Exam FRM Level 2 Ultimate Guide (Books 4 & 5)

Estimated reading time: 31 minutes

 

Introduction

In the last of this series, we will now focus on books 4 and 5 in level 2 for our full FRM exam summary.

(click here to see previous guide)

You may download this entire content on our shop page, free of charge.

 

FRM Level 2 Book 4 – Liquidity and Treasury Risk Management

 

Liquidity Risk

The credit crisis that started in 2007 has emphasized the importance of liquidity risk for both financial institutions and their regulators

Financial institutions that relied on wholesale deposits for their funding experienced problems as investors lost confidence in the financial system

Financial institutions found that some instruments for which there had previously been a liquid market could only be sold at fire-sale prices during the crisis

 

Solvency and liquidity

It is important to distinguish solvency from liquidity

Solvency refers to a company having more assets than liabilities (positive equity value)

Liquidity refers to the ability of a company to make cash payments as they become due

 

Failing because of liquidity

Financial institutions that are solvent can fail because of liquidity problems

Northern Rock, a British bank specializing in mortgage lending, failed largely because of liquidity problems

It is clearly important for financial institutions to manage liquidity carefully

 

Assess by worst-case liquidity

A financial institution should assess a worst-case liquidity scenario and make sure that it can survive that scenario by either converting assets into cash or raising cash in some other way

  • The new Basel III requirements are designed to ensure that banks do this

 

Liquidity and trading

Liquidity is also an important consideration in trading

A liquid position in an asset is one that can be unwound at short notice

As the market for an asset becomes less liquid, traders are more likely to take losses because they face bigger bid–offer spreads

 

Liquidity sources

The main sources of liquidity for a financial institution are:

  • Holdings of cash and Treasury securities
  • The ability to liquidate trading book positions
  • The ability to borrow money at short notice
  • The ability to offer favorable terms to attract retail and wholesale deposits at short notice
  • The ability to securitize assets (such as loans) at short notice
  • Borrowings from the central bank

 

Liquidity black holes

Liquidity black holes are situations where a shock to financial markets causes liquidity to almost completely dry up

Here, everyone wants to sell and no one wants to buy, or vice versa

 

Liquidity and Leverage

One of the most important aspects of the subprime crisis was the sudden reluctance of financial institutions to lend money, and the increased reluctance to borrow

Most financial institutions are heavily leveraged

  • That is, they borrow heavily to finance their assets, compared to the typical non-financial firm

 

Funding liquidity

Funding liquidity is the ability to finance assets continuously at an acceptable borrowing rate

 

Transaction liquidity risk

Transaction liquidity risk is the risk of moving the price of an asset adversely in the act of buying or selling it

Transaction liquidity risk is low if assets can be liquidated or a position can be covered quickly, cheaply, and without moving the price “too much”

We recall that an asset is said to be liquid if it is “near” or a good substitute for cash

 

Liquidity premiums

An asset is said to have a liquidity premium if its price is lower and expected return higher because it isn’t perfectly liquid

A market is said to be liquid if market participants can put on or unwind positions quickly, without excessive transactions costs and without excessive price deterioration

 

Funding liquidity risk

Funding liquidity risk is the risk that creditors either withdraw credit or change the terms on which it is granted in such a way that the positions have to be unwound and/or are no longer profitable

 

Systemic risk

Systemic risk refers to the risk of a general impairment of the financial system

 

Early Warning Indicators, EWIs

As an integral part of liquidity risk management (LRM), bank leadership has the responsibility to both:

  • Identify underlying liquidity risk factors
  • Manage underlying liquidity risk factors

Negative trends serve as early indicators that may warrant an assessment of a bank’s exposure to any emerging risk

 

EWI flags to watch for

Early Warning Indicators (EWIs) may include but are not limited to:

  • Rapid asset growth, especially when funded with potentially volatile liabilities
  • Growing concentrations in assets or liabilities
  • Increases in currency mismatches
  • Decrease of weighted average maturity of liabilities
  • Repeated incidents of breaching internal or regulatory limits
  • Significant deterioration in the bank’s financial condition
  • Credit rating downgrade
  • Stock price declines
  • Rising debt costs
  • Widening debt/credit-default-swap spreads
  • Rising wholesale/retail funding costs
  • Counterparties requesting additional collateral or resisting entering into new transactions
  • Increasing redemptions of CDs before maturity
  • Difficulty accessing longer-term funding
  • Difficulty placing short-term liabilities

