Internal Audit – Trust Account Examination

Final Report

Audit, Evaluation, and Risk Branch

January 2019

Executive summary

The Canada Revenue Agency (CRA) conducts trust account examinations to ensure compliance with registration, withholding, remitting, reporting, and filing obligations related to payroll and the Goods and Services Tax (GST)/Harmonized Sales Tax (HST). This is not to be confused with trusts that are fiduciary arrangements that allow independent trustees to hold assets on behalf of other beneficiaries. During the 2016 to 2017 fiscal year, the CRA collected $263 billion in total source deductions from payroll accounts, $12.6 billion (net) from GST/HST, and another $767.8 million from the Air Travellers Security Charge.

The Business Compliance Directorate within the Collections and Verification Branch is responsible for trust account examinations. Within the directorate, the Employer Examination Section of the Employer Compliance Division is responsible for payroll examinations and the GST/HST Registration & Filing Compliance Section of the Corporation and GST/HST Compliance Division is responsible for the GST/HST and the Air Travellers Security Charge examinations.

Trust account examinations ensure that employers withhold and remit the correct payroll deductions from their employees’ salaries and wages. Additionally, these examinations ensure that registrants are appropriately charging, collecting, and remitting GST/HST and the Air Travellers Security Charge.

The audit objective was to provide the Commissioner, CRA management, and the Board of Management with an assessment of whether there are sufficient and appropriate controls in place that work to support the CRA’s goals and objectives for conducting payroll, GST/HST, and Air Travellers Security Charge trust account examinations. The implementation of Regional Workload Development Teams has addressed gaps in assessing compliance risk as well as strengthened file selection and assignment controls. In addition, the introduction of a 3-tier quality assurance process has added a systematic process to reviewing and assessing file quality.

By improving the risk assessment process, strengthening the quality assurance process, and better evaluating the performance of the examination officers and the program, trust account examinations will be better positioned to identify and address files at high-risk for non-compliance.

Summary of recommendations

The report outlines 5 recommendations covering risk assessment, quality assurance and performance measurement.

The introduction of the dedicated Regional Workload Development Teams in April 2016 has fundamentally changed the Trust Accounts Examination Program. Risk assessment processes have become vital to the Workload Development Team’s efforts to identify high-risk files. In order to identify these files, the Regional Workload Development Team should create a prioritized risk-based workload by assessing risk across all business lines (Payroll, GST/HST, and Air Travellers Security Charge) and all sources of workload (referrals, leads, and self-identified workload). In order to execute this, the Regional Workload Development Teams will need to develop business intelligence on an ongoing basis. As other CRA programs are also working to develop business intelligence, the Regional Workload Development Teams should share and receive the most current and relevant information with other CRA divisions.

In addition, to evaluate the results of these risk assessment processes, the Quality Assurance Team should assess the technical accuracy of the completed files. This process will assist in creating a consistent approach to file execution across the country as well as identify trends in business intelligence for the Regional Workload Development Team.

Finally, measuring the value of this newly implemented workload development process will also help the Business Compliance Directorate to identify areas for continual program improvement. By measuring the performance of the compliance action taken, the Business Compliance Directorate can effectively assess if it is selecting files with the highest non-compliance risk and undertaking the optimal volume of files.

Management’s response

The Collections and Verification Branch has agreed with all of the recommendations in this report and has developed corresponding action plans to address them. The Audit, Evaluation, and Risk Branch reviewed these action plans and determined that they appear reasonable to address all the recommendations in this report.

The action plans that fully address the recommendations include the following commitments:

1. Introduction

The Canada Revenue Agency (CRA) administers various acts, including the Income Tax Act and Excise Tax Act, which outline requirements for employers to collect taxes and other levies on behalf of Her Majesty. Trust accounts are funds held in trust, such as Goods and Services Tax (GST)/Harmonized Sales Tax (HST), Federal/Provincial Income Tax, Canada Pension Plan (CPP) and Employment Insurance (EI) premiums, or other levies that employers and registrants collect at source and pay to the Receiver General at a future date. This is not to be confused with trusts that are fiduciary arrangements that allow independent trustees to hold assets on behalf of other beneficiaries.

