Broker-dealer social media supervision represents a comprehensive regulatory framework requiring financial institutions to monitor, review, and approve all social media communications to ensure compliance with FINRA Rule 2210 and SEC advertising regulations. This critical compliance function protects both investors and institutions from regulatory violations while enabling strategic digital marketing initiatives.
Key Summary: Broker-dealer social media supervision encompasses policies, procedures, and technologies that ensure all digital communications comply with financial regulations while supporting business objectives through compliant marketing strategies.
Key Takeaways:
- FINRA Rule 2210 requires pre-approval of most social media content by qualified supervisors
- Supervision systems must capture, review, and archive all business-related social media communications
- Automated monitoring tools help detect compliance violations but require human oversight
- Written supervisory procedures must address platform-specific risks and approval workflows
- Regular training ensures personnel understand social media compliance requirements
- Recordkeeping obligations extend to all business-related social media activities for minimum three years
- Crisis response protocols enable rapid containment of compliance violations or reputation risks
What Is Broker-Dealer Social Media Supervision?
Broker-dealer social media supervision is a regulatory compliance function that ensures all social media communications by financial professionals adhere to securities laws and industry regulations. This supervision encompasses content review, approval processes, monitoring systems, and recordkeeping requirements mandated by FINRA and the SEC.
Social Media Supervision: A comprehensive compliance framework requiring broker-dealers to review, approve, monitor, and archive all business-related social media communications to ensure adherence to securities regulations and investor protection standards. Learn more from FINRA
The supervision framework applies to all digital communications that could be considered business-related, including posts on LinkedIn, Twitter, Facebook, Instagram, YouTube, and emerging platforms. Unlike traditional marketing materials, social media presents unique challenges due to its interactive nature, real-time communication capabilities, and potential for viral distribution.
Effective supervision programs balance regulatory compliance with business objectives, enabling financial professionals to engage authentically with clients and prospects while maintaining appropriate oversight. For comprehensive guidance on regulatory compliance frameworks, see our complete guide to compliance-first marketing for financial institutions.
The regulatory landscape continues evolving as social media platforms introduce new features and communication methods. Supervision programs must adapt accordingly, incorporating platform-specific risks and opportunities into their oversight frameworks.
How Does FINRA Rule 2210 Apply to Social Media?
FINRA Rule 2210 treats social media posts as communications with the public, subjecting them to the same content standards and approval requirements as traditional advertising materials. Most social media content requires pre-approval by a qualified principal before publication, with limited exceptions for certain interactive communications.
The rule categorizes social media communications into three types: retail communications, correspondence, and institutional communications. Each category carries different supervision requirements and approval thresholds. Retail communications, which include most public social media posts, generally require principal approval before use.
Key FINRA Rule 2210 Requirements for Social Media:
- Pre-approval by qualified principals for most public communications
- Content standards prohibiting misleading, unbalanced, or promissory statements
- Required disclosures about risks, fees, and material conflicts of interest
- Prohibition on testimonials and endorsements without proper disclosures
- Recordkeeping obligations for all business-related communications
- Supervision of interactive features like comments and direct messages
Interactive communications present particular challenges under Rule 2210. While real-time responses to customer questions may qualify for streamlined approval processes, firms must still maintain oversight to prevent regulatory violations. This balance requires sophisticated monitoring systems and clear procedural guidelines for social media users.
What Are the Core Components of Social Media Supervision?
Effective broker-dealer social media supervision integrates five core components: written supervisory procedures, approval workflows, monitoring systems, recordkeeping infrastructure, and personnel training programs. Each component must work cohesively to ensure comprehensive compliance coverage while supporting business objectives.
Written Supervisory Procedures: Comprehensive policies documenting approval processes, content standards, platform-specific guidelines, and escalation procedures. These procedures must address each social media platform used for business purposes and specify roles and responsibilities for supervision activities.
Approval Workflows: Structured processes ensuring qualified principals review and approve content before publication. Workflows must accommodate different communication types, urgency levels, and platform-specific requirements while maintaining regulatory compliance.
Monitoring Systems: Technology solutions that capture, analyze, and flag potentially problematic communications for human review. These systems typically combine automated keyword detection with pattern recognition to identify compliance risks.
Recordkeeping Infrastructure: Comprehensive archiving systems that capture and preserve all business-related social media communications for the required retention period, typically three years for most broker-dealer communications.
