Generative AI in Retail and Commercial Banking 1701787749

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Generative AI

in retail and
commercial banking
Prepared for
Contents
Methodology of survey

Implications for retail and commercial banks

Survey highlights

Priority use cases

Demographics overview

Page 2
Methodology of survey

Background and methodology

Interest and demand for GenAI* solutions is rising quickly.


Retail and commercial banks, as well as SME banking players,
are beginning to make significant movements and investments
into the space.

To better understand how global retail and commercial banks are exploring and/or implementing GenAI applications,
EY-Parthenon teams conducted the following survey:

N=151
 Respondents included global,  Decision-makers focused on client  Respondents had knowledge of  Sample decision-maker titles
regional and community banks servicing, marketing, onboarding, the represented bank’s GenAI included (but were not restricted
within the consumer/retail, product strategy and other initiatives or direct involvement in to): chief strategy officers, chief
commercial and small-and- investment and technology teams leading GenAI efforts, with technology officers, chief lending
medium enterprise (SME) representatives specific expertise in GenAI officer, head of product
banking segments. applications, including ChatGPT, development, head of marketing,
Dall-E, OpenAI and Microsoft relationship manager, chief risk
Azure. officer and other positions in the
firm directly related to client
servicing, client investing, client
Conducted in July 2023 onboarding and risk.

*Generative AI or GenAI

Page 3
Contents
Methodology of survey

Implications for retail and commercial banks

Survey highlights

Priority use cases

Demographics overview

Page 4
Implications for retail and commercial banks

GenAI can unlock meaningful enhancements in profitability and efficiency for retail and
commercial banks
Key takeaway Supporting data

1 Retail and commercial banks are already investing, or are


planning to invest, in GenAI applications.


60% of large banks (>US$500b in deposits) have already made tangible investments in GenAI.
86% of small banks (<US$50b in deposits) are already investing or actively planning to invest.

2 Banks are focused on benefits that will yield efficiency


gains, lower costs and greater client acquisition/retention.


78% of banks see productivity enhancements as a primary driver.
60% of banks seek customer experience enhancements and cost reduction.

3 Enhancements are largely concentrated in the back office,


with risk and ops projected to capture the largest gains.


66% of banks note fewer than 40% of viable use cases as front-office focused.
70% of banks see risk and compliance as the top area for GenAI teams to connect.

 >75% of large (>US$500b in deposits) and >50% of small (<US$50b in deposits), are at the

4 GenAI investments are already being made, with larger


banks further ahead than smaller peers.
beta-testing stage or beyond.
 71% of banks have mobilized and are allocating <20% of their designated budget source (e.g.,
IT) to GenAI initiatives.

50% of banks have identified <10 novel use cases.


5

Banks are prioritizing select use cases, signaling awareness
 >60% of banks are prioritizing customer service, risk management and operations as the top use
of their most salient needs.
cases.

 ~47% of banks prioritize new revenue opportunities and 48% prioritize personalized product
Retail and commercial banks both are prioritizing similar
6 use cases focused on customer experience, risk
management and revenue generation.
recommends as top focus areas.
 69% of retail banks see real-time fraud detection a top investment and 75% of commercial banks
prioritize AML/KYC risk use cases.

There is still much apprehension regarding the viability of  67% of banks are waiting for further developments and testing before prioritizing front-office
7 the GenAI in the front office and doubts about bank’s ability
to implement.
use cases.
 37% of bankers do not have confidence in their bank’s ability to implement GenAI.