The CRA conducts trust account examinations to ensure compliance with requirements in the following areas:

During the 2016 to 2017 fiscal year, the CRA collected $263 billion in total source deductions from payroll accounts, $12.6 billion (net) from GST/HST, and another $767.8 million from the Air Travellers Security Charge.Footnote 1

The Business Compliance Directorate within the Collections and Verification Branch is responsible for trust account examinations. Within the directorate, the Employer Examination Section of the Employer Compliance Division is responsible for payroll examinations, and the GST/HST Registration & Filing Compliance Section of the Corporation and GST/HST Compliance Division is responsible for the GST/HST and the Air Travellers Security Charge examinations.

Key activities of the Employer Examination Section and of the Registration & Filing Compliance Section include:

All Tax Services Offices across Canada deliver payroll and GST/HST programs with the exception of Quebec, where GST/QST is administered by Revenu Québec. Although the Air Travellers Security Charge program is a national program, the Southern Alberta Tax Services Office performs examinations on behalf of the CRA.

According to the 2017 to 2018 Trust Accounts Examination Program and the GST/HST Registration and Filing Compliance Section - Planning Guidelines, the objectives of trust account examinations include:

The Trust Accounts Examination Program completed 57,194 payroll examinations, 11,643 GST/HST examinations, and 94 Air Travellers Security Charge examinations. 

During the last 2 fiscal years (2016 to 2017 and 2017 to 2018), significant changes have taken place within the Business Compliance Directorate, including:

Taking into consideration the volume of money collected and the fact that the Trust Accounts Examination Program had never been audited, an internal audit to assess the existence and strength of the internal controls that support the governance of the programs was relevant and timely.

2. Focus of the audit

This internal audit is included in the approved Risk-Based Audit and Evaluation Plan 2017 to 2020. The Assignment Planning Memorandum was approved by the Management Audit and Evaluation Committee on November 2, 2017.

2.1 Objective

The audit objective was to provide the Commissioner, CRA management, and the Board of Management with an assessment of whether there are sufficient and appropriate controls in place that work to support CRA’s goals and objectives for conducting payroll, GST/HST, and Air Travellers Security Charge trust account examinations.

2.2 Scope

This audit was conducted at Headquarters (HQ) as well as in the Pacific, Prairie, and Ontario regions. File reviews that were completed as part of the audit work focused on files processed across the country between April 1, 2016 and March 31, 2017.

2.3 Audit criteria and methodology

Audit criteria and methodology can be found in Appendix A.

The examination phase of the audit took place from November 2017 to April 2018.

The audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing, as supported by the results of the Quality Assurance and Improvement Program.

3. Findings, recommendations, and action plans

The Collections and Verification Branch has agreed with all of the recommendations in this report and has developed corresponding action plans to address them. The Audit, Evaluation, and Risk Branch has reviewed these action plans and determined that they appear reasonable to address all the recommendations in this report.

3.1 Workload development

Most payroll files are referred for a trust account examination from the Trust Compliance National Inventory by Trust Compliance Officers, Revenue Collections, CPP/EI Rulings, or the Employer Compliance Audit Program. Before the creation of Regional Workload Development Teams, in each Tax Service Office senior Trust Accounts Examination Officers would generate additional files to supplement the workload of examination officers.

The introduction of Regional Workload Development Teams launched a more systematic approach to supplementing the referral workload while also strengthening the segregation of duty controls. Regional Workload Development Team analysts and screeners identify potential risks to payroll compliance as well as techniques to detect non-compliance.  

3.1.1 Risk assessment processes do not consistently assess and prioritize all levels of risk.

3.1.1a Risk assessment processes differ amongst the sources of the Trust Accounts Examination Program’s workload because various criteria are used to identify files for examination. As the Regional Workload Development Teams do not risk assess the entire workload, files are not able to be prioritized based on the highest payroll compliance risks.

In order to meet one of the main program goals of addressing the highest risk non-compliant files, processes to review all potential workload should be in place to risk assess, calibrate, and prioritize all potential files. To build business intelligence and assist in identifying the highest compliance risk criteria, priorities and strategies should be in place to assess and benchmark the risks of the entire population.

