In case
of audit of specific transactions,
AI may also help with analysing b. AI as a tool in other audit AI tools can help arrive at the
whether the evidence might be engagements degree of correlation between
sufficient for assessing the risk AI could help not only in statutory the factors involved.
of material misstatements at audit engagements but also has
the assertion level by helping applications in internal audit, tax c. Challenges in implementing
establish a correlation between audit, forensic audit, etc. AI and results of AI in
the evidence and the assertion. auditing
It can also help assess whether In tax audits, when it comes The biggest challenge in
an audit observation based on a to verifying the matters of implementing AI is understanding
sample will be true for the entire disallowances, depreciation, how the AI tool arrives at the
set of data. TDS, TCS, reconciliation, output, so to say, how it “thinks”.
deductions, and more Although some experts are of the
When it comes to substantive importantly, in determining view that using anthropomorphic
analytical procedures, AI tools the arm’s length nature of words like “think” further
combined with big data can
help identify hidden patterns of
behaviour of various variables
and unearth and establish
relationships among financial
and non-financial information
in a more comprehensive
manner. Use of AI in analytical
procedures might help identify
red flags much earlier than
they would otherwise be and
help establish an early warning
system for the use of the
auditor.

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and auditing professionals need The CAs are increasingly being
The CAs are to re-orient themselves away looked upon to drive the process
increasingly being from routine areas of work that of professionalism within their
looked upon to drive the may be replaced with AI tools domain, which ultimately leads
and equip themselves with the the way towards ease of doing
process of professionalism knowledge and skill required to business. In this context, the
within their domain, work with AI and even to work on judicious use of AI comes in
which ultimately leads AI to stay relevant in the vastly handy and CAs have a major
the way towards ease of dynamic professional world. In this role here. CAs must realise
doing business. process, they may need to unlearn that the scope of application of
things to transcend the clutches their skills and experience goes
of routine work and learn new beyond the traditional lines of
things to achieve mastery over AI audit, accounting and taxation,
reduces our understanding of
tools. Then instead of looking at and it very well extends to
the processing behind AI, it is
AI as a threat to their existence, strategic areas like implementing
necessary to understand how AI-driven business process re-
the Chartered Accountants (CAs)
the output is arrived at. Here is engineering and supporting the
may even take up opportunities in
where XAI as discussed earlier top management of businesses in
implementing AI for their clients or
becomes important. No matter this transition. While section 144 of
auditing the AI environment or the
what human-like terms we use, the Companies Act, 2013 prevents
AI controls, or even in designing
AI is still not human. It does an auditor from rendering these
AI tools that can lead to better
not experience emotions and services to the entities where they
reporting and governance.
thoughts like we do. It does not perform statutory audit, nothing
have a gut feeling. Hence, while As a fallout of AI implementation, prevents a CA from taking up
AI can supplement and support several changes need to be those assignments in respect
an auditor, it can never substitute made to various statutes in of other unrelated entities. A CA
or supplant the auditor in the respect of various sectors of the should boldly step into the realm
human process of forming an economy, some of which are of technology.
opinion which will always remain already in the pipeline as detailed
the dominion of the auditor. in one of the earlier paragraphs Every change is borne of a storm.
on regulatory measures. It requires the eyes of someone
The next challenge could be who can soar high above the
Following this, the regulators
empowering the employees of storm clouds to make sense of
like the RBI and SEBI also
the enterprises and the audit the change. A CA, like the Eagle
need to come out with detailed
team with knowledge and that represents him/her, has the
guidelines on AI-related impact
understanding of the potential foresight and the capability to
on their respective sectors.
uses and challenges involved in soar above the clouds and guide
The Institute of Chartered
AI. This requires an open mind the businesses that are caught
Accountants of India (ICAI) may
to be able to appreciate the in this storm of technological
like to come up with Guidance
concept of AI. upheaval. However, to fully
Notes and/or suitable updates
The other operational challenge to the Accounting and Auditing realise the potential, a lot more
will be how to integrate AI tools Standards, in order to guide the needs to be done by the CAs in
and capabilities with existing Members through the phase of terms of learning, re-learning and
software and hardware. These transition to AI environment. To developing new skills as well as
are usually mitigated by using further pave the way for easing quickly unlearning the irrelevant
cloud-based AI compatible with the future generation of CAs into skill components. The ICAI along
existing applications. this dynamic new business and with the regulators will need to
professional world running and enable this transition by providing
Concluding Thoughts – the right framework.
operating in the AI environment,
Converting Challenges into 
the ICAI may consider to
Opportunities
upgrade the curriculum itself by
Authors may be reached at
In order to face the new world including therein the subjects cs.ushaganapathy@gmail.com,
order that may be established relating to accounting and a.sekar.cs@gmail.com,
or that already may have been auditing in an environment ranjithk.iyer@gmail.com and
established with AI, accounting enriched with AI. eboard@icai.in

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