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Digital Disruption in Wealth Management

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Digital disruption in

Wealth Management
Why established firms should
pay attention to emerging
digital business models for
retail investors
Executive summary

Over the past ten years, numerous startup firms with Leading WM franchises have been monitoring these
digital business models have emerged within the Wealth digital startups for a while, but thus far only a few have
Management (WM) industry. According to our analysis responded with enhancements to their own digital
of over 50 WM startups, these firms are Business-to- presence. However, our research shows the tide is starting
Consumer (B2C) focused, and primarily serve retail to turn and a growing number of incumbents are looking
investors in three ways: to selectively invest in building digital capabilities that will
help broaden their appeal with younger clients and other
1. Connect. Helping investors connect to their peers, digitally savvy retail investors.
multiple accounts, and multiple sources of advice.
The disruptive power of digital technologies business
2. Advise. Providing investors with advice tailored to their models is creating opportunities for new firms to make a
unique situations and delivered through a rich, digital big splash in the wealth management industry. However,
experience. other kinds of financial services firms — such as asset
management and insurance companies — may be able
3. Invest. Providing access to esoteric investment
to leverage similar capabilities to provide client advice and
opportunities and investment strategies similar to those
add greater value through their own distribution channels.
used by professional investors and institutions.
Established WM firms that do not learn from digital
Although it’s unlikely these new firms will draw large
startups and adjust their business models accordingly
amounts of market share away from leading wealth
could find themselves at a significant disadvantage in the
management franchises over the next five years, they will
marketplace. On the other hand, incumbents that learn
likely continue to grow because they target investor needs
to use digital technologies to address unmet needs and
that established firms are not currently satisfying. Also,
deliver a superior client experience may be able to leapfrog
they offer a convenient online client experience that retail
the competition and capitalize on emerging market
investors have increasingly come to expect.
opportunities.

Established Wealth Management firms that


do not learn from digital startups and adjust
their business models accordingly could find
themselves at a significant disadvantage in
the marketplace.

1
Introduction

Imagine two executives having lunch at a wealth


management (WM) conference and discussing the recent
emergence of small, digitally enabled WM firms that
primarily focus on retail investors in the Business-to-
Consumer (B2C) market — firms such as Betterment and
Personal Capital. The first executive doesn’t care about
these startups or view them as a disintermediation threat,
arguing that investors will always want direct, person-
to-person relationships with their financial advisors. The
second executive strongly disagrees, arguing that all
incumbent firms should understand why these new firms
exist, what clients like about them, and what capabilities
should be developed in response to the threat.

This hypothetical scenario illustrates a real ongoing debate


taking place in the WM industry about the relevance of
digitally-enabled startups and their potential for disruption.
Established firms are trying to decide whether it is worth
their time, money, and effort to better understand these
emerging businesses.

According to our research for this report, the answer


is clear. Wealth management is an industry ripe for
disruption, and WM startups are a leading indicator of
what is anticipated to come. Studying the new digital firms
can reveal evolving customer needs that are not currently
being met by established firms, enabling incumbents
to adjust their business models and take advantage of
emerging trends.

Digital Disruption in Wealth Management 2


An overview of wealth
management startups

Our study examined over 50 wealth management startups Connect. Consumers have a need to connect multiple
that are B2C-focused and digitally enabled, most of accounts — often across multiple providers — in order
which were founded within the past ten years (Figure 1). to create a holistic picture of their wealth and more easily
According to our analysis, these fast-growing firms serve manage their finances across multiple asset classes and
retail investors in three ways: they help investors connect; firms. Also, investors want to connect with each other
advise them on financial issues; and help them invest to learn from their peers, and to connect with specialists
(Figure 2). and advisors that align with their needs. New firms are
providing integration across traditional boundaries to help
investors escape siloed investing.