Source: EY-Parthenon HNWI Tokenization Survey (n=251); EY-Parthenon Institutional Investor Tokenization Survey (n=78) Page 5
Contents
Methodology of survey

Implications for retail and commercial banks

Survey highlights

Priority use cases

Demographics overview

Page 6
Survey highlights

Retail and commercial banks demonstrate growing interest in GenAI solutions,


anticipate enhanced profitability and have begun deploying dedicated resources
Retail and commercial banks …
1 Are actively exploring 2 Anticipate numerous benefits 3 Expect lower immediate revenue impacts
GenAI initiatives following implementation % uplift in revenue % cost savings in
in the front office the back office
Both retail and commercial banks are most 3% 2%

45%
3% 7%
motivated to invest in GenAI due to the
23%
following drivers: 25%

of banks are already


investing in GenAI 1. Productivity enhancements 61-80%+ 61-80%+
2. Customer experience enhancements 72%
41-60%
66%
41-60%
3. Cost savings 21-40% 21-40%
4. Competitive differentiation 0-20% 0-20%
5. Task automation N=151 N=151

52%
45%
4 And have begun making investments in dedicated GenAI teams to realize these benefits
GenAI team mobilization % budget dedicated to Funding amount for GenAI
(n=151) GenAI (n=122) teams (n=151)
3%

19% 14% 28% 20% 20% 7% 11%


29%

52% <US$1m
US$2m-US$4m
US$5m-US$10m
US$11m-US$20m
US$21m-US$49m
>US$50m
of banks are planning to
of banks are planning to invest or
invest or highly interested Funding amounts largely correlate with bank
highly interested in learning more 71%
in learning more 81% segment sizes, with most spending <20% of
Yes 0-20%
No >20% their budget on GenAI.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 7
Survey highlights

45% of banks are already investing in GenAI, with larger banks outpacing their peers;
productivity, CX enhancement and cost reduction are top drivers

Please rate the overall interest of your firm in investing in GenAI / What are the primary drivers motivating your bank to
developing additional use cases for GenAI technologies. (n=151)1 implement GenAI technologies? (n=151)

Level of interest in GenAI by deposit size Productivity enhancements 78%


Customer experience
60%
enhancements
28% Cost reduction 59%
38%
45% 46% Competitive differentiation/
51%
60% competitor benchmarking
Task automation 48%

Revenue optimization 42%


58% 21% 41%
40% New revenue generation 42%
Already investing in
Generative AI Security augmentation/
36% risk management 41%
33% Very interested —
planning to invest Cash flow and liquidity
21% optimization
12%
15% 14% 4% Neutral/somewhat
All <US$50b US$51b— US$201b– >US$500b
interested Other 1%
US$200b US$500b

 Large banks with >US$500b in deposits have made tangible investments in their  Productivity enhancements, customer experience enhancements and cost reduction
GenAI capabilities, with 60% already investing in the tech. are key motivators among banks seeking to implement GenAI.
 Conversely, only <30% of smaller banks (<US$50b in deposits) have begun investing  Competitive differentiation also rises to the top as a primary driver, with >50% of
in GenAI technologies. banks perceive GenAI as a catalyst for differentiation.
 Receptivity toward key operational drivers is less homogeneous, with task automation
resonating more strongly with banks than cash flow and liquidity optimization
incentives.

1.Rank order determined by % of respondents that ranked each choice 1, 2 or 3.


Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 8
Survey highlights

Two-thirds of respondents anticipate greater productivity gains from GenAI; over half
expect it to enhance existing tech capabilities and accelerate innovation

How do you think GenAI will change your bank’s “ways of working”? (n=151)

70%

60%

50%

40%
66% 63%
30%
54%
48%
20% 43%
35%
26%
10%
13%
0%
Enable greater Enhance existing Accelerate Reduce reliance Displace headcount Necessitate Unlock alternative Decrease
productivity by technological innovation on select roles via via advanced organization-wide working modalities interpersonal
automating targeted capabilities automation of key automation change management interactions
sales prospecting and functions capabilities protocols
outreach for RMs

Additional Details
 Top areas for change, enabling greater relationship manager (RM)/sales productivity and enhancing technical capabilities, will both require clear performance
metrics in the business case to assess success.
 Among both retail and commercial banks, 54% see GenAI accelerating innovation as a highly anticipated use case, which positions GenAI investments as an enabler
for other areas of innovation as well as future AI use cases.
 With 48% of banks expecting GenAI to mitigate reliance on select roles via automation and 43% believing that GenAI will progressively displace headcount, it will be
especially critical to build a governance and control model to manage the top concerns of trust in the technology.
 Despite its many impacts, the vast majority of respondents do not see GenAI decreasing interpersonal interactions.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 9
Survey highlights

