COMMITMENT TO CHANGE: ELIMINATING OVERLAP AND DUPLICATION IN THE REGULATION OF THE TRUST AND LOAN INDUSTRY IN ONTARIO

October 1996

TABLE OF CONTENTS

EXECUTIVE SUMMARY

For the last decade, most trust and loan companies operating in Ontario have been subject to regulation by two levels of government: the government of the jurisdiction in which they were incorporated and which serves as their primary regulator (in most cases the federal government) and Ontario. Under Ontario's Loan and Trust Corporations Act, all companies wishing to carry on business in the province must comply with Ontario rules in order to register and operate in the province (a provision known as the "equals approach").

Since this statute was passed in 1987, the federal government and other provinces have undertaken major regulatory reforms, which have given companies incorporated in these jurisdictions the power to offer new types of products and services to their clients. However, because of Ontario's "equals approach", companies operating in the province must instead comply with its older and more restrictive provisions, which has hampered their ability to respond to the changing needs of their individual and business clients and to compete effectively against the banks and other financial institutions in a rapidly changing market.

On May 7, 1996, in the 1996 Ontario Budget Statement, the Minister of Finance announced that:

"We will extend the sunset provision of the Loan and Trust Corporations Act and take action to eliminate overlap in the regulation of the loan and trust industry. We will remove the outdated requirement that Ontario duplicate regulatory activities already undertaken by other jurisdictions in Canada. By harmonizing with federal regulations, we will get rid of an unnecessary layer of regulation of this important industry. We will set out our direction in a policy paper to be issued for public comment in the near future."

This paper sets out proposals and options for eliminating overlap and duplication in the regulation of trust and loan companies operating in Ontario. The intent of the government is to take steps to ensure that:

  • the interests of consumers continue to be effectively protected;

  • companies are able to compete in the provincial marketplace without the unnecessary constraints and costs imposed by regulatory duplication;

  • regulation is undertaken by the level of government best positioned to deliver it, in terms of expertise, experience and resources; and

  • to the greatest extent possible, companies and their clients can deal only with one regulatory agency and accountability for ensuring compliance with regulatory standards is clear.

To this end, the Ontario government plans to:

  1. Eliminate the "equals approach" from Ontario's legislation, so that trust and loan companies no longer have to comply with overlapping and conflicting sets of rules with respect to their business operations and organizational structure

  2. Consider alternative ways of ensuring consumers are protected to determine whether there is a continuing need for a separate regulatory program within the Ontario government, including:

    1. assessing the potential for moving towards a greater degree of self-regulation of trust and loan companies operating in Ontario

    2. exploring the possibility of entering into an agreement with the federal government under which federal regulators would assume responsibility for administering standards set out in Ontario legislation

  3. Reassess the need for and desirability of continuing to provide for provincial incorporation of trust and loan companies

As noted in the 1996 Budget Statement, the government has passed a regulation amending section 227 (1) of the Loan and Trust Corporations Act to extend the application of the Act to July 1, 1997. By this new "sunset" date, the government intends to introduce and pass legislation to implement the policy directions outlined in this paper and to determine what other steps should be taken to reorient the province's regulatory role.

The Ministry of Finance invites comments on the policy proposals and options outlined in this paper. Interested parties are asked to provide their submissions to the Ministry of Finance by November 29, 1996. After a review of these submissions, Ministry staff will hold discussions on key policy and technical issues, in preparation for the introduction of legislative amendments.

Submissions should be forwarded to:

Terry Campbell
Acting Director
Financial Services Policy Branch
Ministry of Finance
250 Yonge Street, 30th Floor
Toronto, Ontario
M5B 2N7
(416) 327-0936

Cette publication, sous le titre "Promouvoir le Changement: Éliminer le Chevauchement et le Dédoublement dans la Réglementation des Activités de Prêt et de Fiducie en Ontario", est disponible également en français. Vous pouvez en obtenir un exemplaire en composant Terry Campbell le (416)327-0936. Des exemplaires de cette publication sont aussi disponibles à l'adresse au-dessus.

THE TRUST INDUSTRY IN ONTARIO

Trust companies offer three basic types of services to the public:

  • deposit-taking services (savings and chequing accounts, term deposits and other kinds of investment vehicles)

  • lending services (mortgages and other types of personal and business loans)

  • fiduciary (or trustee) services (the management of estates, trusts and agency accounts on behalf of individual or corporate clients)

Loan companies also offer deposit-taking and lending services, but cannot offer fiduciary services.