There are 3 sources of workload for the Trust Accounts Examination Program:

Referrals from the Trust Compliance National Inventory/Trust Compliance Officer constitute the largest stream of workload for the Trust Accounts Examination Program and are based on predetermined business rules. When certain criteria are present in a Trust Compliance Officer’s file, the business rules require a mandatory referral to the Trust Accounts Examination Program regardless of whether the Trust Compliance Officer can resolve the file. Since the implementation of Regional Workload Development Teams in 2016, neither the criteria nor the business rules have been adjusted to align with the changes in workload development. The referrals from the Trust Compliance National Inventory/Trust Compliance Officer address known compliance risks in that they are all files or payroll accounts that have been flagged by CRA systems.

Referrals or leads from Revenue Collections, CPP/EI rulings, and audits in the Domestic Compliance Programs Branch are determined by the section they originate from, who deem there are risks posed to the CRA. Therefore, specific risk factors identified by the Regional Workload Development Teams may not be considered by officers or auditors when providing referrals or leads. PROTECTED. Regional Workload Development Teams focus principally on what information is missing in files to attempt to identify inconsistencies in payroll accounts. Difficulties in identifying these files can be improved by strengthening business intelligence in the programs.

If the Regional Workload Development teams are not risk assessing workloads homogenously and not generating 1 prioritized inventory, including the Trust Compliance National Inventory, then it is difficult to determine which payroll files are more non-compliant and pose the greater risk in order to support the effective utilization of trust account examination resources.

Because GST/HST examinations are normally conducted only in concurrence with payroll examinations, there is typically no risk assessment process associated with selecting these files for examination. Under certain circumstances, GST/HST trust account examinations are selected without an identified payroll examination.

3.1.1b Air Travellers Security Charge files are selected for examination based on limited selection criteria and without any assessment of risk.

Strategies are required to best direct the program’s limited resources to areas of risk. Processes to assess levels of risk within workloads should be implemented to ascertain if the dedication of resources to the endeavour is in the CRA’s best interest.

Air Travellers Security Charge files are selected for examination based on 2 risk factors:

No other risk factors were included in assessments to select files for examination.

The Air Travellers Security Charge needs to be collected and remitted when airlines use Canadian airports. When foreign airlines do not use Canadian airports during a given period, they are required to remit “nil” returns. Many examinations result in airlines having to file “nil” returns. In fact, in the 2016 to 2017 fiscal year, 70% of files resulted in cancellation or nil returns, and an additional 17% had a net debit result of less than $100. 

Because this program is very small, it has been overlooked with respect to the evolution of risk assessment models in the CRA. By addressing a predetermined quota without risk assessing the files, resources may have been allocated to address files of low risk and consequence.

Recommendation 1

Further to the progressive evolution of the program, the Collections and Verification Branch should develop and implement file selection criteria to allow for a more holistic approach to risk assessment that takes into consideration the multiple business lines (Payroll, GST/HST, and Air Travellers Security Charge) and sources of workload (referrals, leads, and generated by Workload Development) to create a prioritized risk-based workload for the Trust Accounts Examination Program. 

Action Plan 1

Target Date: Q1 2019-2020

In preparation for the Collection and Verification Workload Management System, in 2016, the Business Compliance Directorate initiated discussions with programs regarding long-term planning and risk assessments for each Business Compliance Directorate business line.  The Collection and Verification Workload Management System is expected to enable robust risk assessment of workloads for each program. The trust account examination programs are scheduled for 2022 onboarding. As an interim solution, Business Compliance Directorate will:

National program targets, reporting, procedures, and policies will be updated for payroll and GST/HST and communicated to execution teams to reflect any changes to workload prioritization to ensure that files are worked in order of priority.

Target Date: Q2 2019-2020

The Business Compliance Directorate will conduct a formal analysis of the Air Travellers Security Charge examinations. The key elements considered will be the selection criteria and the referral process. The analysis will include a risk assessment and cost benefit analysis to determine if Air Travellers Security Charge files require an examination or if they can be resolved in an earlier stage of the compliance continuum.

3.1.2 A coordinated and horizontal approach to the identification of payroll non-compliance risk and the development of business intelligence regarding payroll account examination is required.

The more information available and used to identify and assess risk criteria, the stronger the risk assessment process. The ability to review large amounts of data and convert it into business intelligence will help to develop a comprehensive risk identification and assessment process.

Payroll compliance is the responsibility of the Trust Compliance National Inventory, Trust Accounts Examination, and Employer Compliance Audit, with each having separate mandates, goals, and objectives. Files are referred among the 3 programs; however, there was little evidence of exchanging information or sharing business intelligence among them.