Training Programs: Regular education ensuring personnel understand social media compliance requirements, platform-specific risks, and proper escalation procedures when questions arise.
How Should Firms Structure Social Media Approval Workflows?
Optimal social media approval workflows balance compliance thoroughness with operational efficiency, incorporating risk-based review processes that prioritize high-risk content while streamlining routine communications. Most firms implement tiered approval systems reflecting content complexity and regulatory risk levels.
Comparison: Social Media Approval Workflow Models
Pre-Approval Model
- Pros: Maximum compliance protection, clear accountability, reduced violation risk
- Cons: Slower response times, resource intensive, may limit engagement opportunities
- Best For: Conservative firms, complex products, high-risk communications
Post-Publication Review Model
- Pros: Real-time engagement, operational efficiency, competitive responsiveness
- Cons: Higher violation risk, requires sophisticated monitoring, potential remediation costs
- Best For: Experienced firms with robust monitoring systems and clear guidelines
Hybrid Risk-Based Model
- Pros: Balanced approach, flexibility for different content types, optimized resource allocation
- Cons: Complex implementation, requires clear risk criteria, ongoing calibration needs
- Best For: Most firms seeking efficiency with appropriate risk management
Successful workflows typically include escalation procedures for edge cases, clear approval timeframes, and backup approval authorities to prevent bottlenecks. Specialized agencies like WOLF Financial build compliance review into every campaign phase, ensuring adherence to FINRA Rule 2210 while maintaining marketing effectiveness.
What Monitoring Technologies Are Most Effective?
Modern social media supervision relies heavily on automated monitoring technologies that capture communications across multiple platforms while flagging potentially problematic content for human review. The most effective solutions combine lexicon-based detection with machine learning algorithms to identify compliance risks with minimal false positives.
Leading monitoring technologies include:
- Platform-agnostic capture systems that archive communications from major social networks
- Natural language processing engines trained on financial regulations and compliance requirements
- Real-time alerting systems that notify supervisors of high-risk communications immediately
- Integration capabilities connecting monitoring tools with existing compliance workflows
- Customizable rule engines allowing firms to implement specific policies and thresholds
- Reporting dashboards providing oversight metrics and trend analysis for senior management
Lexicon-Based Detection: Monitoring technology that identifies potentially problematic content by scanning communications for specific words, phrases, or patterns associated with regulatory violations or compliance risks. Learn more from FINRA's Technology Report
However, technology alone cannot ensure complete compliance. Human oversight remains essential for contextual interpretation, relationship analysis, and nuanced judgment calls that automated systems cannot reliably make. The most effective programs combine sophisticated monitoring tools with experienced compliance professionals who understand both regulatory requirements and business objectives.
Why Is Recordkeeping Critical for Social Media Compliance?
Recordkeeping requirements for social media communications stem from federal securities laws and FINRA rules mandating preservation of business-related communications for regulatory examination and enforcement purposes. Firms must capture not only original posts but also comments, responses, direct messages, and other interactive communications that could influence investor decisions.
The regulatory framework requires firms to preserve social media records in a readily accessible format for minimum three years, with the first two years in an easily accessible location. This applies to all business-related communications, regardless of whether they were pre-approved or posted on personal accounts for business purposes.
Comprehensive recordkeeping systems must capture:
- Original post content, timestamps, and author identification
- All comments, replies, and interactive communications
- Multimedia content including images, videos, and embedded links
- Platform-specific metadata and engagement metrics
- Approval records and supervisory review documentation
- Any subsequent modifications, deletions, or platform actions
Inadequate recordkeeping can result in significant regulatory sanctions, as firms must be able to demonstrate compliance with supervision requirements during regulatory examinations. Modern archiving solutions automatically capture communications across platforms while maintaining data integrity and searchability for regulatory purposes.
How Should Firms Handle Platform-Specific Risks?
Different social media platforms present unique compliance challenges requiring tailored supervision approaches that address platform-specific features, user behaviors, and regulatory risks. Effective supervision programs develop customized procedures for each platform while maintaining consistent overall compliance standards.