Currently, 52 trust and loan companies (which will be referred to as "trust companies" or "companies" in this paper) are registered and operating in Ontario. Most of these companies are incorporated outside Ontario. Specifically,

  • 34 companies registered in Ontario are federal

  • 8 companies are extra-provincial, that is, incorporated in other provinces

  • 10 companies are incorporated in Ontario

In total, the 52 trust companies operating in Ontario raise over $64 billion in deposits in the province, or about 65% of their total deposits. These companies also hold fiduciary assets totalling more than $675 billion, of which about 70% are held in Ontario.

The trust sector currently employs about 17,000 residents of Ontario, both in the Greater Toronto Area, where many national companies have head offices or executive offices, and in smaller communities. Average wages are higher in the trust industry than in many other sectors, reflecting a higher proportion of skilled jobs. Trust companies also purchase a range of legal, accounting, telecommunications and other services from outside the sector.

Recent Market Trends

Since 1991, 15 companies have left the provincial market through mergers and acquisitions, failures and voluntary withdrawals; assets have dropped from $131 billion to just over $100 billion; and market share of the remaining companies in key markets – deposits and residential and non-residential mortgages – has fallen from about one-quarter to about 15%.

An important factor in this decline has been increased competition in major consumer and business markets from the banks and other federally incorporated financial institutions, which under the regulatory reforms of 1992 gained the power to enter new types of business activities and to own trust companies. To date, Canadian banks have purchased 16 trust companies formerly registered in Ontario, some of which have been absorbed into new trust companies formed by the banks which have focused on providing fiduciary services, in some cases for niche markets.

REGULATORY FRAMEWORK

Jurisdictional Powers and Responsibilities

The regulation of trust and fiduciary services has historically been viewed as the responsibility of the provinces as part of their constitutional jurisdiction over property and civil rights, and the power to register companies offering trust services has also been viewed as exclusively provincial. Both the provincial and federal governments have the power to incorporate trust companies, but the federal government has exclusive authority to incorporate banks and regulate banking.

In the context of these overlapping responsibilities, a cumbersome dual system of regulation has been developed over the years by the federal government and the provinces which have been most active in the regulation of the trust industry (Ontario, Quebec, Alberta and British Columbia).

Ontario's Current Regulatory Framework

Ontario's current regulatory system is based on the Loan and Trust Corporations Act which was passed on June 29, 1987 and came into force in early 1988. This statute was a response to problems that emerged in the industry in the early 1980's, when the Ontario government determined that it was necessary to take control of three provincially incorporated trust companies.

The key elements of the 1987 legislation covered aspects of business operations and organization that were seen as critical to corporate solvency: capital levels, business powers, investments, subsidiaries, liquidity, restricted-party transactions and corporate governance. Through the "equals approach", new requirements and restrictions established by the province in these areas were applied to all companies operating in Ontario, whether incorporated in Ontario, federally or in other provinces. Companies which did not comply with standards set out in the Ontario statute with respect to their operations both inside and outside Ontario were not permitted to register and do business in the province, even when these standards conflicted with those established by their incorporating jurisdiction. This approach has been unique; no other province has imposed additional regulatory requirements on companies operating in those jurisdictions.

The Act also set out some standards regarding the management of estates, trusts and agencies by trust companies, although the management of trusts is primarily governed by general standards contained in other provincial statutes, including the Trustee Act, the Pension Benefits Act and the Estates Administration Act.

Finally, the Act and the regulations established some standards on fair business practices and provided powers to create additional rules on marketplace conduct.

In short, the primary focus of the new Ontario statute was the regulation of corporate solvency, not only of trust companies incorporated in Ontario, but also those incorporated and regulated in other jurisdictions.

Federal Reforms

Since the Ontario statute came into effect, the federal government has implemented extensive reforms of its financial services legislation, including its Trust and Loan Companies Act.

The federal reforms of 1992 established stricter rules on self-dealing and restricted- party transactions and new minimum capital requirements consistent with international standards; increased the responsibility of boards of directors; provided the Superintendent of Financial Institutions with stronger supervisory powers; and maintained certain "pillar" restrictions regarding what activities financial institutions could undertake (e.g., banks could not perform in-house trust activities).

