世界銀行-發(fā)展中國家移動貨幣公司破產(chǎn)：決策者綜述（英）-2024

FINANCEE

Q

U

I

T

A

B

L

E

G

R

O

W

T

H

,

F

I

N

A

N

C

E

&

I

N

S

T

I

T

U

T

I

O

N

S

N

O

T

E

SInsolvency

of

Mobile

MoneyFirmsinDeveloping

CountriesOverview

for

PolicyMakersAndresF.

Martinez,

WillPaterson,andJonathanGreenacre?

2023InternationalBank

forReconstructionand

Development/

TheWorld

Bank1818H

Street

NW,

Washington

DC20433Telephone:

202-473-1000;Internet:

This

work

is

a

product

of

the

staff

of

The

World

Bank

with

external

contributions.

The

?ndings,interpretations,

and

conclusions

expressed

in

this

work

do

not

necessarily

re?ect

the

views

of

TheWorld

Bank,

its

BoardofExecutiveDirectors,

or

thegovernments

they

represent.The

World

Bank

does

not

guarantee

the

accuracy,

completeness,

or

currency

of

the

data

includedin

this

work

and

does

not

assume

responsibility

for

any

errors,

omissions,

or

discrepancies

inthe

information,

or

liability

with

respect

to

the

use

of

or

failure

to

use

the

information,

methods,processes,

or

conclusions

set

forth.

The

boundaries,

colors,

denominations,

and

other

informationshown

on

any

map

in

this

work

do

not

imply

any

judgment

on

the

part

of

The

World

Bank

concerningthelegalstatus

ofany

territoryorthe

endorsement

oracceptanceofsuchboundaries.Nothing

herein

shall

constitute

or

be

construed

or

considered

to

be

a

limitation

upon

or

waiver

oftheprivilegesandimmunitiesof

TheWorld

Bank,allof

whichare

speci?callyreserved.Rights

and

PermissionsThe

material

in

this

work

is

subject

to

copyright.

Because

The

World

Bank

encourages

disseminationof

its

knowledge,

this

work

may

be

reproduced,

in

whole

or

in

part,

for

noncommercial

purposes

aslongas

full

attributiontothis

work

is

given.Any

queries

on

rights

and

licenses,

including

subsidiary

rights,

should

be

addressed

to

World

BankPublications,

The

World

Bank

Group,

1818HStreet

NW,

Washington,

DC

20433,

USA;fax:202-522-2625;

e-mail:pubrights@.Coverphoto:S.

Further

permission

requiredforreuse.>>>AcknowledgmentsThis

note

was

authored

by

Andres

F.

Martinez,

Will

Paterson

(Finance,Competitiveness

and

Innovation

Global

Practice,

World

Bank

Group),

andJonathan

Greenacre

(Boston

University).

The

authors

thank

those

who

providedcomments,

inparticular:

Holti

Banka,

Harish

Natarajan,

Ahmed

Taw?k

Rostom,Matthew

Saal

and

Gynedi

Srinivas

(World

Bank

Group);

Stefan

Staschen

andPatrick

Meagher

(CGAP);

Teresa

Rodriguez

de

las

Heras

Ballell

(UniversidadCarlos

IIIdeMadrid);andtheFCIGlobalInsolvency&

Debt

Resolution

Team.The

authors

are

also

grateful

to

World

Bank

colleagues

Jean

Pesme

(GlobalDirector,

Finance),

Mahesh

Uttamchandani

(former

Practice

Manager,

EFNFI)andNirajVerma

(actingPracticeManager,

EFNFI)for

theirguidance.>>>ContentsAcknowledgmentsOverview355Addressinsolvencyin

theregulationof

mobilemoney

toprotectusersand

theeconomy1.

The

Treatment

of

Mobile

Money

Firms

in

DomesticInsolvency

Frameworks72.

Major

Risks

to

Funds

as

a

Result

of

Insolvency2.1

Lossof

Value

Risk2.2

IlliquidityRisk1010113.

Mitigation

Tools3.1

Trust

Model12123.2

Custodian133.3

SpecializedRegimes4.