By working in “silos,” the 3 payroll compliance programs might not be targeting all payroll non-compliance risks as effectively as possible. Furthermore, by failing to interact with other programs within the CRA, the payroll programs are limiting themselves when attempting to develop business intelligence and risk assessment models. The CRA is continuously striving to improve both efficiency and effectiveness, and looking across programs rather than only within them can help to achieve these goals.

In most regions, the Regional Workload Development Team either shares office space with or is within the same Tax Services Office as the Business Intelligence and Quality Assurance Teams in the Domestic Compliance Programs Branch. Despite their proximity and similar organizational structure, the teams have little interaction between them. Information and good practices generally are not shared between them. Consequently, the CRA might be missing opportunities for both of these teams to learn from each other and further develop their respective programs.

Recommendation 2

The Collections and Verification Branch should implement business intelligence sharing protocols between the Trust Accounts Examination Program’s workload, the Employer Accounts and Services Section and the Employer Compliance Audit Section in the Collections and Verification Branch as well as the Business Intelligence Division and GST/HST Business Intelligence Section in Domestic Compliance Programs Branch to provide the workload development teams with the most current and relevant information to assist in risk assessment and file selection.

Action Plan 2

Target Date: Q4 2019-2020

The Business Compliance Directorate will ensure that the trust account examination programs’ business intelligence sharing needs, within the CRA, are addressed at the CRA Business Intelligence Operational Working Group.

The Business Compliance Directorate will implement a structure for regular meetings between its Regional Workload Development Teams and Regional Business Intelligence and Quality Assurance teams with the purpose of sharing knowledge and best practices.

3.2 Quality assurance

The Collections and Verification Branch introduced a multi-tiered quality assurance review process in April 2016. This process aims to improve file consistency across the entire Trust Accounts Examination Program. The process was designed specifically for the Trust Accounts Examination Program and consists of 3 tiers of review:

Additionally, there is a Headquarters quality assurance oversight component in this structure. This gauges consistency across all regions and provides overarching HQ support and supervision. The implementation of this oversight program shows the Collections and Verification Branch’s commitment to improving file quality within the program and the Directorate.

3.2.1 Quality assurance processes do not include the review of technical accuracy.

3.2.1a Quality assurance measurement criteria focus on file completeness and adherence to internal policy and procedures only. The technical accuracy of the examiner’s work is not reviewed.

Quality assurance processes are currently in place to support the management team, officers, and key stakeholders in maintaining and improving the quality of their files. Quality assurance processes should develop a consistent standard of quality to be maintained across the entire program. In order to assess the quality of the file, quality assurance officers need to conduct a comprehensive review that includes reviewing the file selection criteria and assessing the thoroughness of file execution. To assess technical accuracy, quality assurance officers would need to be adept in all aspects of the program in addition to having access to source documents that were used by the examination officer.

Quality assurance officers in both Tier 1 and Tier 2 work in multiple program areas with the Collections and Verification Branch. This requires a general understanding of multiple business lines rather than in-depth knowledge of a particular program. In order to conduct a comprehensive quality review effectively, quality assurance officers need additional in-depth training in terms of identifying technical accuracy concerns in the file.

Technical accuracy assessments are greatly restricted when the file does not contain the source information that was used to make decisions. The Trust Accounts Calculation Tool is used to capture all the relevant information from the examination and is heavily dependent on the information that the examination officer inputs into it. This tool does not allow the ability to include copies of source documentation within the file, but rather includes only an attestation by the examination officer of their actions and the documentation that they examined. Quality assurance officers are therefore limited to and reliant upon the examination officers’ attestation when conducting their reviews. For desk review files, the CRA receives information electronically. However, it too is not attached to the file.

Currently, there is no control to assess if the examination officer and team leader are appropriately addressing the issues identified by the Regional Workload Development Teams. Furthermore, without a technical review of the examination file, the Business Compliance Directorate can neither assess the consistency of file execution across Tax Services Offices or regions nor identify program-wide concerns in how examination officers execute their files.

3.2.1b  Files that the Trust Accounts Examination Program has cancelled are excluded from the quality assurance review.   