At the same time, however, the 1992 changes gave federal financial institutions broader business powers, including:

  • the powers of a natural person (all powers other than those specifically prohibited);

  • broader lending and investment powers (the right to invest in accordance with the "prudent person" standard, rather than to make only those investments listed in the statute);

  • the right to own other financial institutions;

  • the ability to own a range of subsidiaries (including real estate and insurance brokerages, merchant banks, and information technology firms); and

  • the power to enter into networking arrangements with other companies in which the products and services of these companies are marketed to the customers of the financial institution.

In addition to these reforms, the federal government and its agencies have taken further steps to strengthen the regulatory system. As part of a "safety and soundness package" passed in May 1996 (An Act to Amend, Enact and Repeal Certain Laws Relating to Financial Institutions), the Office of the Superintendent of Financial Institutions was provided with stronger and more flexible regulatory powers, including the power to take control of a troubled financial institution before it becomes insolvent.

Since the late 1980's, the Canada Deposit Insurance Corporation (CDIC) has also become more active in setting standards for and monitoring operations of the institutions it insures. CDIC has issued standards on sound business and financial practices, including the management of capital, liquidity, interest rate risk, credit risk, foreign exchange risk, internal controls and real estate appraisals. CDIC can set terms and conditions on deposit insurance coverage provided to an institution, or refuse coverage altogether. Under the provisions of An Act to Amend, Enact and Repeal Certain Laws Relating to Financial Institutions, CDIC is empowered to charge risk-rated premiums for deposit insurance coverage, intended to discourage high-risk activities by deposit institutions.

The 1992 federal reforms also required that the legislation be reviewed by March 1997, and in June 1996, the Department of Finance released a discussion paper (entitled "1997 Review of Financial Sector Legislation: Proposals for Changes") proposing a number of minor legislative amendments, as well as the establishment of an advisory group to make recommendations on a wide range of issues affecting the financial sector. The federal paper also noted that:

"The government supports reducing overlap and duplication in Canadian financial sector regulation. The government reaffirms its commitment to work with the provinces to make further progress in a number of areas."

Reforms in Other Jurisdictions

Most other jurisdictions which regulate the trust industry have also made major reforms since Ontario's Loan and Trust Corporations Act came into effect.

In 1987, the Quebec government introduced new legislation, which included a requirement for a statutory review every five years. Regulatory requirements have also been reformed in British Columbia, Manitoba, New Brunswick and Nova Scotia. In May 1996, the Alberta government passed major changes to its regulatory approach, most notably that the province would no longer regulate the solvency of companies incorporated outside Alberta.

NEED FOR REFORM OF ONTARIO LEGISLATION

Although there have been substantial changes to regulatory systems at the federal level and in other provinces in recent years, Ontario's Loan and Trust Corporations Act has remained unchanged since it came into effect in 1988.

Because the "equals approach" in Ontario's legislation requires all trust companies operating in the province to comply with Ontario's rules whether or not they are regulated elsewhere in Canada, Ontario's rules have in effect established the operating environment for the industry over the last eight years, and prevented reforms introduced by other jurisdictions from being fully realized.

This has meant that, as well as incurring the additional compliance costs created by dual legislation, companies incorporated federally and in other provinces have been unable to make full use of the business powers granted to them by these jurisdictions to meet the needs of their customers. For example, Ontario legislation imposes very strict limits on a trust company's ability to undertake commercial lending, including a prohibition on issuing letters of credit, imposes restrictive caps on the amount of a company's consumer lending, and permits a much narrower range of subsidiaries than is allowed by federal legislation. More generally, these restrictions have tended to inhibit innovation by trust companies operating in Ontario, which has in turn limited choices for their customers.

The Ontario statute also severely constrains specialization to serve particular market niches. Companies wishing to operate in Ontario must obtain deposit insurance coverage and maintain the capacity to take deposits, even where they would prefer to focus exclusively on fiduciary services.

Many industry representatives and observers have concluded that the regulatory requirements imposed by Ontario have limited the trust industry's ability to compete effectively in a rapidly changing financial services marketplace, without enhancing protection for consumers. Indeed, Ontario regulatory standards are generally seen as less important to depositors than CDIC coverage and regulatory oversight, nor do they address emerging consumer concerns such as the confidentiality of personal financial information and the use of new distribution arrangements.