Conclusion14151618AppendixEndnotesEQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<4>>>OverviewInsolvency

of

Mobile

Money

Firms

inDeveloping

CountriesThis

Note

provides

an

overview

of

the

challenges

policy

makers

may

encounterwhenamobile

money

?rm

becomes

insolvent.

Such

?rms

would

likely

be

subject

to

corporateinsolvency

laws.

Existing

mitigation

tools

meant

to

safeguard

customers’

funds

may

facelegal

and

logistical

problems

unless

they

are

coordinated

with

the

country’s

standardinsolvency

system.

Customers

may

lose

funds

and/or

not

have

quick

access

to

them.TheNote

alsohighlights

several

areas

requiringfurther

research.Address

insolvency

in

the

regulation

of

mobile

money

toprotect

users

and

the

economyE-money

services

have

become

increasingly

popular,

particularly

in

developing

countries.

These1services,

o?ered

by

providers

other

than

traditional

banks,

enable

customers

to

deposit,

store,transfer

value,

and,

in

some

cases,

convert

e-money

back

into

cash.

A

key

e-money

service

ismobile

money.ment

service,

provided

by

nonbank

entities,

that

enables

people

to

deposit,

store,

transfer,

andwithdraw

electronic

funds

back

into

cash.

The

term

mobile

money

?rm

refers

to

?rms

provid-2For

the

purposes

of

this

Note,

the

term

mobile

money

refers

to

an

electronic

pay-3ing

mobile

money.

Depending

on

the

regulatory

framework,

these

?rms

include

mobile

networkoperators(MNO),subsidiaries

of

MNOs,

and?rms

unrelatedtoan

MNO.

First

launchedin2004,mobile

money

accounts

now

number

over

one

billion

in

95

developing

countries

and

processa

combined

US$2

billion

in

transactions

daily.

The

COVID-19

pandemic

accelerated

the

use

ofmobile

money

and

other

e-money

services,

as

many

countries

lowered

transaction

costs

andincreased

limitsto

incentivize

contactless

transactions.Mobilemoney

has

greatly

bene?tted

millions

of

people

in

developing

countries.

The

servicehasbeen

especially

impactful

where

customers

have

less

access

to

traditional

bank

accounts

andmobile

phone

penetration

is

high,

providing

users

with

an

alternative

way

to

store,

transfer,

andpay

withmobilemoney.

At

thesame

time,

therapid

growthof

mobilemoney

raisessome

regula-EQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<5tory

concerns.

The

service

is

bene?cial

as

long

as

customerscan

quickly

and

readily

access

their

funds.

But

what

if

a

mobilemoney

?rm

becomes

insolvent?

Will

customers

still

be

able

touse

funds

during

the

?rm’s

insolvency

process?

Do

they

risklosingfunds?tor

said

were

in

place

were

not

properly

constituted.

Shortly5after

this

case,

the

UK

established

speci?c

regulations

ad-dressingtheinsolvency

of

e-money

?rms.In

a

developing

country

where

mobile

money

plays

a

criticalrole

in

servicing

low-income

populations,

the

insolvency

of

ane-money

?rm

like

Ipagoo

could

cause

loss

or

delay

in

accessto

funds

for

those

who

need

them

the

most.

In

severe

cases,such

an

insolvency

could

damage

the

credibilityof

themobilemoney

system

and

the

economy

more

broadly.

While

we

arenot

aware

of

a

mobile

money

?rm

insolvency

in

a

developingcountr

y,

it

is

important

forpolicy

makers

to

put

in

place,

review,and,

where

necessary,

strengthen

fund

safeguarding

frame-works

that

ensure

adequate

coordination

with

applicable

in-solvency

rules.

Ideally,

policy

makers

should

review

fundsafe-guarding

rules

before

a

mobile

money

?rm

becomes

insolvent.Waiting

until

an

insolvencyoccurswould

likelycompoundlossand

disruption

for

customers.

This

is

because

there

may

be

anextensive

delay

whilecourtsand

otheractorsclarifywhatpro-tectionsare

available

and

how

e?ectively

they

operate.This

Note

provides

an

overview

for

policy

makers

of

the

risksof

not

having

robust

mechanisms

in

place

to

deal

with

mo-bile

money

?rm

insolvency.