Impacts to workforce, productivity enhancements and cost savings are expected to be


larger across the back office

What percentage of your workforce do What degree of productivity enhancements do What degree of cost savings do you
you believe will be directly impacted by you expect GenAI to produce across the expect GenAI to produce across the
GenAI? (n=151) following functions? (n=151) following functions? (n=151)

5% 3%
9% 3% 9% 6%
11% 9%
16%
17% 20% 20%

31% 38%
33%
40% 39%
40%

53% 48% 50%


34% 31% 35%

Front office Back office Front office Back office Front office Back office

0%–20% 21%–40% 41%–60% 61%–80%+

Additional Details

 46% of large banks with >US$500b in deposits anticipate a direct impact on 41–50% of their respective workforces in the back office, up from 38% of small banks
with <US$50b.
 The front office will be especially impacted over longer timelines; while only <40% of banks anticipate >20% in cost savings or productivity enhancements in the
front office in less than five years, >60% anticipate that level of impact in less than five years.
 Even in the longer-term outlook of less than five years, fewer than than 20% of banks across all segments see >40% impact to workforce, productivity or cost.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 10
Survey highlights

Customer service, onboarding, risk management and operations were identified as top
impacted areas in terms of cost and time savings

Which departments across the front office do you expect will


Which departments across the back office do you expect will realize
realize the greatest time and cost savings from implementation?
the greatest time and cost savings from implementation? (n=151)
(n=151)

64% 66%
62%

49%
41% 39% 39%
35% 34%
30% 28%

17%
10%

Customer Onboarding Relationship Marketing Sales Prospecting Product Risk Operations Regulatory/ Technology Finance/ Human
service management development management/ compliance accounting resources
fraud

Additional Details Additional Details

 Customer service and onboarding were identified as top departments for  Both retail and commercial banks see far greater cost savings vs. time
significant cost and time savings, signaling an ongoing strategic focus on savings for top back-office departments of risk management and operations.
client-facing functions to drive cost optimization.
 Large banks with >US$500b in deposits lead smaller segments in terms of
expected time savings in customer service, representing 42% of those
selecting customer service as a top candidate in efficiency gains.
 44% of large banks with >US$500b in deposits noted product development
as an area to drive time savings vs. 28% of overall respondents.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 11
Survey highlights

50% of banks are exploring <10 novel use cases; of those, client-focused use cases
such as enhancing marketing and human-like chatbots are top priorities

How many new use cases have been identified,


What type of GenAI investments/use cases/initiatives is your firm currently exploring? (n=151)
across your firm, for GenAI ? (n=151)

Number of new use cases for GenAI Novel GenAI use cases

N=151 Enhanced marketing 69%

7% Enhanced human-like chatbots 68%


1%
Enhanced onboarding or
7% AML/KYC 57%

Predictive analytics 55%

Real-time fraud detection 54%


34% Enhanced/continuous
risk management 48%
Personalized assistants for
customer-facing roles 37%

Enhanced data aggregation 34%


Ultra-personalized investment
advisory 32%

Other 2%

50% >150
101–150
 Banks are exploring a diverse array of novel use cases, with 15% of banks identifying at least
51–100 >50%; however, the distribution of identified use cases is also fairly polarized, with another 50%
11–50 of banks identifying <10 new use cases.
<10  Client-focused marketing and chatbots stand out as the top use cases being explored, with
forward-looking predictive analytics use cases being explored by >50% of banks.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 12
Survey highlights

Majority of respondents (66%) note less than 40% of viable use cases are front-office
focused, with 67% waiting for further development and testing before prioritization

What percentage of viable use cases reflect front-office Would your firm prioritize front-office client-centric
functions (e.g., marketing, prospecting) as opposed to back- GenAI applications over augmentation of back-office
office functions (e.g., risk management, operations)? (n=151) automation? (n=148)

Proportion of total use cases represented by front office Prioritization level of front-office applications