COMMITMENT TO CHANGE: THE 1996 BUDGET STATEMENT

On May 7, 1996, in the 1996 Ontario Budget Statement, the Minister of Finance announced that:

"We will extend the sunset provision of the Loan and Trust Corporations Act and take action to eliminate overlap in the regulation of the loan and trust industry. We will remove the outdated requirement that Ontario duplicate regulatory activities already undertaken by other jurisdictions in Canada. By harmonizing with federal regulations, we will get rid of an unnecessary layer of regulation of this important industry. We will set out our direction in a policy paper to be issued for public comment in the near future."

This paper sets out the government's proposals to eliminate overlap and duplication in the regulation of trust companies operating in Ontario.

KEY POLICY OBJECTIVES

Over the next year, Ontario intends to take steps to achieve a regulatory environment in which:

  • the interests of consumers continue to be effectively protected

    • a central factor in Ontario's consideration of how to reshape its regulatory role in the trust industry will be to ensure that Ontario depositors and other consumers of trust company services remain protected so that the public can have confidence in dealing with companies operating in the province

  • companies are able to compete in the provincial marketplace without the unnecessary constraints and costs imposed by regulatory duplication

    • it is clear that regulatory duplication among different levels of government creates additional costs to be borne by the industry, their clients, and ultimately by provincial taxpayers, which are not justified by the value created by a second level of regulation;

  • regulation is undertaken by the level of government best positioned to deliver it, in terms of expertise, experience and resources;

    • focusing regulatory responsibilities in a single body could allow for more responsive and more effective regulation

and

  • to the greatest extent possible, companies and their clients can deal only with one regulatory agency and accountability for ensuring compliance with regulatory standards is clear

    • regulatory duplication leads to confusion for both companies and their clients as to which level of government is responsible for setting standards, ensuring compliance and taking regulatory action

PROPOSED POLICY DIRECTIONS

In summary, the Ontario government plans to:

  1. Eliminate the "equals approach" from Ontario's legislation, so that companies no longer have to comply with overlapping and conflicting sets of rules with respect to their business operations and organizational structure.

  2. Consider alternative ways of ensuring consumers are protected to determine whether there is a continuing need for a separate regulatory program within the Ontario government, including:

    1. assessing the potential for moving towards a greater degree of self-regulation of trust and loan companies operating in Ontario

    2. exploring the possibility of entering into an agreement with the federal government under which federal regulators would assume responsibility for administering standards set out in Ontario legislation

  3. Reassess the need for and desirability of continuing to provide for provincial incorporation of trust and loan companies

DISCUSSION AND QUESTIONS TO CONSIDER

A.   Elimination of the "Equals Approach"

As noted earlier, through the "equals approach", Ontario applies its solvency requirements to the operations of companies incorporated in Ontario and in other jurisdictions, and to the operations of these companies both inside and outside Ontario.

These requirements are established by s. 39 of the Loan and Trust Corporations Act which requires extra-provincial companies to comply with certain provisions of the statute in order be registered in Ontario. In addition, the requirements of Parts IX and X expressly apply to all companies registered in Ontario. As a result, companies incorporated outside Ontario must comply with Ontario's Loan and Trust Corporations Act with respect to:

  • limits on business powers

  • standards and limits on investments, including permitted investments in subsidiaries

  • limits on borrowing

  • standards on corporate governance (e.g. composition and mandate of the board of directors and its committees)

  • requirements on reporting and public disclosure

  • restrictions on restricted-party transactions

  • requirements to obtain the Superintendent's approval for certain transactions and activities

Discussion:

Eliminating the "equals approach" will allow companies incorporated outside Ontario to exercise the business powers provided to them under the legislation of these jurisdictions, and therefore to expand their services or restructure their operations to serve their customers more effectively and to attract new customers. It will also lower the costs to these companies of complying with regulatory standards, which should also benefit their customers. When this policy change is implemented, companies incorporated federally will be able to deal nearly exclusively with federal regulatory agencies and those incorporated in other provinces will be able to deal primarily with one or two regulatory agencies, since they will no longer be required to submit reports to and to be examined by Ontario regulatory officials. This will in turn clarify accountability for ensuring compliance with regulatory standards, which will assist regulators, companies and their clients. Finally, since reforms undertaken by the federal government and other major jurisdictions have modernized standards relating to solvency, consumer protection will not be affected.