Examples: Mint, SocialPicks, MyFinancialAdvice

Figure 1: Deployment Timeline

• Jemstep
• Stock Twits
• People & Picks
• A
 ffluence
• Betterment • Portfolio Monkey
• MyGDP • NerdWallet
• Market Riders • Motif
• Currensee • S eed Ups • LikeFolio
• Family Bhive • Crowdcube • Daric
• eToro • Peers • Future Advisor • Realty Mogul
• LearnVest • Wealth Front
• My Financial Advice • Lending Club

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

• Flat Fee Portfolio • Covestor • Money Strands • NestEgg Wealth • Funders Club
• Collective2 • Seedrs • Crowdfunder • CircleUp
• Family Office Exchange • Personal Capital • Plan & Act • Collaperty
• Institute for Private Investors • Mint • Hello Wallet
• CAPS – Motley Fool • Fundrise
• Yodlee – Money Center • Hedgeable • My Prosperity
• Tiger 21 • Prosper • Prodigy Network
• Garrett Planning Network • Social Picks • Financial Guard
• Financial Planning Association
• Folio Investing

3
Digital disruption framework

Figure 2: WM Digital Disruption Framework

Connect Advise Invest

Allow investors to connect their Leverage digital interfaces and Provide investors access to
accounts together, and connect with analytics to deliver tailored advice and non-traditional, institutional-like
their peers and the right advisors enhanced experiences investment strategies and opportunities

Account Aggregation: Financial Planning: Non-Traditional Investment


• Money Strands (with Digital Store Front) Strategies:
• My Prosperity • Wealth Front • Collective2
• Mint • Personal Capital • Covestor
• Yodlee – Money Center • Plan & Act • Currensee
• Hello Wallet • Motif
• LearnVest • eToro

Social:
• Peers • Tiger 21
Portfolio Allocation: Alternative Products:
• Social Picks • Institute for Private
(Algorithms-based) • Prosper
• Affluence Investors
• My GDP • Seed Ups
• Family Bhive • Stock Twits
• NestEgg Wealth • Seedrs
• CAPS – Motley Fool • Family Office
• FlatFee Portfolios • Lending Club
• People & Picks Exchange
• Folio Investing • Crowdfunders
• Future Advisor • Prodigy Network
• Market Riders • Fundrise
Client/Advisor Matching: • Hedgeable • Funders Club
• Garrett Planning Network • Financial Guard • Crowdcube
• My Financial Advice • LikeFolio • Collaperty
• Finanical Planning Association • Portfolio Monkey • CircleUp
• NerdWallet • Betterment • Realty Mogul
• Jemstep • Daric

Digital Disruption in Wealth Management 4


Digital disruption
framework continues...

Advise. Retail investors often seek advice from reputable Invest. Some retail investors are ready to explore
sources and want that advice to be tailored to their unique non-traditional investments or are looking to emulate
needs and circumstances. In the past, access to tailored professional and institutional investment strategies. In
solutions was largely limited to wealthy investors due to response, digitally enabled firms are starting to provide
the high cost of customization. Now, digital platforms access to alternative finance products that were historically
are democratizing the delivery of financial advice, with the sole purview of commercial or high net-worth
algorithmic tools giving the masses access to customized investors.
investment planning and portfolio allocation.
Examples: Covestor, Prosper, Seedups
Examples: Personal Capital, Betterment
Although firms are typically categorized based on their
primary functions, many offer services that cut across
categories (Figure 3).

5
Digital wealth management
firms capabilities
Figure 3: Digital WM Firms Capabilities

Connect Advise Invest


Account Client/Advisor Portfolio Non-Traditional Alternative
Social Financial Planning
Aggregation Matching Allocation Investment Strategies Products
Affluence
Betterment
CAPS - Motley Fool
CircleUp
Collaperty
Collective2
Covestor
Crowdcube
Crowdfunder
Currensee
Daric
eToro
Family Bhive
Family Office Exchange
Financial Guard
Financial Planning Assoc.
Flat Fee Portfolio
Folio Investing
Funders Club
Fundrise
FutureAdvisor
Garrett Planning Network
Hedgeable
Hello Wallet
Institution for Private Investors
Jemstep
LearnVest
LendingClub
LikeFolio
Market Riders
Mint
Money Strands
Motif Investing
My Financial Advice
My Prosperity
My GDP
NerdWallet
NestEgg Wealth
Peers: The Wealth Peer Group
People & Picks
Personal Capital
Plan & Act
Portfolio Monkey
Prodigy Network
Prosper
Realty Mogul
Seedrs
Seedups
Social Picks
Stock Twits
Tiger 21
Wealth Front
Yodlee Money Center

