To register as an investment adviser in Arizona, you file Form ADV (Parts 1 and 2) for your firm and Form U-4 for each investment adviser representative, both submitted electronically through the FINRA IARD/WebCRD system, along with a $250 firm fee, a $40 fee per representative, and an Affidavit of Adviser Activity in Arizona, all filed with the Arizona Corporation Commission Securities Division under A.R.S. § 44-3153. The form tells the state who you are, how you handle client money, what you charge, and whether you have any disciplinary history.
Getting this wrong is not a small problem. A single mismatched answer on Form ADV Part 1B or a missing fingerprint card can freeze your application for weeks, and Arizona law lets the Commission deny or revoke a license for false statements. Roughly 15,000+ state-registered investment advisers operate across the United States under this exact framework, and state regulators report that the most common reason for a stalled application is an incomplete or inconsistent filing — not a bad business plan.
Here is what you will learn in this guide:
- 🧭 How to set up your FINRA Entitlement account and access Form ADV and Form U-4 the right way the first time
- 📝 A true line-by-line walkthrough of every major Form ADV and Form U-4 field, with sample entries you can copy the format of
- 💵 The exact fees, the fingerprint rule, and the Series 65 exam requirement that trip up most first-time filers
- 👥 Three real filer scenarios — a solo founder, a two-partner LLC, and a new representative — walked through start to finish
- ⚠️ The field-level mistakes that get applications rejected and how to avoid every one of them
What These Forms Are and Who Must File Them
An investment adviser (IA) is any person or firm that, for pay, advises others about buying or selling securities. In Arizona, if you have a place of business in the state or enough clients here, you must be licensed before you give that advice. The license is granted by the Securities Division of the Arizona Corporation Commission (ACC), the state agency that enforces the Securities Act of Arizona and protects Arizona investors from fraud.
There are two layers to the registration, and you must understand the split. The firm files Form ADV, which describes the business itself — its owners, its services, its fees, and its custody practices. Each person at the firm who gives advice files Form U-4, the individual application that discloses that person’s employment, exams, and any legal or financial trouble. A one-person firm files both, because the owner is both the firm and its only representative.
Three statutes set the foundation. A.R.S. § 44-3153 governs the firm application and lists every supporting document. A.R.S. § 44-3156 governs representative licensing through Form U-4. And A.R.S. § 44-3151 makes it unlawful to act as an adviser without a license. The penalty for skipping registration is steep: the Commission can issue a cease-and-desist order, impose civil penalties, and order restitution to clients.
Who must file depends on your assets under management. Advisers with less than $100 million in regulated assets generally register with the state of Arizona, while those at or above $100 million register with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940 and only notice file in Arizona. This $100 million line comes from the federal National Securities Markets Improvement Act (NSMIA), which divides oversight between states and the SEC. Knowing which side of the line you fall on is the first decision you make, because it changes which boxes you complete on Form ADV.
Before You Start: Documents and Information You Need
Open nothing until you have gathered every item below. The fastest applications are the ones where the filer never has to stop and hunt for a number. Missing even one document can push your start date back by weeks because the Securities Division will not process an incomplete file.
Here is your pre-filing checklist:
- FINRA Entitlement credentials. You cannot reach Form ADV or Form U-4 without a WebCRD/IARD account; without it, you have no way to file at all.
- Your firm’s legal name and entity documents. The Arizona Corporation Commission cross-checks your entity registration, and a name that does not match your Articles of Organization triggers a hold.
- Federal Employer Identification Number (EIN). Form ADV asks for it directly, and a missing or wrong EIN breaks the link between your filing and your tax records.
- CRD number (if you have one). If you previously worked at a broker-dealer or another RIA, your existing CRD number must be used, because a duplicate number creates a record conflict.
- Exam or designation proof. You need a passing Series 65 score (or Series 7 + 66), or a qualifying designation such as CFP, CFA, ChFC, or PFS; without it, the Division denies the representative.
- Fingerprint card and processing fee. Sole proprietors and representatives need fingerprints on file; without them the application cannot clear the background review.
- Audited balance sheet (only if required). If you will take custody of client funds or collect large prepaid fees, A.A.C. R14-6-206 requires one, and skipping it where required is an automatic deficiency.
- Your written advisory agreement. A.R.S. § 44-3154 requires you to confirm a compliant client contract; without it your filing is incomplete.
- Form ADV Part 2A and 2B drafts. These plain-English brochures must be uploaded as part of Part 1; a filing with no brochure attached is rejected on sight.
- Proof of lawful presence. A.R.S. § 41-1080 requires Arizona residents to document lawful presence before a license issues.
Each item connects to a specific field or attachment later in the form. Gather them into one folder now, and label each file clearly, because you will upload several of them directly into the IARD system.
Where to Get the Forms and How to Access Them
You do not download these forms as blank PDFs and mail them in. Both Form ADV and Form U-4 live inside the FINRA IARD/WebCRD system, the electronic platform Arizona uses to receive and review applications. FINRA itself does not regulate you — it simply runs the filing pipes that the Arizona Corporation Commission reads from.