A

broad

perception

in

the

marketis

that

most

of

the

risks

associated

with

such

insolvencies

aremitigated

by

regulatory

measures,

known

as

fund

safeguard-ing

rules,

imposed

to

protect

funds

provided

by

customers(“funds”).

The

closer

analysis

provided

here

shows

that

a

coun-try’s

policy

makers

may

conclude

that

current

risk

mitigationarrangements

may

be

inadequate,

especially

when

evaluatedin

the

context

of

the

national

corporate

insolvency

systems

un-der

which

these

arrangements

would

be

activated.

This

Notefocuses

solely

on

corporate

insolvency

issues

related

to

mobilemoney

?rms;it

does

not

analyze

other

relevant

areas,

such

as?nancial

supervision,

several

of

which

are

also

important

andcouldbe

thesubjectof

a

separate

study.Several

tools

commonly

used

to

protect

funds

can

serve

asstarting

points

for

analyzing

the

e?ectiveness

of

a

country’sfund

safeguarding

framework.

See

the

Appendix

for

a

list

ofquestions

policy

makers

can

use

to

begin

the

review

process.This

Note

does

not

provide

recommendations

on

which

toolsto

use,

nor

does

it

exhaustively

cover

all

the

issues

that

mayarise

following

the

insolvency

of

amobile

money?rm.

Further-more,a

policy

maker

should

consider

the

speci?c

operational,regulatory,

and

legal

context

of

the

country

when

examiningthe

problems

raised

below.

The

key

issues

introduced

by

thisNoteare:In

most

countries,

no

speci?c

laws

or

regulations

address

theinsolvency

of

a

mobile

money

?rm.

By

default,

then,

if

thesecompanies

become

?nancially

distressed,

their

insolvencies(including

possible

reorganization

of

viable

?rms

and

liquida-tion

of

?rms

that

cannot

be

saved)

would

fall

under

the

domes-tic

corporate

insolvency

law

of

the

country

in

which

the

mo-bile

money

?rm

is

incorporated.

Critically,

therefore,

for

each4country

in

which

mobile

money

?rms

operate,

the

insolvencyrules

may

not

fully

recognize

the

asset

segregation

of

fundsafeguarding

rules

nor

give

priority

to

mobile

money

accountholdersrelative

to

other

liabilities.

This

could

result

in

aloss

ofvalueandloss

of

liquidity

to

the

accountholders.1.

The

importance

of

reviewing

the

treatment

of

mobile

money?rms

undera

country’s

insolvencyframework;2.

Majorriskstofunds;andThe

recent

insolvency

of

the

British

e-money

?rm

Ipagoo

inwhich

United

Kingdom

electronic

money

regulations

were

putto

the

test

(explored

further

below)

illustrates

this.

Domesticcourts

addressing

the

insolvency

provided

guidance

on

fundsafeguarding

rules,?ndingthatcertain

protectionsthe

regula-3.

Key

mitigation

tools

to

safeguard

funds

and

the

possiblelimitations

of

these

tools

vis-à-vis

the

corporate

insolvencysystem.EQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<61.>>>The

Treatment

of

Mobile

MoneyFirms

in

Domestic

InsolvencyFrameworksA

key

regulatory

difference

between

banking

and

mobile

money

is

the

insolvencyregimetowhich

each

issubject.

These

usually

breakdownas

follows:?

Banks

are

subject

to

special

resolution

tools

that

maintain

access

to

services

duringtimesof

?nancialdistressand

providea

special

regimefor

customers.?

Mobilemoney?rms

are

subject

toa

country’s

regularcorporate

insolvency

regime.Given

that

the

mobile

money

industry

is

relatively

new,

most

corporate

insolvency

laws

do

not6containspeci?cprovisions

regarding

the

insolvency

of

a

mobile

money?rm.

Mobile

money?rmsareuniqueamongnon-bank

businesses

in

that

they

receive

considerable

amountsof

fundspro-vided

by

customers

who

then

rely

on

the

?rms

to

provide

functionality

to

complete

day-to-daytransactions

through

services

similar

in

many

ways

to

those

provided

by

the

banking

industr

y.