Source: Deloitte Analysis, 2013 Key: Primary Capability Secondary Capability

Digital Disruption in Wealth Management 6


Connect

Account Aggregation on financial planning. Myprosperity can aggregate bank,


Retail investors are increasingly frustrated with having to credit card, investment accounts, and assets (e.g. home,
reconcile or aggregate transactional information across car) into a single dashboard, providing the user with a
numerous bank, investment, and retirement accounts. real-time view across multiple accounts and financial
They want an accurate, real-time, aggregated view of their institutions. The site has a budgeting tool to help users
financial assets, liabilities, and net worth across multiple monitor spending and manage savings goals. A “financial
accounts and providers. Also, such a view would help fitness score” is generated to measure against personal
financial advisors provide more effective and timely financial goals and preferences. It also facilitates users’ need to
planning and investment advice — and create opportunities share information with the financial and legal professionals
for them to cross-sell a wide range of financial products and through a limited access portal.
services.
Large incumbent firms could offer something similar to Mint
One of the first movers in this market was Mint.com. Mint and Myprosperity by building account aggregation into their
is a free online personal finance service that allows users current digital front-ends (websites/mobile apps), as it would
to see all their balances and transactions in one place. likely require minimal integration with current systems. Many
Launched in 2007, Mint now has over 1 million users, B2B financial services technology firms provide products to
making it one of the largest and fastest growing account help incorporate aggregation into a company’s infrastructure.
aggregation services. Once a user provides their logins, Mint Once a comprehensive picture of a client’s wealth has been
automatically pulls in daily information about bank accounts, captured, incumbent firms may be better positioned to
credit cards, loans, property, and investments from nearly systemically provide effective financial advice and
all banking and financial institutions in the U.S. — giving cross-sell new products and services — enabling more
users an up-to-date view of their money with no data entry, effective share of wallet strategies. Another potential use of
import or synching required. Mint automatically categorizes account aggregation is to offer services to families and other
transactions, calculates budgets by category, and shows cash groups of individuals, where different members would have
flow for each month. To keep users engaged, the service different levels of access to the financial picture.
also sends email and SMS alerts about upcoming bills, low
balances, and unusual spending. In addition, Mint.com offers Social networks
personalized recommendations on alternative products a Since the financial crisis, retail investors have become more
user may be interested in. The recommendation engine is a skeptical of the advice they receive, while at the same time
source of revenue as affiliates pay to have their products put realizing they need this advice more than ever (See Figure
in front of desired clients. 4). One way to mitigate the perceived risk of advice is to
provide customers with access to a variety of different
Myprosperity is conceptually similar to Mint, with a focus sources. Investor want to know what their peers think and

Figure 4: Why the mass affluent left their advisors

Didn’t trust my advisor any more, felt they were putting their 27%
own interests ahead of mine

Felt doing it on my own would yield better outcomes 23%

Realized I enjoy managing investments on my own 20%

The quality of advice received was poor/below my 15%


expectations
My financial advisor did not offer me the right investment 10%
options