Your first step is to request a FINRA Entitlement, which is the master account that unlocks IARD. You complete the entitlement paperwork through FINRA’s entitlement program, name a Super Account Administrator (SAA) for your firm, and fund an IARD Daily Account that FINRA debits for your fees. Plan for one to two weeks here, because nothing else can start until entitlement is approved.
Once inside, Form ADV is filed under the IARD module and Form U-4 under the WebCRD module — they share one login. The Arizona-specific Affidavit of Adviser Activity and the fingerprint packet are not in IARD; you download those from the ACC Securities Division Forms page and submit them separately to the Division.
Confirm you are using the current version of each form. Form ADV is a uniform form maintained by NASAA and the SEC and is revised periodically; the version inside IARD is always the current one, so file through the live system rather than any saved PDF to be sure your revision date is right.
Step-by-Step: How to Fill Out Form ADV and Form U-4 Line by Line
This is the heart of the process. Work through the items in the order the system presents them, and treat every answer as something a regulator will read and cross-check. Sample entries below are shown in italics so you can tell them apart from instructions.
Form ADV Part 1A, Item 1 — Identifying Information
This field asks for your firm’s legal name, its main business address, and how clients can reach you. You answer with the exact legal name on your Arizona entity filing, your principal office address, phone, and email, and your CRD number if one already exists. Desert Ridge Advisors LLC enters its name in full, not a shortened “DRA,” and lists 4455 E. Camelback Rd., Suite 200, Phoenix, AZ 85018.
A common edge case is the firm that operates under a “doing business as” name. If you market yourself as Desert Ridge Wealth but your legal name is Desert Ridge Advisors LLC, you enter the legal name in the main field and disclose the DBA in the dedicated other-names section. The most frequent mistake here is typing a trade name where the legal name belongs, which causes the ACC’s entity cross-check to fail and your file to stall. A widespread misconception is that the address can be a P.O. Box; it cannot, because the principal office must be a physical location where books and records are kept.
Form ADV Part 1A, Item 2 — SEC or State Registration
This field asks whether you are registering with the SEC or with one or more states. You select state registration and check Arizona if your regulated assets are under $100 million, which is the path for most new firms. Desert Ridge Advisors LLC, managing $38 million, checks the box for state registration and selects Arizona as its home state.
The key edge case is the firm sitting near the $100 million line. If you expect to cross it within 120 days of filing, federal rules may let you register with the SEC instead, so check your projected assets carefully. The common mistake is checking SEC registration when you do not yet qualify, which gets your filing bounced back and forces a refile with the state. People often wrongly believe they may pick whichever regulator they prefer; in reality the asset threshold decides for you.
Form ADV Part 1A, Item 5 — Information About Your Advisory Business
This field asks how many clients you have, how much you manage, and the types of clients you serve. You enter your regulated assets under management (RAUM), your approximate number of clients, and the fee structures you use. Desert Ridge Advisors LLC reports $38,000,000 in RAUM, 42 clients, and checks boxes for individuals and high-net-worth individuals.
A frequent edge case is the firm with no assets yet because it has not opened. New firms report $0 in RAUM and 0 clients, which is allowed and normal at launch. The common mistake is inflating client or asset counts to look more established, which is a misstatement the Commission can act on under A.R.S. § 44-3201. Many filers wrongly think RAUM means only fee-paying accounts; it actually includes all securities portfolios for which you provide continuous, regulated advice.
Form ADV Part 1A, Item 9 — Custody
This field asks whether your firm holds or controls client cash or securities. You answer yes or no, and if yes, you report the amount and the number of clients involved. Most new state advisers answer no because they use an independent qualified custodian; Desert Ridge Advisors LLC checks No since client assets sit at a national brokerage custodian.
The important edge case is the adviser who can deduct fees directly from client accounts — that may count as limited custody depending on the safeguards in place. The serious mistake is answering “no” while actually controlling client funds, because misstating custody triggers the audited balance sheet and surprise-exam rules under A.A.C. R14-6-206 and invites enforcement. A common misconception is that holding a client password is harmless; it can create custody and change your entire compliance burden.
Form ADV Part 1A, Item 11 — Disclosure Information
This field asks whether you or your firm have any criminal, regulatory, civil, or financial events to report. You answer each yes/no question honestly and attach a Disclosure Reporting Page (DRP) for every “yes.” A clean firm checks No across the board, while a firm with a past event attaches a DRP explaining a 2019 state regulatory fine, since resolved.
The edge case people miss is old or expunged matters; many events must still be reported even if dismissed, so when unsure, disclose. The gravest mistake on the entire form is answering “no” to a disclosure question that should be “yes,” because a hidden event discovered later is grounds for denial or revocation and possible fraud charges. The dangerous misconception is that a dismissed charge never needs reporting — the form asks about charges, not just convictions, so read each question literally.