Likefunds

held

in

a

bank,

a

person

can

deposit,

store,

transfer,

and,

in

some

cases,

withdraw

cashfromtheir

mobile

money

account;insomeinstances,

mobilemoney

accountspay

interest.

How-7ever,while

banks

have

specialized

insolvency

resolution

regimes

to

address

the

speci?c

needs

ofdepositors,mostmobilemoney?rms

wouldcomeundergeneralinsolvency

laws

that

donot

givespecialstatus

to

accountholderssimilar

to

that

given

to

bank

depositors.

Mobile

moneyaccountholders

are

likely

to

be

classi?ed

as

unsecured

creditors

(despite

the

issuer’s

mobile

moneyaccount

nominally

being

backed

by

cash

or

securities),

unless

structures

to

safeguard

fundsexist

and

are

enforceable

under

the

general

bankruptcy

law.

For

these

reasons,

it

is

important

thatregulators

properly

understand

the

dynamic

between

their

country’s

corporate

insolvency

systemand

whatever

mechanisms

are

in

place

to

mitigate

the

negative

impacts

on

customers

caused

bythe

insolvency

of

a

mobilemoney?rm.Despitethe

similarities

noted,banksandmobilemoney?rms

areregulateddi?erently,

including8with

respect

to

the

applicable

insolvency

regime.

In

most

countries,

default

of

a

bank

is

treatedconsiderably

di?erently

than

default

of

a

mobile

money

?rm.

Banks

are

usually

subject

to

a

rangeof

emergency

regulatory

tools

that

exempt

them

from

the

corporate

insolvency

law.

Such

tools9EQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<7usuallyincludeacombinationof

depositguaranteeschemes,emergency

liquidity

assistance

facilities,

and

special

resolu-tionregimes.tional

legislation

to

safeguard

funds,

including

provisions

thatthe

funds

not

be

commingled

with

other

funds

provided

bye-money

users.

Fur

ther,

that

the

funds

“shall

be

insulated

.

.

.against

the

claims

of

other

creditors

of

the

payment

institu-tion,

in

particular

in

the

event

of

insolvency.”15

Ultimately

in

theIpagoo

case,

the

EMRs

were

“construed

as

a

means

chosento

implement

the

insulation

provisions.”16

The

Court

found

thatthe

EMRs

and

the

EU

Directives

provide

that

e-money

holdersare

granted

rights

in

priority

to

other

creditors;

e-money

hold-ers

are

“intended

to

stand

apart

from

the

normal

insolvencyregime

and

should

only

bear

the

costs

associated

with

dis-tributing

it.”17

Fur

ther,

even

though

not

necessary

for

the

?naldecision,

the

Court

found

that

the

insolvency

provisions

inthe

EMRs,

given

their

status

of

transposing

an

EU

Directive,18could

havethe

potential

to

change

the

priorities

in

the

corporateinsolvency

law.19

A

key

conclusion

from

the

case

is

important

tohighlight:

the

application

of

the

EU

rules

had

the

ultimate

e?ectof

protecting

customers

who

provided

the

funds.

Had

the

EUlegislation

not

been

applicable

to

the

Ipagoo

case,

the

solutionwould

have

been

di?erent.

It

is

likely

that

the

provisions

con-tained

in

the

UK’s

EMR

would

have

been

insu?cient

to

ensurethat

the

funds

were

su?ciently

protected

in

the

case

that

Ipa-goo

did

not

meet

the

requirement

to

segregate

those

funds—which

iswhat

happenedinpractice.While

to

date

no

major

mobile

money

?rm

has

become

insol-vent,

?rms

providing

other

e-money

services

havefailed,

dem-onstrating

the

importance

of

clarifying

fund

safeguarding

rules.One

such

e-money

?rm

is

Ipagoo

LLP

(“Ipagoo”),

the

subjectof

the

recent

England

and

Wales

Court

of

Appeal

case10

ReIpagoo

LLP

(In

Administration)(2022)

EWCACiv

302,

in

whichthe

fund

safeguarding

rules

applicable

to

e-money

were

put

tothetest.