I thought my financial advisor was not as competent 6%

7
how they invest, not just learn from investment specialists. advisors and matching engines that use targeted questions
Furthermore, they value interactions with their peers beyond to connect clients with particular advisors based on a broad
addressing their own immediate investment needs. Forums range of factors, including everything from financial needs
that began as chat groups and online discussions have and preferences to backgrounds and hobbies.
quickly evolved into full-blown social platforms that allow
for an open exchange of ideas and the ability to form affinity Garrett Planning Network is an example of one such firm.
groups. The company, which has been around since 2000, allows
individuals to search for an independent advisor in their
People & Picks, founded by Zack's Investment Research, is area and then read about the advisor’s experience and
an example of a company that has created a social platform background. Any customer can contact an advisor for
and online community for users to interact with one another. answers to simple questions or for full financial planning
The platform allows users to rate any stock as a buy/sell services. The site provides a list of critical questions that
and tracks performance against the market. Users can share customers can ask an advisor to help assess if there is a
ideas with fellow users, and keep track of past selections. good fit.
The platform can also be used to blog and share ideas and
opinions about the market, and it aggregates the data so “My Financial Advice” is a business that further automates
people can review user sentiment for a particular stock.a the selection process by providing a list of initial questions
that an individual might ask, and then providing a list of
Family Office Exchange is a company in the social category local advisors that can resolve those questions. Prospective
that focuses on providing wealthy families (or their agents) customers can learn about an advisor’s cost and ratings
with a financial education about how to effectively pass from previous customers, and can read the advisor’s profile
wealth onto future generations. Founded in 1989, to see their certifications and past experience. The platform
the company has become a platform for sharing leading reinforces the idea of getting independent financial advice
practices in family wealth management. It provides a global from the convenience of home via a telephone or email.
online community and listserv that gives members a place to
network and have discussions. It also uses the relationship Established WM firms might be able to differentiate
with wealthy families to connect them with advisors when themselves by deploying more robust client/advisor
needed. matching. Currently, matching is mostly based on
proximity and short-term needs (e.g., retirement planning
For major financial institutions, social platforms can be an or tax optimization). Enhanced matching could identify
effective acquisition tool and increase client retention. These commonalities between clients and financial advisors
platforms can provide access to a wide range of qualitative (e.g., personality profiles, backgrounds, interests) that might
and quantitative investor data that can be used to better help foster a long-term relationship.
design and target products and services. In particular, private
banking arms can transform a client base into a valuable The matching process is also a prime opportunity to capture
internal network of high net worth clients who have been additional details about current and potential customers,
vetted through Know Your Customer/Anti-Money Laundering and could give traditional firms the option of leveraging
processes. analytics and big data to improve client acquisition strategies
and on-boarding processes, and to better understand and
Client/advisor matching respond to client needs. This analysis could also help financial
Although some clients want to make their own investment advisors better understand their market.
decisions, many would still like to find an advisor that is
the best possible match in terms of competence, personal
affinity, and/or cost. WM firms are often reluctant to help
a client seek out an advisor who is a better long-term match
for fear of upsetting the sales force. Digital startup firms have
stepped in to fill this gap by building databases of financial

Digital Disruption in Wealth Management 8


Advise

Investors have always been interested in advice about (for investors with over $100,000 in assets). Account
their assets and investments that could help them manage aggregation enables users to monitor their finances
their finances more wisely. But with the move to online as part of a single, integrated dashboard that shows
platforms, digital interactions have naturally become as asset allocations, potential portfolio risks, and how
an important extension of the overall client experience. different product fees might impact their goals. Personal
Clients today expect their Wealth Managers to provide the Capital aims to merge online money management with
same level of experience and ease-of-use as other online personalized case-by-case guidance.
businesses, such as Amazon and Google. New analytics It features an integrated dashboard and also provides
technologies enable financial planning and portfolio personal advisors to help investors navigate their financial
allocation tools to automatically deliver tailored advice data and challenges.
directly to retail customers. Armed with more data from
client profiles, Learnvest goes even further by acting as an online coach.
firms can better understand the psychology of the investor. The company provides an online tool that helps users track
And while a financial advisor might still be the preferred their spending, visualize their budgets, and attain their
solution, these new technology-driven insights provide financial goals. It also facilitates discussions by allowing
investors with a useful amount of automated advice users and their financial planners to both view the user’s
tailored to their unique goals. dashboard at the same time. In addition, Learnvest
offers ten-day boot camps on finance-related subjects
Financial Planning such as becoming a parent, shopping for clothing, and
Online wealth management startups have entered this navigating one’s career. Learnvest also offers financial
market and successfully attracted financial planning education by connecting users with Certified Financial
customers by setting up digital storefronts based on Planners (CFPs) who can answer questions and perform
well-designed platforms that have a low learning curve. complimentary evaluations. For young adults interested in
These companies can form a complete picture of a client’s working one-on-one with their assigned financial planner,
financial situation by taking into consideration personal a variety of service bundles are available to help them
financial goals, risk tolerance, diversification, and/or accomplish their life goals. CFPs use information about a
investment strategies. person’s spending habits, budget, and financial goals to
offer specific advice and help individuals understand how
Examples of these digital storefronts include Personal money, expenses, and debt will continue to affect their
Capital and Learnvest. Personal Capital offers an lives as professionals.
investment platform with multiple options, from tracking
and analyzing investments to financial advisor services