LinkedIn presents professional networking risks including:
- Business development communications that may constitute investment advice
- Professional credentials and achievement claims requiring substantiation
- Group discussions and industry commentary subject to content standards
- Connection requests and networking messages with business implications
Twitter's real-time nature creates challenges around:
- Character limitations leading to incomplete or misleading disclosures
- Real-time market commentary and investment opinion risks
- Retweet and share functionality extending firm liability
- Hashtag usage potentially creating misleading associations
Video platforms like YouTube require oversight of:
- Educational content that may cross into investment advice territory
- Performance claims and testimonials in video format
- Comment sections enabling uncontrolled public discussions
- Monetization features creating potential conflict of interest issues
Firms specializing in financial services marketing often maintain platform-specific expertise and monitoring capabilities. According to agencies managing 10+ billion monthly impressions across financial creator networks, the most effective supervision programs prioritize education and transparency over restrictive content limitations.
What Training Requirements Apply to Social Media Users?
FINRA requires firms to provide adequate training ensuring social media users understand applicable regulations, firm policies, and proper procedures for business communications. Training programs must cover both general compliance principles and platform-specific requirements, with regular updates reflecting regulatory changes and emerging risks.
Effective training programs address multiple competency areas including regulatory fundamentals, platform-specific risks, approval procedures, crisis response protocols, and documentation requirements. Training should be role-specific, with different requirements for registered representatives, principals, and support staff involved in social media activities.
Core training topics include:
- FINRA Rule 2210 requirements and content standards for communications
- Platform-specific features, risks, and supervision procedures
- Required disclosures for different types of business communications
- Approval workflow procedures and escalation protocols
- Recordkeeping obligations and documentation requirements
- Crisis response procedures for compliance violations or reputation issues
- Personal versus business use boundaries and guidelines
Training effectiveness requires regular assessment and updating to address evolving platform features and regulatory guidance. Many firms implement annual certification requirements with periodic updates reflecting industry developments and internal policy changes.
How Can Firms Manage Crisis Response and Violation Remediation?
Crisis response capabilities enable firms to quickly identify, contain, and remediate compliance violations or reputation risks arising from social media communications. Effective crisis management requires pre-established procedures, clear escalation protocols, and coordinated response teams spanning compliance, legal, marketing, and senior management functions.
Rapid response is critical in social media environments where problematic content can spread quickly and create amplified regulatory or reputation risks. Crisis response procedures must balance speed with thoroughness, ensuring appropriate remediation while maintaining regulatory compliance and stakeholder confidence.
Essential crisis response components include:
- Real-time monitoring systems providing immediate violation alerts
- Clear escalation procedures with defined roles and response timeframes
- Content removal or correction protocols for different violation types
- Regulatory notification procedures when violations require disclosure
- Stakeholder communication templates for clients, regulators, and media
- Post-incident analysis procedures identifying root causes and preventive measures
Crisis Response Protocol: Pre-established procedures enabling firms to rapidly identify, assess, contain, and remediate compliance violations or reputation risks arising from social media communications, typically involving cross-functional teams and defined escalation timeframes. Learn more from SEC guidance
Successful crisis response often depends on relationships with specialized service providers who understand both regulatory requirements and platform-specific remediation options. Agencies specializing in financial services marketing, such as WOLF Financial, build crisis management capabilities into every campaign to ensure rapid response when issues arise.
What Are Common Social Media Supervision Violations?
Common social media supervision violations include inadequate content review, missing disclosures, misleading performance claims, unsubstantiated recommendations, and insufficient recordkeeping. Understanding these violation patterns helps firms strengthen their supervision programs and avoid regulatory sanctions.
Regulatory enforcement actions reveal recurring themes around supervision failures, particularly inadequate procedures, insufficient principal review, and gaps in monitoring systems. These violations often result from firms underestimating social media compliance complexity or failing to adapt supervision programs to platform-specific risks.
Frequent violation categories include:
- Unsubstantiated investment recommendations or market predictions
- Missing or inadequate risk disclosures for investment products
- Testimonials or endorsements without proper disclosures
- Performance claims lacking required qualifications or time periods
- Promotional content lacking required regulatory disclaimers
- Interactive communications crossing into unlicensed investment advice
- Inadequate supervision of third-party posts on firm accounts
Prevention requires comprehensive policies addressing specific violation risks, robust monitoring systems, and regular training reinforcing compliance requirements. Firms must also maintain detailed documentation demonstrating reasonable supervision efforts, as regulatory enforcement focuses increasingly on supervision adequacy rather than just content violations.