N=151
10%

25%
32%

26%

Yes, we’re excited about the enhanced

66% 61%–80%+ 67%


1%
capabilities
Maybe, we’re waiting for further
development and testing
40% 41%–60%
No, we’re only considering back-office
21%–40% applications
<20%

 Two-thirds of respondents see less than 40% of viable use cases as front-office specific, emphasizing that most banks are prioritizing back-office operations and risk
use cases similarly to past automation technologies.
 67% are awaiting further development/testing before prioritizing GenAI use cases, echoing uncertainty in the viability of the technology and the low confidence
bankers have in their firm’s capabilities to implement.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 13
Survey highlights

Two-thirds of all respondents express confidence in their internal capabilities to deploy


GenAI use cases, with data privacy and accuracy/reliability as top concerns

Do you believe that your bank is well equipped with the correct Please select challenges/barriers to implementation
technological infrastructure, internal controls and internal talent to that your bank has encountered while exploring GenAI
implement GenAI use cases? (n=151) initiatives. (n=151)

Degree of confidence in internal capabilities


Yes No 1 Concerns regarding data privacy and security

2 Concerns regarding accuracy/reliability

58% 65% 66%


3 Cost of implementation
61%
63%
4 Legal and reputational risk

5 Ambiguous business use cases


42%
39% 34%
37% 35%
6 Concerns regarding fairness and biases

All <US$50b US$51b–


US$200b
US$201b–
US$500b
>US$500b
7 Ethical considerations

 Confidence in internal technological infrastructure and capabilities increases


slightly with those with larger deposit sizes.
8 Cost of ongoing or routine maintenance

9 High energy consumption

1.Rank order determined by % of respondents that ranked each choice 1, 2, or 3


Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 14
Survey highlights

Banks are cautious about GenAI viability to drive full automation in the near term and
most still do not see high viability even after 10 years

How viable are full automation use cases of GenAI at your firm? (n=151)

1%
5% 6%
25% 22%

44%
49% 51%

60%
66%
High (>60%)
50%
45% 42% Medium (20%–60%)

Low (<20%)
16%
9%
1% 2% 2% 5% Not viable
Year 1 Year 2 Year 3 Year 5 Year 10

Additional Details

 Banks anticipate that GenAI’s full automation capabilities will significantly increase in viability over the next 1–10 years; however, even after 10 years, most banks
still do not see high viability.
 Although 45% of banks do not see GenAI as viable in the next year, the proportion decreases to 1% by Year 3, indicating growing confidence in their internal
capabilities and partnership opportunities in the near term.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 15
Survey highlights

90% of banks have dedicated at least some resources to GenAI initiatives; however,
most applications (73%) are not expected to launch before 2024

Has your firm allocated dedicated resources to GenAI exploration


When do you expect to launch GenAI applications? (n=136)
and/or deployment? (n=151)

Dedicated resources to GenAI deployment 4%


9% 6%
16% 13%

20%

67%
64% 58% 69%
38% 59%

Yes, we have a team


10% solely focused on GenAI
Yes, we have mandated
some existing teams
2025+
Yes, we have dedicated 27% 25% 29% 25% 29%
a few internal resources 2024
No, but plan to do so in 2023
the near term All <US$50b US$51b– US$201b– >US$500b
32%
US$200b US$500b

Additional Details

 Among banks that have yet to fully launch a GenAI application, 91% overall anticipate doing so by the latter half of 2024.
 Larger banks with >US$200b in deposits outpace their smaller counterparts in speed-to-launch, with 96% of banks with >US$500b in deposits and 92% of banks with
US$201b-US$500b in deposits planning to launch by 2024 at the latest.
 16% of smaller banks with <US$50b in deposits anticipate launching GenAI applications in 2025 or beyond, while only 9% of all respondents expect to wait that long.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 16
Survey highlights

61% of banks have already launched or soft-launched GenAI applications, and are
largely funding efforts from their IT/tech spend

Where is funding/spend for dedicated GenAI teams being sourced?