Thecasehighlighteda

key

lesson:if

an

e-money?rmfails,

and

it

is

not

subject

to

bank

regulation,

it

will

likely

be

sub-ject

to

a

country’s

regular

corporate

insolvency

law,

exposingcustomers’

fundstoa

rangeof

risks.In

August

2019,

Ipagoo

became

insolvent

and

went

into

ad-ministration.11

The

UK

Electronic

Money

Regulations

(2011)(“EMRs”),

which

implemented

the

European

Union

ElectronicMoney

Directive,

required

Ipagoo

to

safeguard

the

funds

pro-vided

by

customers.

It

was

not

possible

for

the

Administratorsto

determine

whether

the

funds

were

properly

safeguarded,and

Ipagoo

was

likely

in

serious

non-compliance

with

theEMRs.12

OnceIpagoobecameinsolvent,

it,like

other

e-moneyproviders,

was

subject

to

the

UK’s

regular

corporate

insol-vency

regime.

The

Administrators

of

Ipagoo

asked

the

Courtfor

guidance

on

how

to

distribute

the

funds

and

whether

theEMRscreateda

statutorytrustthatwouldsegregate

the

fundsprovided

by

customers

from

other

assets

of

the

company.One

of

the

key

issues

for

the

Court

to

decide

was

whetherthe

EMRs’

insolvency

provision13

would

be

applicable,

ratherthan

the

regular

creditor

payment

priorities

established

by

thecorporate

insolvency

law.

Ultimately,

reviews

at

the

trial-

andappeals-court

levels

were

required

to

clarify

the

precise

op-eration

of

fund

safeguarding

rules,

causing

a

two-year

delaybetween

Ipagoo’s

insolvency

and

the

?nal

decision

regardingdistributionof

fundstocustomers.14Since

Ipagoo

went

insolvent,

the

UK

has

tried

to

?x

this

problemby

introducing

new

regulations

for

this

industry:

an

insolvencyprocedure

(called

“special

administration”)

for

payment

institu-tions

and

for

electronic

money

institutions,

which

is

discussedbelow.20

Many

other

countries,

particularly

in

the

developingworld,

have

not

introduced

specialized

insolvency

regimes

formobile

money

?rms

or

updated

their

basic

fund

safeguardingrules.

This

could

put

funds

atrisk.

For

example,

Kenya

and

Tan-zania,

two

countries

with

major

mobile

money

sectors,

have

notamended

their

fund

safeguarding

rules

since

2014

and

2015respectively,

despite

signi?cant

growth

of

this

service

and

itsimportance

to

the

countries’

economies.21

Although

both

Kenyaand

Tanzania

havea

range

of

protections

against

loss

of

valueand

illiquidity,

as

explained

below,

it

is

unclear

how

some

toolswilloperate

inpractice,

such

asaccelerated

fundsdispersal.The

Ipagoo

case

also

involved

two

European

Union

(EU)

di-rectives

related

to

e-money:

Electronic

Money

Directive

(EMD)(2009/110/EC)

and

the

Second

Payment

Services

Directive(PSD2)

(2015/2366/EU).

As

with

all

EU

Directives,

these

pro-visions

had

not

immediately

been

made

part

of

the

domesticlegislation

of

the

member

countries:

each

member

countryis

required

to

transpose

them

to

national

legislation.

The

e-money

Directives

required

EU

Member

States

to

establish

na-For

several

reasons,

inadequate

fund

safeguarding

ruleswould

likely

create

more

serious

problems

in

developing

coun-tries

than

the

Ipagoo

insolvency

created

in

the

UK.

First,

mo-bile

money,

by

enabling

people

to

use

it

as

a

form

of

savings,has

a

wider

functionality

than

Ipagoo’s

service.

Fur

ther,

mobileEQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<8money

servicesnormallyhave

anetworkof

agents,

whichen-able

users

to

convert

mobile

money

into

cash

withouthaving

atraditional

bank

account.