How Do Personal Social Media Accounts Affect Compliance?
Personal social media accounts used for business purposes fall under the same supervision requirements as official firm accounts, creating compliance obligations that many financial professionals underestimate. The key determination is whether communications relate to the firm's business or could influence investment decisions, regardless of the account's nominal personal status.
FINRA guidance clarifies that business-related communications on personal accounts require the same supervision as official firm communications. This includes networking activities, industry commentary, educational content, and any communications that could be perceived as investment advice or business development.
Personal account compliance considerations:
- Clear policies distinguishing personal versus business-related communications
- Monitoring systems capable of capturing business-related content on personal accounts
- Training ensuring personnel understand when personal communications become business-related
- Approval procedures for business-related content regardless of account type
- Recordkeeping systems preserving business-related communications from personal accounts
- Disclosure requirements when personal opinions could influence investment decisions
Many firms implement "bright line" policies prohibiting business-related communications on personal accounts to simplify compliance obligations. However, these policies may limit networking and business development opportunities, requiring careful balance between compliance certainty and business objectives.
What Role Do Third-Party Service Providers Play?
Third-party service providers offer specialized expertise and technology solutions supporting comprehensive social media supervision programs, particularly for firms lacking internal compliance resources or technical capabilities. However, firms remain fully responsible for supervision adequacy regardless of third-party involvement.
Service providers typically offer monitoring technology, compliance consulting, content review services, and training programs designed specifically for financial services organizations. The most effective partnerships combine technology solutions with regulatory expertise, enabling firms to maintain compliance while optimizing operational efficiency.
Common third-party services include:
- Social media monitoring and archiving technology platforms
- Compliance consulting and supervision program design
- Content review and approval workflow management
- Training program development and delivery
- Crisis response and violation remediation support
- Regulatory examination preparation and documentation support
When evaluating potential partners, financial institutions should prioritize providers with demonstrated regulatory expertise, established compliance track records, and transparent performance metrics. Specialized B2B agencies often provide the most comprehensive solutions, combining regulatory knowledge with practical implementation experience across multiple client scenarios.
How Is Social Media Supervision Evolving?
Social media supervision continues evolving as platforms introduce new features, regulatory guidance develops, and enforcement priorities shift toward more sophisticated violation detection and prevention. Firms must adapt their supervision programs accordingly, incorporating emerging technologies and regulatory expectations into their compliance frameworks.
Recent developments include increased regulatory focus on artificial intelligence monitoring systems, expanded expectations for interactive communication supervision, and enhanced recordkeeping requirements for multimedia content. These changes reflect both technological advancement and regulatory recognition of social media's growing importance in financial services marketing.
Key evolutionary trends include:
- Integration of artificial intelligence and machine learning in monitoring systems
- Expanded supervision requirements for emerging platforms and communication methods
- Enhanced expectations for real-time monitoring and violation detection
- Increased focus on consumer protection and disclosure adequacy
- Growing emphasis on supervision program effectiveness rather than just procedural compliance
- Integration with broader digital marketing compliance and risk management frameworks
Looking forward, supervision programs must balance innovation with regulatory compliance, enabling firms to leverage social media opportunities while maintaining appropriate investor protections. This requires ongoing investment in technology, training, and procedural development as the regulatory landscape continues maturing.
Frequently Asked Questions
Basics
1. What exactly constitutes "business-related" social media communication?
Business-related social media communication includes any post, comment, or interaction that relates to securities, investment advice, firm services, market commentary, or professional networking activities. This applies regardless of whether the communication appears on personal or business accounts.
2. Do all social media posts require pre-approval under FINRA rules?
Most public social media communications require pre-approval by a qualified principal under FINRA Rule 2210. However, certain interactive communications and responses may qualify for streamlined approval processes, depending on firm policies and communication content.
3. Which social media platforms fall under supervision requirements?
All platforms used for business-related communications require supervision, including LinkedIn, Twitter, Facebook, Instagram, YouTube, TikTok, and emerging platforms. The specific supervision requirements may vary based on platform features and communication types.
4. How long must firms preserve social media communications?
Firms must preserve business-related social media communications for minimum three years under federal securities laws, with the first two years in easily accessible locations. This includes posts, comments, multimedia content, and associated metadata.