 

The Investment Function

The primary function of most banks and other depository institutions is not to buy and sell bonds, but rather to make loans to businesses and individuals

 

The use of loans

Loans support business investment and consumer spending in local communities

Such loans ultimately provide jobs and income to residents

Buying and selling bonds has its place because not all of a financial firm’s funds can be allocated to loans

 

The issue with loans

Many loans are illiquid—they cannot easily be sold or securitized prior to maturity if a lending institution needs cash in a hurry

Another problem is that loans are among the riskiest assets, generally carrying the highest customer default rates of any form of credit

 

Investments and portfolios

Investments perform a number of vital functions in the asset portfolios of financial firms, providing:

  • Income
  • Liquidity
  • Diversification
  • A partial shelter from taxation

Investments also tend to stabilize earnings, providing supplemental income when other sources of revenue are in decline

 

The investment officer

The investment officer must choose what kinds of investments best contribute to the goals established for each institution’s investment portfolio

In choosing which investments to hold, investments officers must weigh multiple factors:

  • The goal of the investment portfolio
  • Expected rates of return
  • Tax exposure
  • Risks associated with changing market interest rates
  • Possible default

 

Liquidity and Reserves Management

A financial institution’s need for liquidity can be viewed within a demand–supply framework

For most financial institutions, the most pressing demands for spendable funds generally come from two sources:

  • Customers withdrawing money from their accounts
  • Credit requests from customers the institution wishes to keep

Either in the form of new loan requests or drawings upon existing credit lines

 

Sources of supply

To meet demands for liquidity, financial firms can draw upon several potential sources of supply

The most important source for a depository institution normally is receipt of new customer deposits

In choosing which source of reserves to draw upon, money managers must carefully consider several aspects:

  • Immediacy of need
  • Duration of need
  • Access to the market for liquid funds
  • Relative costs and risks of alternative sources of funds
  • The interest rate outlook
  • Outlook for central bank monetary policy
  • Rules and regulations applicable to a liquidity source

 

Intraday Liquidity Risk Management

The banking industry’s interest in intraday liquidity risk in the United States can be traced back to the early 1980s

  • This was an era of extremely high interest rates and tight money

 

Banks and stress testing

Banks should continuously build and expand the types of scenarios they can model in stress testing

Banks should have at least the following four scenarios:

  • Own financial stress
  • Counterparty stress
  • Customer stress
  • Market-wide credit or liquidity stress

The 2007–08 financial crisis highlighted a number of deficiencies in industry practices and led to more rigorous research efforts

 

Monitoring Liquidity

The identification and taxonomy of the cash flows that can occur during the business activity of a financial institution is crucial to building effective tools to monitor and manage liquidity risk

The taxonomy suggested focuses on two main dimensions:

  • Time
  • Amount

For Time: Cash flows may occur at future instants that are known with certainty or they may manifest themselves at some random instants

For Amount: Cash flows may occur in an amount that is known with certainty at the reference time, or their amount cannot be fully determined

In the first case we say that, according to the time of their appearance, they are deterministic

In the second case we define them as stochastic (again, according to time)

 

The failure mechanics

A bank is conventionally viewed as an intermediary between depositors, who desire short-term liquidity, and borrowers, who seek project financing

  • Occasionally shocks prevent the ability of borrowers to repay their loans
  • Depositors may become concerned over the bank’s solvency
  • Depositors may then “run,” accelerating or worsening the bank’s failure

 

Treating the social costs of bank failures

The standard policy tools for treating the social costs of bank failures include:

  • Regulatory supervision and risk-based capital requirements
  • Deposit insurance
  • Regulatory resolution mechanisms

 

Dealer banks

Dealer banks are often parts of large complex financial organizations whose failures can damage the economy significantly

  • As a result, they are sometimes considered “too big to fail”

 

Off-balance-sheet financing

Some large dealer banks have made extensive use of “off-balance-sheet” financing

  • Example, a bank can originate or purchase residential mortgages and other loans that are financed by selling the loans to a financial corporation or trust that it has set up for this express purpose
  • Such a “special purpose entity” pays its sponsoring bank for the assets with the proceeds of debt that it issues to third-party investors
  • The principal and interest payments of the debt issued by the special purpose entity are paid from the cash flows that it hopes to receive from the assets that it has purchased from the sponsoring bank