9
Portfolio Allocation Today, many wealth managers have a robust online
Some digital startups offer customized investment presence, and a few firms have already begun to establish
portfolio allocations, based a person’s unique needs, using online platforms that aim to pair the advisor experience
pre-defined proprietary algorithms. They also provide with online details and transparency. However, the
user interfaces with interactive controls that dynamically remaining firms have an opportunity to leapfrog the
illustrate a variety competition by delivering advice both to the mass market
of scenarios, making goals-based investing much easier. and to affluent clients that fall below the wealth tier
where truly personalized advice is economical. The key
Startups that provide tailored portfolio allocation services is to provide a rich, digital experience that complements
include Betterment and Hedgeable. Betterment is a person-to-person advisory relationships and increases
relatively new company that offers automated investing advisor productivity. Real-time trading ideas and access
to the public. For a monthly fee, Betterment automatically to market and company research can be delivered by the
creates a customized asset allocation based on clients’ advisor to enhance the client relationship. Each of these
financial goals and then invests their money in a blend components can also be provided directly to customers
of two baskets: Bond Exchange Traded Funds (ETFs) and online in order to attract investors who are more
Stock Market ETFs. Betterment gives clients control over self-directed.
their level of investment risk by letting them adjust the
proportion of money invested in each basket.

Hedgeable is an online portfolio management company


that provides retail investors with an accessible method
of growing their portfolios in fluctuating markets by
recommending portfolio allocations. Based on a client’s
unique profile, the company sends out alerts when a
trade is recommended. After executing the trade, risk and
performance analytics are both calculated and delivered
to the user to provide guidance.

Digital Disruption in Wealth Management 10


Invest

In the current low yield investment environment, investors These investment products could help established wealth
are constantly looking for better risk/return opportunities. management firms capture a larger share of wallet. In
In response, startups have emerged that provide mass general, traditional WM firms already have all of the
market access to sophisticated, institutional-like trading underlying components needed to address this gap in
strategies. Whether by copying the trading strategies of the market. Their in-house trading desks already design
professional portfolio managers (PMs), or using automated high end strategies and share them with the firm’s most
trading strategies developed by hedge fund managers, profitable clients. Now, firms have an opportunity to
companies are finding ways to give retail investors access market a subset of these pre-defined trading strategies to
to services that historically have been the purview of another tier of digitally savvy customers.
institutional or high-net-worth investors.
Alternative Products
Startups in this segment fall into two main categories: In addition to gaining access to advanced trading
those offering non-traditional investment strategies, and strategies, some investors may want to diversify into
those offering access to esoteric asset classes. exotic asset classes. A number of startups have emerged
that offer investors access to investments that were
Non-Traditional Investment Strategies previously unavailable. These startups fall into two types:
Startups focused on non-traditional investment strategies (1) platforms that allow investors to become creditors and
offer individuals access to strategies that can help them offer direct loans to borrowers for a fixed rate of return,
invest like professionals. Covestor is a company that allows and (2) platforms where investors “crowdfund” a company
its members to view, study, and mirror the portfolios of and own a portion of the equity. Both types essentially
professional PMs — and will help match investors to PMs serve as a central point for bringing investors together with
that share their risk tolerance. Covestor offers access people that need funding.
to over 150 PMs, and once a client selects a PM, the
company will automatically recreate that PM’s account LendingClub falls into the first category of direct peer-to-
with the client’s assets and then mirror all subsequent peer lending, and is one of the largest companies in this
trades that the executed. Covestor earns money by niche market. Borrowers go on the company’s website
charging a fee based on the assets invested with PMs. and, once screened, create a listing with their information,
including the desired loan amount and purpose of the
Another company in this segment includes Collective2, loan. Loan investors view the listings and invest in those
which uses trading algorithms originally developed that meet their lending criteria. Once the process is
by hedge funds for ultra-high net worth individuals. complete, borrowers make fixed monthly payments and
Collective2 brings a previously exclusive product to the loan investors receive a portion of those payments directly
mass market, and is particularly appealing to investors into their LendingClub account. LendingClub makes
looking for new, complex investment strategies. money by charging a loan origination fee to the borrower
Additionally, the company will connect investors to a and a servicing fee to the loan investor.
limited number of brokerage firms that provide auto-
trading. Investors are charged a monthly fixed fee set by
the system developer, plus a flat monthly fee to
auto-trade stocks and options.