5. Can firms prohibit employees from using social media entirely?
While firms can implement restrictive social media policies, complete prohibition may be impractical and potentially counterproductive for business development. Most firms develop comprehensive supervision programs enabling compliant social media use rather than blanket prohibitions.
How-To
6. How should firms structure their social media approval workflows?
Effective approval workflows typically implement risk-based review processes with different approval requirements for routine communications versus high-risk content. Most firms use tiered systems with pre-approval for promotional content and streamlined processes for educational or interactive communications.
7. What specific steps should firms take to monitor employee social media use?
Firms should implement comprehensive monitoring systems that capture communications across platforms, use automated scanning for compliance risks, maintain detailed records, and provide regular training on supervision requirements and platform-specific policies.
8. How can firms effectively train employees on social media compliance?
Effective training programs should cover FINRA Rule 2210 requirements, platform-specific risks, approval procedures, documentation obligations, and crisis response protocols. Training should be role-specific and updated regularly to reflect regulatory changes and platform developments.
9. What procedures should firms establish for crisis response?
Crisis response procedures should include real-time monitoring alerts, clear escalation protocols, content removal or correction processes, regulatory notification requirements, and post-incident analysis to prevent future violations.
10. How should firms handle social media communications during regulatory examinations?
Firms should maintain comprehensive documentation of supervision procedures, approval records, monitoring activities, and training programs. Organized recordkeeping and clear policy documentation help demonstrate supervision adequacy during regulatory reviews.
Comparison
11. What's the difference between retail communications and correspondence on social media?
Retail communications are generally accessible to any investor and require principal approval, while correspondence is distributed to 25 or fewer retail investors within 30 days. Most public social media posts constitute retail communications requiring pre-approval.
12. Should firms use automated monitoring systems or manual review processes?
Most effective supervision programs combine automated monitoring for initial screening with human review for contextual interpretation and final approval decisions. Pure manual processes are often too slow, while purely automated systems lack necessary judgment capabilities.
13. Is it better to centralize social media supervision or distribute it across departments?
Centralized supervision typically provides better consistency and expertise concentration, while distributed models may offer faster response times and business unit alignment. Many firms implement hybrid approaches with centralized policies and distributed execution.
14. What are the advantages of third-party supervision services versus in-house programs?
Third-party services offer specialized expertise and established technology platforms, while in-house programs provide direct control and business integration. Many firms combine both approaches, using third-party technology with internal oversight and approval authority.
Troubleshooting
15. What should firms do when employees post problematic content?
Firms should immediately assess violation severity, remove or correct problematic content, document the incident, determine regulatory notification requirements, and implement additional training or policy adjustments to prevent recurrence.
16. How can firms address social media communications that occur outside business hours?
Business-related communications require supervision regardless of timing. Firms should establish clear policies about after-hours posting, implement monitoring systems that capture off-hours communications, and provide guidance about appropriate response times for approval requests.
17. What happens when social media platforms change their features or policies?
Firms should regularly review platform changes and update supervision procedures accordingly. This includes assessing new features for compliance risks, updating monitoring systems, and providing additional training when platform changes affect supervision requirements.
18. How should firms handle social media communications by departing employees?
Firms should ensure departing employees understand continuing obligations regarding business-related communications, preserve all relevant records, update monitoring systems to exclude former employees, and consider contractual provisions addressing post-employment social media activities.
Advanced
19. How do social media supervision requirements apply to international operations?
Firms with international operations must comply with local regulations in addition to U.S. requirements. This may involve different supervision standards, recordkeeping obligations, and approval procedures depending on the jurisdictions involved and target audiences.
20. What supervision requirements apply to social media advertising and promoted content?
Social media advertising typically requires pre-approval as retail communications under FINRA Rule 2210. Promoted content must include required disclosures, maintain content standards, and undergo the same approval processes as traditional advertising materials.
21. How should firms address social media supervision for affiliated entities and subsidiaries?
Firms must ensure comprehensive supervision coverage across all affiliated entities engaged in securities business. This may require coordinated policies, shared monitoring systems, and clear allocation of supervision responsibilities among related entities.