 

Liquidity Stress Testing

Liquidity stress testing provides the critical underpinning to a bank’s liquidity risk management framework

  • The point of the test is to determine the amount of liquidity that must be held in order to ensure the institution can meet financial obligations under stressed conditions

A robust liquidity stress test is based on a projection of cash flows arising from assets, liabilities, and other off-balance sheet items

  • It will be performed under a variety of systemic and idiosyncratic scenarios that can occur over varying time horizons

 

The LST framework

In order to construct an effective liquidity stress testing framework, it is important to clearly define what is meant by “liquidity” for liquidity stress testing purposes

  • Within this context, liquidity refers to funding liquidity risk—the risk that the institution will not have adequate capacity to fund its obligations without incurring unacceptable economic losses

 

The strategic use of liquidity

As a source of funding liquidity, businesses utilize liquidity for four purposes:

  • Operational purposes
  • Restricted purposes
  • Contingent purposes
  • Strategic purposes

 

Focus areas for testing stress capabilities

As banks continue to refine their liquidity stress capabilities, they should focus on four areas:

  • Ensuring appropriate scope and structure of the liquidity stress test
  • Building the model on robust assumptions
  • Improving integration with related risk and performance models
  • Automating the process

A bank will produce a number of liquidity reports in the normal course of business, on a daily, weekly, monthly and quarterly basis

Stress test output results should help senior management to understand the liquidity position of the bank, enabling them to take mitigating action if deemed necessary

 

Contingency Funding Planning

A contingency funding plan (CFP) serves as a logical connection to its companion, the liquidity stress testing framework, by linking the stress test results and other related information as inputs to:

  • The CFP governance
  • The menu of contingent liquidity actions
  • The decision framework

 

Contingent liquidity events

Contingent liquidity events can be categorized by their level of estimated adverse impact and probability

Institutions manage one end of the spectrum—the low-impact, high-probability events—as part of their business-as-usual (BAU) funding and liquidity risk management activities

However, they use CFPs to address the other end of the spectrum associated with high-impact low-probability events

 

Attributes of an effective CFP plan

An effective contingency funding plan will include the following attributes:

  • Strong management involvement and participation from the enterprise
  • Alignment to other capital and risk management frameworks
  • Evaluation of a wide range of possible scenarios
  • Clearly documented management action plan
  • Communication plan with coordination to internal and external stake-holders

 

Managing and Pricing Services

Deposit accounts are the number one source of funds at most banks

Deposits provide much of the raw material for making loans and represent the ultimate source of profits and growth for a depository institution

 

Indicators of management effectiveness

Important indicators of management’s effectiveness are:

  • Whether funds deposited by the public have been raised at the lowest possible cost
  • Whether sufficient deposits are available to fund future projects

 

The ever-present issues

Two key issues every depository institution must deal:

Where can funds be raised at lowest possible cost?

How can management ensure that the institution always has enough deposits to support its activities?

 

The Chief Deposit Officer

So challenging has it become today to attract significant new deposits that many financial firms have created a new executive position— Chief Deposit Officer

 

Transaction deposits

Transaction deposits include:

Regular checking accounts, which often bear no interest-return

Interest-bearing deposits which usually pay a low yield

 

Non-transaction deposits

Non-transaction deposits may include:

Certificates of deposit (CDs)

Savings accounts

Money market accounts

 

Transaction versus non-transaction deposits

However, transaction deposits often are among the most profitable deposit services. This is due to:

  • Their nonexistent or low interest rates
  • The higher service fees these accounts usually carry

In contrast, non-transaction, or thrift, deposits generally have the advantage of a more stable funding base that allows a depository institution to reach for longer-term and higher-yielding assets

 

Covering a funds gap

Which non-deposit sources will management use to cover a funds gap?

The answer depends upon five factors:

  1. The relative costs of raising funds from each source
  2. The risk (volatility and dependability) of each funding source
  3. The length of time (maturity or term) for which funds are needed
  4. The size of the institution that requires more funds
  5. Regulations limiting the use of alternative funds sources

 

Repurchase Agreements and Financing

Repos are short-term contracts that are used to lend money on the security of usually high-grade collateral

  • They are used to finance the purchase of bonds, and to borrow bonds to be sold short

Financial institutions have traditionally relied on repos to finance some portion of fixed income inventory

 

Why Repo financing?