Once the Regional Workload Development Teams select files for review, Trust Accounts Examination Officers either complete or cancel them. A robust quality assurance program should include a sample review of all examination files regardless of their outcome. Excluding certain types of files in the review might create gaps in assessing overall file execution and quality in the program.

Examination files that are completed and closed by the Trust Accounts Examination Officers are subject to selection for a quality assurance review. Examination files that are not pursued and are cancelled by examination officers are excluded in the samples selected for review. Examination officers, with team leader approval, can cancel trust account examinations without permission of the Regional Workload Development Team. Consequently, there is a risk that they can circumvent the segregation of duty controls.

Team leaders in Trust Accounts Examination are authorized to cancel files selected by the Regional Workload Development Teams, which weakens the segregation of duty controls. Provided this authority remains with the team leaders and not the Regional Workload Development Team, inclusion of cancelled files in the quality assurance sample population provides a check that there are documented and justifiable rationales for cancelling files.

In the 2016 to 2017 fiscal year, 57,194 payroll exams were completed while 9,633 were cancelled. Therefore, a substantial proportion of files (14.4%) ended in cancellation.

Recommendation 3

The Collections and Verification Branch should include an assessment of the technical accuracy of work performed on all categories of files, including cancelled files, and use the information gained from the assessment to improve both the workload development and the trust account examination functions.

Action Plan 3

Target Date: Q4 2019-2020

Business Compliance Directorate will complete its pilot (Tier 3) quality assurance reviews of cancelled examinations. Cancelled examinations will be included nationally as part of regular quality assurance reviews.

New quality assurance criteria will be introduced with more focus on technical aspects. Source documents will be included in quality assurance reviews on a regular (project) basis.

Business Compliance Directorate will analyze and integrate quality assurance results into program planning.

3.3 Performance measurement

In order to measure a program’s performance effectively, key metrics need to be in place to assess the program’s activities. Consequently, good performance metrics should measure the efficiency and effectiveness of the program while also providing management with insight as to any possible performance-related issues.

3.3.1 Performance measurement criteria have not evolved to match the operational changes to the trust account examination programs.

3.3.1a Performance measurement criteria have not been adjusted to reflect the changes in workload development and fail to assess the effectiveness of the selection criteria or program activities.

Files identified by Regional Workload Development Teams attempt to address unknown non-compliance PROTECTED. These cases of non-compliance would most likely never be identified or resolved without the work of the Regional Workload Development Team and the compliance action taken on these files by the Trust Accounts Examination Officers. As these files differ in how they are both identified and examined from the bulk of the workload that is generated by referrals from Trust Compliance Officers, performance measures in place should assess the value of all files while considering their differences.

Fiscal impact is used as the key production measure and target for payroll files. In measuring the fiscal impact of the payroll files, no consideration is given to the extent of the examination officer’s work on the file or to the efforts of the Regional Workload Development Team in identifying the non-compliant taxpayers. To illustrate, a file that an examination officer examines for missing remittances from a taxpayer is considered equal to a file that identified the same amount in unreported income. The effort on the part of the examination officer in identifying the non-compliant amounts is also not considered when measuring the fiscal impact of the file.

Unless performance measures are updated, examination files that only appear to have the greater fiscal impact will continually be selected over files that may actually have the greater impact on compliance. Furthermore, the program will continue to work toward their fiscal impact targets without knowing whether they are using resources effectively or efficiently.

Recommendation 4

The Collections and Verification Branch should develop program performance metrics that assess the effectiveness of its program activities. 

Action Plan 4

Target Date: Q1 2019-2020

Business Compliance Directorate will review, develop, and implement additional measurements to assess the effectiveness of its program activities, such as measuring repeated non-compliance and success of criteria used for file selection. Business Compliance Directorate will also set internal production targets for specific workload streams to ensure the intended coverage is obtained.

3.3.1b Fiscal impact measures and targets for the GST/HST trust account examination program do not appropriately reflect all the aspects of the program.

Until April 9, 2018, GST/HST examinations included a very limited review of PROTECTED invoices regardless of the size of the file, which could contain large volumes of invoices to substantiate the amounts claimed. The review of invoices was done in order to validate the existence of the account. PROTECTED. To further investigate the return, officers could make referrals to GST/HST Compliance Audit. However, the Collections and Verification Branch has revamped the GST/HST trust account examination program and, going forward, it will add more rigour to the examination process. The Collections and Verification Branch also strengthened its linkages to GST/HST Compliance Audit by including information in the Integras case management system. Because these procedures were implemented only recently, Internal Audit has not yet assessed their impact on the program.