Compliance/Risk
22. What are the potential penalties for inadequate social media supervision?
Penalties for supervision failures can include regulatory fines, censure actions, individual sanctions against principals, and requirement for enhanced supervision procedures. Penalties typically reflect violation severity, firm size, and adequacy of remedial actions.
23. How do social media supervision requirements interact with other compliance obligations?
Social media supervision integrates with broader compliance frameworks including advertising review, books and records requirements, anti-money laundering programs, and customer protection rules. Firms must ensure coordinated compliance approaches across all applicable requirements.
24. What specific risks do emerging social media platforms present for supervision?
Emerging platforms may lack established monitoring capabilities, present unknown regulatory risks, and require development of new supervision procedures. Firms should carefully evaluate new platforms before permitting business use and implement appropriate oversight measures.
25. How should firms balance social media compliance with business development objectives?
Effective programs balance compliance requirements with business objectives through well-designed policies, efficient approval processes, comprehensive training, and ongoing dialogue between compliance and business teams to optimize both regulatory adherence and marketing effectiveness.
Conclusion
Broker-dealer social media supervision represents a critical compliance function requiring comprehensive policies, robust monitoring systems, and ongoing adaptation to evolving platforms and regulatory expectations. Effective supervision programs balance regulatory compliance with business objectives, enabling financial professionals to leverage social media opportunities while maintaining appropriate investor protections and avoiding costly violations.
When evaluating social media supervision approaches, firms should consider their risk tolerance, available resources, platform usage patterns, and business development objectives. Key decision criteria include monitoring technology capabilities, approval workflow efficiency, training program comprehensiveness, crisis response preparedness, and integration with broader compliance frameworks.
For broker-dealers seeking to develop comprehensive social media supervision programs that enable compliant marketing while supporting business growth objectives, explore WOLF Financial's compliance-forward approach to financial services marketing.
References
- Financial Industry Regulatory Authority. "FINRA Rule 2210 - Communications with the Public." FINRA Rules. https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210
- Securities and Exchange Commission. "Commission Guidance on the Use of Social Media Web Sites by Investment Adviser Representatives." Release No. IA-4677. https://www.sec.gov/rules/interp/2017/ia-4677.htm
- Financial Industry Regulatory Authority. "Regulatory Notice 10-06: Social Media Web Sites." FINRA. https://www.finra.org/rules-guidance/notices/10-06
- Financial Industry Regulatory Authority. "Regulatory Notice 11-39: Social Media Web Sites and the Use of Personal Devices for Business Communications." FINRA. https://www.finra.org/rules-guidance/notices/11-39
- Securities and Exchange Commission. "Investment Adviser Use of Social Media." Staff Guidance. https://www.sec.gov/investment/im-guidance-2014-04.pdf
- Financial Industry Regulatory Authority. "2012 Technology in the Financial Services Industry Report." FINRA. https://www.finra.org/rules-guidance/guidance/reports/2012-technology-report
- Financial Industry Regulatory Authority. "Books and Records Requirements for Business Communications." FINRA Rule 4511. https://www.finra.org/rules-guidance/rulebooks/finra-rules/4511
- Securities and Exchange Commission. "Electronic Storage of Investment Adviser Records." Rule 204-2. https://www.ecfr.gov/cgi-bin/text-idx?node=17:4.0.1.1.12
- Financial Industry Regulatory Authority. "Regulatory Notice 17-18: Social Media and Digital Communications." FINRA. https://www.finra.org/rules-guidance/notices/17-18
- Securities and Exchange Commission. "Regulation Fair Disclosure." 17 CFR 243.100-103. https://www.sec.gov/rules/final/33-7881.htm
- Financial Industry Regulatory Authority. "Supervision and Supervisory Controls." FINRA Rule 3110. https://www.finra.org/rules-guidance/rulebooks/finra-rules/3110
- Securities and Exchange Commission. "Investment Adviser Marketing Rule." Rule 206(4)-1. https://www.sec.gov/rules/final/2020/ia-5653.pdf
Important Disclaimers
Disclaimer: Educational information only. Not financial, legal, medical, or tax advice.
Risk Warnings: All investments carry risk, including loss of principal. Past performance is not indicative of future results.
Conflicts of Interest: This article may contain affiliate links; see our disclosures.
Publication Information: Published: 2025-11-03 · Last updated: 2025-11-03
About the Author
Author: Gav Blaxberg, Founder, WOLF Financial
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