Repo financing is typically a relatively inexpensive way to borrow money

However the practice can leave firms in a perilous situation should lenders of cash through repos, in times of trouble, fail to renew their loans

 

Liquidity Transfer Pricing

Internal transfer pricing is an extremely important management tool for banks

Until the global financial crisis (GFC), many banks treated liquidity as a free good for transfer pricing purposes

  • This was one cause for the very poor liquidity outcomes experienced during the GFC

 

LTP as a practice

Although liquidity transfer pricing (LTP) practices are improving, there is little guidance publicly available to banks, regulators, and other stakeholders on what constitutes good practice

Remember that LTP is a process that attributes the costs, benefits and risks of liquidity to respective business units within a bank

 

The purpose of LTP

The purpose of LTP is to transfer liquidity costs and benefits from business units to a centrally managed pool

To achieve this, LTP charges users of funds (assets/loans) for the cost of liquidity, and credits providers of funds (liabilities/deposits) for the benefit of liquidity

 

The average cost approach to LTP

The average cost approach to LTP is simple, but has two major defects:

First, it neglects the varying maturity of assets and liabilities by applying a single charge for the use of funds

Second, it lags changes in banks’ actual market cost of funding

 

Matched-maturity marginal cost of funds

Overall, a matched-maturity marginal cost of funds approach promotes better LTP practice

A matched-maturity approach is more complex than the pooled average cost of funds approach, but it has some significant advantages:

First, it recognizes that the costs and benefits of liquidity are related to the maturities of assets and liabilities

Second, it recognizes the importance of having changes in market conditions incorporated quickly and efficiently into the rate used to charge and credit users and providers of funds

 

The US Dollar Shortage in Global Banking

The global financial crisis has shown just how unstable banks’ sources of funding can become

Throughout the crisis many banks faced severe difficulties securing short-term US dollar funding

In response, central banks around the world adopted extraordinary policy measures

  • This includes international swap arrangements with the US Federal Reserve
  • For the purpose of enabling them to provide US dollars to commercial banks in their respective jurisdictions

 

Financing foreign currency positions

A bank can finance foreign currency positions in several ways:

The bank can borrow domestic currency, and convert it in a straight FX spot transaction to purchase the foreign asset in that currency

It can use FX swaps to convert its domestic currency liabilities into foreign currency and purchase the foreign assets

The bank can borrow foreign currency, either from the interbank market, from non-bank market participants or from central banks

 

Covered interest parity

Covered interest parity (CIP) is the closest thing to a physical law in international finance

It holds that the interest rate differential between two currencies in the cash money markets should equal the differential between the forward and spot exchange rates

Otherwise, arbitrageurs could make a seemingly riskless profit

 

Risk Management for changing Interest Rates

Financial institutions today are highly complex organizations, offering multiple financial services through multiple departments, each staffed by specialists in making different kinds of decisions

The amount of risk that a financial firm accepts in its portfolio is closely related to the adequacy and composition of its capital (net worth)

In a well-managed financial institution management decisions must be coordinated in order to ensure they do not clash with each other

 

The dominant approach to funds management

The funds management approach which dominates today is a more balanced approach to asset-liability management that stresses several key objectives:

Management should exercise as much control as possible over the volume, mix, and return or cost of both assets and liabilities

Management’s control over assets must be coordinated with its control over liabilities so that asset management and liability management are internally consistent

Management policies need to be developed that maximize returns and effectively control costs

 

Illiquid Assets

Vayanos and Wang (2012) provide a taxonomy of how illiquidity arises due to market imperfections:

  • Clientele effects and participation costs
  • Transaction costs
  • Search frictions
  • Asymmetric information
  • Price impact
  • Funding constraints

 

FRM Level 2 Book 5 – Risk and Investment Management

 

Factor Theory

Assets earn risk premiums because they are exposed to underlying factor risks

 

The capital asset pricing model

The capital asset pricing model (CAPM) states that assets that crash when the market loses money are risky and therefore must reward their holders with high-risk premiums

While the CAPM defines bad times as times of low market returns, multifactor models capture multiple definitions of bad times across many factors and states of nature

 