Questions requiring further consideration
  • What impact will removing "equals approach" have on Ontario-incorporated companies, and should any steps be taken in the near term to address this impact?

B.   Consideration of Alternative Ways of Ensuring Consumers are Protected

The most important policy objective, in assessing how to refocus the provincial regulatory framework, is to ensure that the interests of consumers continue to be effectively protected. This suggests that registration requirements and a mechanism to regulate fiduciary activities by trust companies must be maintained. A review of constitutional opinion and case law on the regulation of trust companies indicates that only provincial governments have the authority to require trust companies to register to do business in a province and to regulate fiduciary services. This means that only provincial legislation can establish regulatory controls on the type of companies which may take deposits from and offer fiduciary services to the public.

If there were no requirement to register with the province before carrying on business, any company (whether a financial institution or a non-financial company) could take deposits and offer fiduciary services to the public, and there would be no mechanism for a regulatory agency to ensure that the company followed appropriate standards or to take action if the company engaged in unsound or unethical practices.

Similarly, the provincial Loan and Trust Corporations Act is the only statute which provides for controls on the type of companies which can offer fiduciary services to the public, and for the establishment of standards on the responsibilities of trust companies when managing trust funds for individual or business consumers.

While only the province can establish registration requirements and standards on fiduciary activities, the administration and enforcement of such standards could, however, be undertaken by a self-regulatory body or by the federal government.

Questions requiring further consideration
  • Is it necessary to maintain statutory registration requirements for trust companies to operate in Ontario?

  • If registration requirements should be maintained, are there ways in which those requirements or their administration could be modified to enhance efficiency and effectiveness? For example, should companies which offer only fiduciary services be permitted, in the future, to register in Ontario and, if so, what would be appropriate registration requirements? Should companies incorporated outside Canada be permitted to register in Ontario and, if so, what would be appropriate registration requirements?

  • Is it necessary to maintain controls on the provision of fiduciary services in legislation governing trust companies, given the existence of legislation of general application regarding trust matters and the body of common law in this area? If so, are existing regulatory standards for fiduciary services adequate and effective?

If the conclusion is reached that legislative standards should be maintained to control registration and the provision of fiduciary services by trust companies in Ontario, the Ontario government would be interested in pursuing alternative ways of ensuring consumers are protected:

  1. The option of moving towards a greater degree of self-regulation

Analysis:

The current regulatory framework includes some elements of self-regulation (boards of directors, for example, are responsible for establishing corporate policies on such key issues as the investment portfolio, and for assessing corporate performance on an ongoing basis) which could be developed further. In addition, government regulation of some aspects of the business activities of trust companies, notably the provision of fiduciary services, is not extensive at present and could potentially be replaced by self-regulation.

However, self-regulation of all aspects of company activities may not be desirable. In particular, it is generally expected those activities which affect corporate solvency are monitored not only by company managers and directors but also by external auditors and ultimately by regulators. Without such oversight, deposit insurance from the Canada Deposit Insurance Corporation would not be available to companies, and such coverage is viewed by most depositors as a prerequisite for entrusting their savings to a financial institution. There might, then, be significant competitive disadvantages associated with a fully self-regulatory system.

Questions requiring further consideration
  • In what ways could self-regulation be expanded for trust companies operating in Ontario?

  • What are the likely benefits and costs for companies of a greater degree of self-regulation?

  • What are the expected benefits and costs for consumers of a greater degree of self-regulation?

  1. The option of delegating provincial regulatory powers to the federal government

As discussed earlier, the federal government does not have the constitutional authority to require companies to register in order to operate in Ontario or any other province, nor to set standards with respect to fiduciary services offered by trust companies. However, Ontario could explore ways of delegating its power to enforce provincial registration requirements and provincial standards on fiduciary services to the federal government.

In addition, Ontario could pursue an agreement to delegate to the federal government the enforcement of its solvency standards that would continue to apply to Ontario-incorporated companies.