At what stage is your investment in GenAI? (n=151) Approximately what percentage of your bank’s budget do you expect
will be allocated to mobilizing the GenAI team? (n=122)

Stage of investment by deposit size Funding source and amount for GenAI teams

19% 17% 15% 21%


25% IT/tech Machine learning/AI Operations

35%
42% 42% 29% 39% 27% 16% 10% 7%
55%
9%
14% Business/corporate Product development
13% 25%
strategy
41% 8%
26% 28% 21% 17%
All <US$50b US$51b– US$201b– >US$500b
5% 3%
US$200b US$500b 71% 20%
Already rolled out GenAI applications, or ready to launch imminently 1%
Beta-testing or have soft-launched GenAI applications
Designing GenAI applications
Unsure 61%+ 41%–60% 21%–40% 0%–20%
Considering investment areas and prioritizing use cases

 Majority of banks (~40%) are funding initiatives from IT/tech budgets, as well as
the business/corp. strategy budget (17%).
 Over 70% of respondents noted their banks are allocating <20% of their
designated funding source (e.g., IT/tech) toward GenAI applications.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 17
Survey highlights

Of banks that have not yet established a GenAI team, a majority plan to establish a team
within the next one to two years

Does your bank have plans to establish a GenAI team/sub-unit in the What barriers and/or challenges have deterred your bank
future? (n=29) from establishing a dedicated GenAI team? (n=29)

6% 10%
3%
1 Insufficient internal expertise on GenAI

2 Regulatory ambiguity and volatility surrounding


GenAI

3 Cost/budget constraints

4 Perception of inadequate return on investment

79%
5 Inadequacy of ancillary support

Do not know/no plans to Yes, within the next 1–2 6 Low prioritization of GenAI
establish a team years (2024–25)
Yes, in 3+ years (2026+) Yes, this year (2023)

 An overwhelming majority (79%) of banks that have yet to establish a GenAI  Despite broad enthusiasm for GenAI applications, notable barriers to
team anticipate doing so within the next one to two years. establishing dedicated teams remain top-of-mind for many banks, with more
than half (55%) identifying insufficient internal expertise as a key challenge.
 Very few are waiting, with only 6% of banks planning to establish GenAI
after three+ years and only 10% unsure or without a current plan to  Regulatory ambiguity and cost constraints are also critical hurdles to GenAI
establish a team, emphasizing the sentiment that there is some urgency to implementation.
move quickly.

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 18
Contents
Methodology of survey

Implications for retail and commercial banks

Survey highlights

Priority use cases

Demographics overview

Page 19
Priority use cases

Top front-office use cases for retail and commercial banks

Where do you expect to prioritize investment across front-office functions? Select all that apply

Retail banks (n=87) Commercial banks (n=64)

New customer ID/segmentation 54% CRM automation 58%

Personalized product recommendations 48% New revenue opportunity ID 50%

New revenue opportunity ID 45% Personalized product recommendations 48%


Customer behavior modeling/sentiment analysis 40%
Hyper-personalized advertising, outreach and sales 42%
Customer journey mapping/simulations 40%
Real-time data entry and report generation 42%
Hyper-personalized advertising,
38%
outreach and sales
Product development/beta-testing 36%
Advanced sales analytics 36%
Financial scenario planning/report generation 31%
Product development/beta-testing 30%
Front-office resource directory via chatbot 28%
Real-time data entry and report generation 29%
Working capital predictions/forecasting 27%
Financial scenario planning/report generation 28%

Dynamic pricing for consumer banking products 28% Regulatory environment monitoring and summarization 27%

Front-office resource directory via chatbot 20% Cash flow forecasting/advanced predictive analytics 23%

FX and remittance facilitation 10% Trade finance automation 23%

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 20
Priority use cases

Top client-facing use cases for retail and commercial banks

Where do you expect to prioritize investment across client-facing functions? Select all that apply

Retail banks (n=85) Commercial banks (n=63)