The financial crisis of 2008 and 2009

During the financial crisis of 2008 and 2009, the price of most risky assets plunged

The riskier fixed income securities, like corporate bonds, emerging market bonds, and high yield bonds, also fell, tumbling along with real estate

The only assets to go up during 2008 were cash (U.S. Treasury bills) and safe-haven sovereign bonds, especially long-term U.S. Treasuries

 

Asset risk premiums

Assets have risk premiums not because the assets themselves earn risk premiums

Assets are bundles of factor risks, and it is the exposures to the underlying factor risks that earn risk premiums

 

CAPM

CAPM was revolutionary because it was the first cogent theory to recognize that the risk of an asset was not how that asset behaved in isolation but how that asset moved in relation to other assets and to the market as a whole

 

CAPM lessons

CAPM Lesson 1: Don’t Hold an Individual Asset, Hold the Factor

CAPM Lesson 2: Each Investor Has His Own Optimal Exposure of Factor Risk

CAPM Lesson 3: The Average Investor Holds the Market

CAPM Lesson 4: The Factor Risk Premium Has an Economic Story

CAPM Lesson 5: Risk Is Factor Exposure

CAPM Lesson 6: Assets Paying Off in Bad Times Have Low Risk Premiums

 

Factors

Factors drive risk premiums

One set of factors describes fundamental, economy-wide variables like growth, inflation, volatility, productivity, and demographic risk

Another set consists of tradeable investment styles like the market portfolio, value-growth investing, and momentum investing

 

The economic theory behind factors

The economic theory behind factors can be either:

Rational; where the factors have high returns over the long run to compensate for their low returns during bad times, or

Behavioral; where factor risk premiums result from the behavior of agents that is not arbitraged away

 

Low economic growth

When economic growth slows or inflation is high, all firms and investors in the economy are affected—it is just a question of degree

Most consumers dislike low growth and high inflation because it is more likely they will be laid off or they are less able to afford the same basket of goods and services in real terms

 

Those who benefit from slow growth

A few investors, such as debt collectors, benefit from slow growth, and a few other investors, including owners of oil wells, benefit from high inflation induced by surging commodity prices

 

Alpha

Alpha is the average return in excess of a benchmark

  • It tells us more about the set of factors used to construct that benchmark than about the skill involved in beating it

A positive alpha under one set of factors can turn negative using a different set

Whatever the benchmark, alpha is often hard to detect statistically, especially when adjustments for risk vary over time

 

The risky anomaly

The risky anomaly is that stocks with low betas and low volatilities have high returns

or…

The risk anomaly is that risk (as measured by market beta or volatility) is negatively related to returns

 

The low-risk anomaly

The low-risk anomaly is a combination of three effects, with the third a consequence of the first two:

  1. Volatility is negatively related to future returns
  2. Realized beta is negatively related to future returns
  3. Minimum variance portfolios do better than the market

 

Portfolio Construction

Implementation is the efficient translation of research into portfolios

Implementation includes both portfolio construction and trading

Good implementation can’t help poor research, but poor implementation can foil good research

 

Important inputs of portfolio construction

Portfolio construction requires several inputs:

  • The current portfolio
  • Alphas
  • Covariance estimates
  • Transactions cost estimates
  • An active risk aversion
  • Of the above inputs, we can only measure the current portfolio with near certainty

 

The present errors 

The alphas, covariances, and transactions cost estimates are all subject to error

The alphas are often unreasonable and subject to hidden biases

The covariances and transactions costs are noisy estimates; they are not measured with certainty

 

Questions for Implementation

Implementation schemes must address two questions:

  • First, what portfolio would we choose given inputs (alpha, covariance, active risk aversion, and transactions costs) known without error?
  • Second, what procedures can we use to make the portfolio construction process robust in the presence of unreasonable and noisy inputs?

 

The classes of procedures

There are four generic classes of procedures that cover the vast majority of institutional portfolio management applications:

  1. Screens
  2. Stratification
  3. Linear programming
  4. Quadratic programming

 

Portfolio Risk: Analytical Methods

Initially, VaR was developed as a methodology to measure portfolio risk

The concept of value-at-risk (VaR), or portfolio risk, is not new

What is new is the systematic application of VaR to many sources of financial / portfolio risk

 

VaR and leverage

VaR explicitly accounts for leverage and portfolio diversification and provides a simple, single measure of risk based on current positions

 

Measuring VaR

There are many approaches to measuring VaR

The shortest approach assumes that asset payoffs are linear (or delta) functions of normally distributed risk factors

 

Why VaR?