In

Sub-Saharan

Africa,

15

percent

ofadults

have

used

a

mobile

money

account

to

save.22

This

is

be-cause

some

mobile

money

services

enable

customers

to

storefunds

in

their

accounts

and

even

to

obtain

interest.23

This

couldmean

that

the

insolvency

of

a

mobile

money

?rm

can

causepeopleinthesecountries

to

loseaportionof

their

longer-termsavings

inadditiontotheir

transactionfunds.the

speci?c

trust

(or

fund-separating

mechanism)

has

beenestablished.25Third,

mobile

money

plays

a

more

signi?cant

role

in

the

econo-mies

of

manydeveloping

countries

than

in

those

of

developedcountries,

to

the

point

thatthe

service

mayrepresent

a

form

of“systemic

risk.”

This

means

that

failure

of

one

or

more

mobilemoney

?rmsmay

signi?cantly

damage

the?nancialandwidereconomic

system

of

a

developing

countr

y.

For

example,

by2014,

M-Pesa

processed

66.56

percent

of

the

volume

of

na-tional

payments

in

Kenya.

Collapse

of

this

service

would

there-fore

have

a

comparatively

bigger

impact

inKenya

than

it

wouldin

jurisdictionswheremobile

money

is

less

widely

used.Whileno

mobile

money

?rm

in

a

developing

country

has

becomeinsolvent,

occasional

short-termoutages

of

e-money

services(ranging

in

duration

from

one

to

two

hours

to

three

to

four

days)have

occurred

in

several

countries,

and

each

of

these

outagesimposed

signi?cant

costs

on

the

a?ected

communities.

Theextent

of

such

costs

suggests

that

the

insolvency

of

a

majormobile

money

?rm,

which

might

cause

a

disruption

of

sever-al

years,

could

be

seriously

damaging

to

local

economies.26Second,

in

many

developing

countries,

regulatory

and

legalframeworks

for

insolvency,

and

their

implementation,

often

failto

comply

with

existing

good

international

practices,

such

asthose

set

out

in

the

World

Bank

Principles

for

E?ective

Insol-vency

and

Creditor/Debtor

Regimes.24

This

means

it

is

evenmore

di?cult

for

policy

makers

to

predict

how

a

court

and

re-lated

bodies

will

resolve

a

failing

mobile

money

?rm.

In

turn,thismeansitisdi?culttopredicthow

fund

safeguardingruleswill

operate,

particularly

regarding

the

extent

to

which

the

rulesprotect

funds.

Even

in

countries

where

the

insolvency

systemworks

well,

issues

mayarise

related

to

trust

law

or

the

way

thatEQUITABLEGROWTH,FINANCE&INSTITUTIONSNOTE

|

INSOLVENCY

OF

MOBILEMONEY

FIRMSINDEVELOPINGCOUNTRIES

<<<92.>>>Major

Risks

to

Funds

asa

Result

of

InsolvencyA

country’s

corporate

insolvency

regime

can

expose

funds

provided

by

customers

to

two

types

ofrisk:lossof

value

and

illiquidity.27

These

risks

depend

on

how

the

domestic

legalframeworkclas-si?esthecustomerswho

provided

those

funds,particularlywhetherthey

are

treatedascreditorsof

the

insolvent

debtor

or

remain

“outside”

the

corporate

insolvency

proceeding.

This

classi?ca-tion

will

depend

on

a

range

of

domestic

factors.28

However,

without

any

regulatory

mechanismsinplacethat

deal

with

thesecreditorsspeci?cally,

it

is

likely

that

mobile

money

customerswill

beclassi?ed

as

unsecured

creditors.29

The

extent

to

which

the

insolvency

regime

complies

with

goodinternational

practices

also

impacts

thescaleof

theserisks.30Manycountrieshave

implemented

mitigation

tools

(analyzed

in

Section3

below)designedto

ad-dress

some

of

the

risks.

The

discussion

in

this

section

focuses

on

the

possible

di?culties

that

theapplication

of

the

corporate

insolvency

law

could

generate

in

the

absence

of

any

mechanism

tosafeguard

the

funds

provided

by

customers.2.1

Loss

of

Value

RiskThe

mostlikely

scenario,

in

the

absence

of

speci?crulesto

prevent

it,

is

thatcustomersthatpro-vided

funds

to

the

debtor

will

be

treated

as

unsecured

creditors.

In