Analysis:

There are at least four possible types of agreements which Ontario could explore to delegate its regulatory powers to the federal government:

  1. an administrative agreement, under which federal regulators undertake specific regulatory functions (such as examinations) on behalf of Ontario on a fee-for-service basis

  2. an agreement under which federal regulators administer and enforce regulatory standards set out in Ontario legislation, in accordance with the terms of a memorandum of understanding

  3. the establishment of a provision in Ontario's Loan and Trust Corporations Act which states that the official responsible for administering and enforcing the Act is the federal Superintendent of Financial Institutions

  4. the establishment of a provision in Ontario's Loan and Trust Corporations Act which states that the official responsible for administering and enforcing the Act is the federal Superintendent of Financial Institutions

Clearly, the extent of responsibilities and liabilities retained by the province would depend on which type of agreement was put into place. Similarly, the type of agreement would determine the level of resources that the province would need to allocate to regulation of the industry.

It should be noted that if the federal government were to assume responsibility for enforcing provincial regulatory standards, these requirements may have to be changed to be more consistent with or to complement existing federal standards. In particular, if federal officials agreed to regulate the solvency of the Ontario-incorporated companies, it is likely that they would expect Ontario's standards on solvency to be harmonized with federal standards.

Questions requiring further consideration
  • What impact would an agreement under which the federal government undertook to administer provincial regulatory standards have on trust and loan companies?

  • What impact, if any, would such an agreement have on consumers?

Another possible way in which the provincial regulatory role could be reduced is for the province to cease to provide for companies to be incorporated in Ontario.

C.   Reassessing the Need for Provincial Incorporation of Trust Companies

Analysis:

As noted above, there are currently 10 provincially incorporated companies. The regulation of these companies is now undertaken by the Ministry of Finance based on standards set out in the Loan and Trust Corporations Act which, under the "equals approach", the Ministry also applied to extra-provincial companies operating in the province. As Ontario moves to eliminate overlap and duplication in trust regulation and reduces its regulatory role accordingly, it is possible that the province would no longer have the "critical mass" of regulatory expertise necessary to properly regulate the Ontario-incorporated companies. Rather than maintain a separate regulatory infrastructure performing functions parallel to the existing federal regulatory system, Ontario is interested in reassessing the need for and desirability of continuing to provide for trust companies to be incorporated and regulated at the provincial level.

If there were no longer trust companies incorporated in Ontario, there would be no need for the province to maintain statutory provisions relating either to incorporation or to solvency, since other jurisdictions (primarily the federal government) would be responsible for setting incorporation procedures and enforcing standards relating to solvency for all other companies. It should also be recognized that substantial efficiencies could be achieved if regulatory activities and expertise were focused at a single level of government.

It may be possible for the province to establish transition mechanisms by which existing companies could transfer their incorporation to another jurisdiction with a minimum of disruption to companies and their customers. For example, Ontario could amend the existing Loan and Trust Corporations Act to enable Ontario-incorporated companies to continue their incorporation in another jurisdiction in Canada, and work with officials in other jurisdictions to facilitate the transfer of incorporation.

Questions requiring further consideration
  • What would be the expected costs to Ontario-incorporated companies of continuing their incorporation in another jurisdiction and how could these be minimized?

  • How long a transition period would be needed for companies to transfer their incorporation and are there steps that Ontario could take to facilitate their transfer?

NEXT STEPS

As announced in the 1996 Budget Statement, the government has passed a regulation amending section 227 (1) of the Loan and Trust Corporations Act to extend the application of the Act to July 1, 1997. By this new "sunset" date, the government intends to introduce and pass legislation to implement the policy directions outlined in this paper and to determine what other steps should be taken to reorient the province's regulatory role.

The Ministry of Finance invites comments on the policy proposals and options outlined in this paper. Interested parties are asked to provide their submissions to the Ministry of Finance by November 29, 1996. After a review of these submissions, Ministry staff will hold focused discussions on policy and technical issues, in preparation for the introduction of legislative amendments.

Submissions should be forwarded to:

Terry Campbell
Acting Director
Financial Services Policy Branch
Ministry of Finance
250 Yonge Street, 30th Floor
Toronto, Ontario
M5B 2N7
(416) 327-0936

Cette publication, sous le titre "Promouvoir le Changement: Éliminer le Chevauchement et le Dédoublement dans la Réglementation des Activités de Prêt et de Fiducie en Ontario", est disponible également en français. Vous pouvez en obtenir un exemplaire en composant Terry Campbell le (416)327-0936. Des exemplaires de cette publication sont aussi disponibles à l'adresse au-dessus.

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