Many of the reasons that made VaR successful in the banking industry also apply to asset managers:

VaR is a forward-looking measure of the risk profile of a fund based on current positions

The more traditional returns-based approach, in contrast, is purely historical; it does not offer timely measurement of risk

VaR can be used to measure, control, and manage risk

VaR is comprehensive because it accounts for leverage, volatility, and diversification

VaR is a simple measure of risk that can be explained easily to portfolio managers and investors

VaR systems also can be used to set consistent guidelines

 

Risk Monitoring and Performance Measurement

The uncertainty of loss represents the cost that businesses accept to produce profit

Loss potential (i.e., “risk”) represents the “shadow price” behind profit expectations

A willingness to accept loss in order to generate profit suggests that a cost benefit process is present

 

Risk and Return

For a return to be deemed desirable, it should attain levels that compensate for the risks incurred

 

The risk budget

The risk budget—often called asset allocation—should quantify the vision of the business plan

For each allocation of risk budget, there should be a corresponding (and acceptable) return expectation

For each return expectation, some sense of expected variability around that expectation should be explored

 

Portfolio Performance Evaluation

Most financial assets are managed by professional investors

Efficient allocation therefore depends on the quality of these professionals and the ability of financial markets to identify the best stewards

If capital markets are to be reasonably efficient, investors must be able to measure the performance of their asset managers

An appropriate performance measure depends on the role of the portfolio to be evaluated

 

The different performance measures

Appropriate performance measures are as follows:

Sharpe: When the portfolio represents the entire investment fund

Information ratio: When the portfolio represents the active portfolio to be optimally mixed with the passive portfolio

Treynor: When the portfolio represents one sub-portfolio of many

Jensen (alpha): All of these measures require a positive alpha for the portfolio to be considered attractive

 

Style analysis

Style analysis uses a multiple regression model where the factors are category (style) portfolios such as bills, bonds, and stocks

The coefficients on the style portfolios indicate a passive strategy that would match the risk exposures of the managed portfolio

Shifting mean and risk of actively managed portfolios make it difficult to assess performance

  • An important example of this problem arises when portfolio managers attempt to time the market, resulting in ever-changing portfolio betas

 

Manipulation and measuring performance

Managers can manipulate their performance measures by adjusting their risk-return profile in response to performance in the early part of an evaluation period

 

Morningstar risk-adjusted return

The Morningstar risk-adjusted return is the only manipulation-proof performance measure

 

Decomposing portfolio performance

Common attribution procedures decompose portfolio performance to:

  • Asset allocation
  • Sector selection
  • Security selection decisions

Performance is assessed by calculating departures of portfolio composition from a benchmark or neutral portfolio

 

Hedge Funds

Hedge funds have their roots in the world of private wealth management

For over half a century, wealthy individuals invested their capital alongside “talented” traders expecting out-sized return to their investment irrespective of general market conditions

 

Hedge funds versus mutual funds

Hedge funds are distinct from mutual funds in several important respects:

Historically, hedge funds are private investment vehicles not open to the general investment public

Hedge funds face less regulation than publicly traded mutual funds

This allows them to hold substantial short positions to preserve capital during market downturns

Typically, hedge fund managers generate profit from both long as well as short positions

It is the practice of shorting and the leveraging of investors’ capital that distinguish hedge funds from conventional long-bias funds

 

Performing Due Diligence

Due diligence is the term used to describe the process of evaluation and analysis that an investor follows to get comfortable with a strategy, a manager, and a fund prior to making an investment

 

The steps of due diligence

Due diligence includes all the steps that are needed to get to know:

Why and how a fund came into being

The skills its founders or current partners claim to have mastered

The evaluation of the timeliness, accuracy, and consistency of manager and fund information

The reliability and independence of service providers; and far more

 

The skill sets needed to run a hedge fund

Investors would be wise to assess all three skill sets needed to run a modern-day hedge fund:

  • Investment
  • Operational
  • Business skills

 

The segments of the due diligence process

This segment organizes the due diligence process into four sections:

The Investment process

Risk management

Operational environment

Business model assessment

 

In closing

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