Cross-selling for value-added products


D2C personalized advertising/messaging 62% 67%
via chatbot

Cross-selling for value-added


61%
products via chatbot D2C personalized advertising/messaging 57%

Conversational virtual assistants


52% Automated customer future needs
for complex inquiries
48%
forecasting
Human-like onboarding guidance 51%
Advanced financial planning, spending insight
44%
generation and notification delivery
Real-time automated approvals for
49%
“scorecard” lending
Human-like financial advisory virtual
40%
Advanced financial planning, spending insight assistants
38%
generation and notification delivery
Payables/receivables tracking and
35%
report generation
Automated customer future needs forecasting 35%

Simplified form auto-population via Cash flow/liquidity insights 29%


35%
predictive analytics

Projected loss assessments for


Auto-generated custom educational content 33% 22%
lending use cases

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 21
Priority use cases

Top back-office use cases for retail and commercial banks

Where do you expect to prioritize investment across back-office functions? Select all that apply

Retail banks (n=87) Commercial banks (n=64)

Real-time fraud detection 69% Augmented AML/KYC 75%

Process optimization/automation 61%


Predictive analytics 60%
Regulatory monitoring and
56%
compliance advising
Enhanced AML/KYC 56%
Enhanced/continuous risk management 50%
Enhanced/continuous
risk management 52% Real-time ongoing risk monitoring
47%
for lending
Real-time ongoing risk
48% Data entry/validation 45%
monitoring for lending
Automated loan application Automated data aggregation and analysis 41%
processing/underwriting 47%
Predictive analytics for cash
38%
Automated data entry 40% flow/treasury management
Enhanced commercial loan
36%
app processing/underwriting
Enhanced data aggregation 31%
Enhanced payment reconciliation,
31%
clearing, and settlement processes
Enhanced payment reconciliation,
31%
clearing, and settlement processes Market volatility monitoring and advising 20%
News classification/sentiment
18% Trade finance automation 19%
analysis

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 22
Contents
Methodology of survey

Implications for retail and commercial banks

Survey highlights

Priority use cases

Demographics overview

Page 23
Demographics overview

Surveyed institutional investor demographics

Surveyed commercial and retail banks are primarily represented by


What type of banking function most accurately describes your department?
respondents from Asia and the US at public firms (n=151)
Banks surveyed are broadly split between commercial/SME banking and
retail/consumer banking (n=151)
Other Africa LATAM
Canada
25% Private
3% 2%
Commercial/SME banking 42%
1%
Europe
1%
13% 58% Retail/Consumer banking

51%
What is the size of your institution’s deposit base?

75% Public Both retail and commercial banks are acutely interested in GenAI and a
28% substantial proportion has already initiated deployment (n=151)
Asia
US

35%
23% 23%
19%

Firm type <US$50b US$51b– US$201b– >US$500b


US$200b US$500b

Source: EY Parthenon Retail and Commercial Banking GenAI Survey July 2023 (n=151) Page 24
Ernst & Young LLP contacts

Authors Key contacts

Aaron Byrne Toshi Mogi Sameer Gupta


Global Financial Services Leader GenAI Strategy Co-Leader
EY Americas Financial Services GenAI Co-Leader
EY-Parthenon EY-Parthenon
Ernst & Young LLP
Ernst & Young LLP Ernst & Young LLP
sameer.gupta@ey.com
aaron.byrne@parthenon.ey.com toshi.mogi@parthenon.ey.com

Prashant Kher Zachary Trull Vidhya Sekhar


GenAI Strategy Co-Leader Financial Services Strategy
EY Americas Financial Services GenAI Co-Leader
EY-Parthenon EY-Parthenon
Ernst & Young LLP
Ernst & Young LLP Ernst & Young LLP
vidhya.sekhar@ey.com
prashant.k.kher@parthenon.ey.com zachary.w.trull@parthenon.ey.com

David Kadio-Morokro
EY Americas Financial Services Innovation Leader
Contributors Ernst & Young LLP
david.kadio-morokro@ey.com

Will Laud Elizabeth Sun


Financial Services Strategy Financial Services Strategy
EY-Parthenon EY-Parthenon
Ernst & Young LLP Ernst & Young LLP
will.laud@parthenon.ey.com elizabeth.sun@parthenon.ey.com

Page 25
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