With respect to workload selection, GST/HST examinations are supposed to be selected and completed only in connection with identified payroll examinations. However, evidence was found that, under certain circumstances, GST/HST files were selected for examination without connection to payroll files. This was done for at least 1 of the following purposes:

When production targets are established for a program that does not have the ability to identify and select its own risk-based workload, it is difficult to measure these targets’ impact on overall non-compliance. Moreover, when such targets are in place, decisions regarding resource allocation are made based on target goals instead of on efficiency and efficacy.

Without understanding the true value of these GST/HST examinations, resources will be assigned to conduct them without necessarily knowing how they either benefit the Trust Accounts Examination Program or add value to the CRA.

Recommendation 5

The Collections and Verification Branch should implement robust performance measures to assess the value that GST/HST examinations have in helping the CRA achieve its goals and objectives.

Action Plan 5

Target Date: Q1 2020-2021

Business Compliance Directorate will review, develop, and implement additional performance measurements to assess the value that GST/HST examinations have in helping CRA achieve its goals and objectives.

4. Conclusion

The implementation of Regional Workload Development Teams has addressed gaps in assessing compliance risk as well as strengthened file selection and assignment controls. A systematic review of compliance risks and the continued development of business intelligence in all trust account examination workloads will support the program in identifying high-risk files across the country. Revised performance measures that better reflect the new risk assessment process will aid in achieving the program’s goals and objectives and better directing the program’s resources.

By improving risk assessment processes, strengthening quality assurance processes, and better evaluating the performance of the trust account examinations, the CRA will be better situated to identify and address trust account files at a high risk for non-compliance.

5. Acknowledgements

In closing, we would like to recognize and thank the Collections and Verification Branch; the Business Compliance Directorate; and the Ontario, Prairie, and Pacific Regions for the time they have dedicated and the information they have provided during the course of this engagement.

6. Appendices

Appendix A: Audit criteria and methodology

Based on the risk assessment, the following lines of enquiry were identified:

Lines of enquiry and criteria utilized in the internal audit
Lines of enquiry Criteria
Workload management Risk assessment processes are in place to identify and prioritize files.
Workload management Workload development procedures support the goal of selecting high risk files and other program objectives.
Workload management File distribution procedures are in place to select, assign, and monitor workload throughout the program to ensure segregation of duty controls.
Workload management Regionalizing workload management has led to more efficient processes within the program and the CRA.
Quality assurance Criteria used in the quality assurance process are sufficient and relevant to the objectives of the program.
Quality assurance Quality assurance results are communicated and reported in a timely manner and a feedback loop exists to support the improvement of program delivery.
Performance measurement Program performance measurement and reporting provide accurate and relevant information to support management decision making.

Methodology

The methods for examination included the following:

Appendix B: Glossary

Glossary
Term Definition
152(7) assessments Subsection 152(7) of the Income Tax Act grants the Minister of National Revenue the authority to assess tax payable for taxpayers if they have not filed returns for specific years and if certain criteria have been met.
Desk review Review conducted by examination officers whereby documents are provided by the employer electronically and the examination officers execute the review on CRA premises. Examination officers do not visit the employer’s place of business during a “desk review.”
Developing workload The entire process of selecting files to be examined from the development of business intelligence, to conducting large scale risk assessments, to selecting groupings of files and the screening process to narrow down the groupings to manageable workload that can be assigned to examination officers.
Integras Integrated audit management system is a suite of work-tools that manages all phases of an audit.
Registrant An individual that has a valid GST/HST number.
Segregation of duties The concept of having more than 1 person required to complete a task. In business, sharing more than 1 individual in 1 single task is an internal control intended to prevent fraud and error.
Trust A trust is a fiduciary relationship in which one party, known as a trustor, gives another party, the trustee, the right to hold title to property or assets for the benefit of a third party, the beneficiary.
Trust account examination The CRA allows individuals (businesses and employers) to collect and remit monies on their behalf or “in trust.” This includes GST/HST, payroll deductions and the Air Travellers Security Charge. Trust account examinations are conducted to ensure that said businesses and employers are in compliance with the requirements of operating one of these accounts.

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