11
In October 2013, the SEC opened private investments Although WM startups have begun to establish a foothold
to the general public in response to the crowd funding in these new areas, incumbent WM firms can leverage
provision (Title III) of the JOBS Act. This will enable their strong brand names to defend their market leadership
startups to reach a much broader investment audience and capitalize on emerging opportunities. In particular,
than securities laws used to allow. Although there are they can retain client assets by offering new investment
still certain limitations based on income and net worth, opportunities similar to those described here.
this law is expected to have a significant impact on
firms involved in crowdfunding. Companies such as Looking ahead, Title III of the JOBS Act is likely to create
Crowdfunder provide an online platform for startups to new growth opportunities in marketing and financing of
post company information and funding request. Investors startups. Also, there may be a significant opportunity in
can then behave like venture capitalists by funding startups niche crowdfunding (e.g., there has recently been a surge
looking for capital. The Crowdfunder website provides key in websites exclusively focused on the crowdfunding for
information about each company and shows how much real estate.
funding is currently committed to it.

Digital Disruption in Wealth Management 12


Conclusion

Established wealth management firms have many reasons Although this report focuses on wealth management, the
to care about the new startups, technologies, and findings also apply to other types of financial services. For
solutions that are emerging in the sector. Although WM example, insurance companies and asset management
startups probably won’t disintermediate financial advisors firms have their own unique distribution channels, and
for all customer types, they may increasingly poach clients some are already expanding beyond the sale of a narrow
who no longer feel the need to consult with a human product range (e.g., life and annuity insurance). Lessons
expert for basic investment decisions. and insights from wealth management can equip these
other types of financial services firms with new tools to
Startup firms in wealth management are targeting an provide broader investment advice and more effective
evolving set of client needs. These needs are increasingly financial plans.
important for a new generation of clients, and as such are
driving fundamental changes for companies in the business Many leading financial firms are taking notice of the trends
of providing financial advice. WM startups are disrupting in wealth management and are looking to selectively
the industry by democratizing access to tailored advice and invest in building similar digital capabilities to broaden
non-traditional investments — and mass market investors their appeal to younger, digitally savvy clients. Account
are embracing the new offerings. aggregation could help make a firm the advisor of choice
in its segment, and provide an entry point for clients
Established WM firms have traditionally focused on the looking to change or enhance their portfolios. Client/
needs of their most profitable (and most demanding) advisor matching and social platforms can also serve as
customers. This focus has allowed digital startups to entry points, and both enable a company to demonstrate
establish a foothold by addressing the simpler needs of to clients that it places their needs first and is willing to
customer segments that are less profitable, but also less provide them with a tailored experience.
demanding. In the future, these startups — enabled by
emerging technologies — will likely be able to improve All of these tools can be used to enhance the financial
and expand their offerings to an ever-increasing audience advisor relationship — not replace it. By empowering
without sacrificing the economic advantages that allow advisors, incumbent firms can deliver a better client
them to be profitable at the lower-end of the market experience, address needs that are not currently being
(Figure 5). met, and capitalize on emerging market opportunities.
On the other hand, established WM firms that do not learn
from the digital startups and adjust their business models
accordingly could find themselves at a significant
competitive disadvantage.

13
Figure 5: While startups may provide a lower performance point, they can grow to disrupt
traditional WM firms.

4. Disruption

1. Overshoot
Performance

Performance that mainstream


customers willing to pay for

3. Upward march

Legend
2. Foothold Incumbent Firms
Disrupting Firms
Client Expectations

Time

Source: Adapted from Clayton M. Christensen and Michael E. Raynor, The Innovator’s Solution: Creating and
Sustaining Successful Growth. Boston: Harvard Business School Press, 2003.

Source: Raynor, Michael; “The Innovator’s Manifesto: Deliberate Disruption for Transformational Growth”

Digital Disruption in Wealth Management 14


Authors
Gauthier Vincent Robert Berini
Principal, Deloitte Consulting LLP Director, Deloitte Consulting LLP
gvincent@deloitte.com rberini@deloitte.com

Rohit Gera
Manager, Deloitte Consulting LLP
rgera@deloitte.com

Contributors
Joshua Skelly
Consultant, Deloitte Consulting LLP

This publication contains general information only, and none of the member firms of Deloitte Touche
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of this publication, rendering professional advice or services. Before making any decision or taking any action
that may affect your business, you should consult a qualified professional adviser. No entity in the Deloitte
Network shall be responsible for any loss whatsoever sustained by any person who relies on this publication.

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