Form ADV Part 1B — Arizona State-Specific Items
This section appears only for state-registered firms and asks Arizona-specific questions about your business, bonding, and supervision. You answer each Part 1B item based on Arizona’s rules, including questions tied to financial requirements under A.R.S. § 44-3159. Desert Ridge Advisors LLC confirms it does not maintain custody and therefore is not subject to the related balance-sheet trigger.
The edge case here is a firm registered in several states, because Part 1B answers can differ from one state to the next. The common mistake is copying Part 1B answers from another state’s filing, which produces wrong responses Arizona will flag. Filers often wrongly assume Part 1B repeats Part 1A; it does not, and skipping it is one of the top reasons Arizona returns an application.
Form ADV Part 2A — The Firm Brochure
This part asks you to describe your firm in a plain-English narrative covering services, fees, conflicts, and disciplinary history. You write it in clear language, follow the required item order, and upload it as a PDF inside Part 1. Desert Ridge Advisors LLC states its fee as 1.00% of assets under management, billed quarterly in arrears.
The edge case is the firm offering multiple services, such as financial planning plus asset management, which each need their own fee description. The common mistake is dense, jargon-filled writing, because Arizona expressly requires the brochure to be understandable to ordinary clients. A common misconception is that Part 2A is optional at filing; it is mandatory, and the application is incomplete without it.
Form ADV Part 2B — The Brochure Supplement
This part asks for background on each individual who gives advice, including education, experience, exams, and any disciplinary events. You prepare one Part 2B per advising person and upload it with the filing. Desert Ridge Advisors LLC prepares a Part 2B for founder Maria Lopez listing her CFP designation and Series 65.
The edge case is a firm with several representatives, since each one needs a separate supplement. The mistake is leaving out a person who actually advises clients, which leaves a regulated activity undocumented. People often wrongly believe back-office staff need a Part 2B; only those who give advice or supervise advice do.
Form U-4, Items 1–7 — Representative Identifying and Employment Information
This part asks for the individual representative’s name, addresses, Social Security number, and a ten-year employment and residence history. You complete it for each person, with no gaps in the timeline and dates in MM/YYYY format. Maria Lopez enters her name as it reads on her Social Security card and lists 06/2018–present for her current role.
The edge case is a gap in employment, such as time off; you must account for it as unemployed rather than leave a hole. The common mistake is leaving timeline gaps, which the Division flags and sends back for correction. A frequent misconception is that only securities jobs count; the form wants all employment and residence history for the full period.
Form U-4, Item 14 — Disclosure Questions
This part asks the representative a long list of yes/no questions about criminal, regulatory, civil, customer-complaint, and financial events. You answer each truthfully and attach a DRP for every “yes.” A clean applicant answers No throughout, while one with a past event attaches a DRP describing a 2017 customer complaint, denied and closed.
The edge case is a bankruptcy within the last ten years, which must be reported even though it is not a crime. The most damaging mistake is concealing an event, because Form U-4 is signed under penalty of perjury and a false answer can end a career. The misconception is that a sealed or expunged matter never needs disclosure; many still do, so disclose when unsure.
Form U-4, Item 15 — Exam and Designation Requirement
This part links to the representative’s exam record and any qualifying professional designation. You confirm the Series 65, or Series 7 plus Series 66, or an accepted designation such as CFP, CFA, ChFC, or PFS that waives the exam under A.A.C. R14-6-204. Maria Lopez relies on her active CFP designation to satisfy the requirement.
The edge case is an exam taken years ago, which can expire if you have been out of the industry beyond the allowed window. The mistake is assuming a lapsed Series 65 still counts, which leads to a denial. A common misconception is that a college finance degree alone qualifies; it does not — Arizona requires the exam or a listed designation.
Submitting the Affidavit, Fingerprints, and Fees
After the electronic forms, you handle the Arizona-only pieces. You sign the Affidavit of Adviser Activity in Arizona required by A.R.S. § 44-3153(C)(4), submit a fingerprint card with the processing fee if your prints are not already on file, and let IARD debit the $250 firm fee and $40 representative fee. Desert Ridge Advisors LLC mails its signed affidavit and Maria Lopez’s fingerprint card to the Securities Division while the fees clear through IARD.
The edge case is the applicant whose fingerprints are already on file with the Division, CRD, or IARD, who may skip the new card. The mistake is forgetting the affidavit, which is an Arizona-specific document the IARD system will not prompt you for. People wrongly assume paying the IARD fee completes everything; the paper affidavit and prints must reach Phoenix too.
Three Filled-Out Examples Using Real Scenarios
Below are three common filers walked through the form from start to finish. Each table shows the major sections and what that person enters.
Scenario 1 — Maria Lopez, Solo Founder Launching a One-Person RIA in Scottsdale
Maria is a CFP starting her own firm with no employees and modest assets.
| Form Section | What Maria Enters |
|---|---|
| Form ADV Item 1 (Firm name) | Lopez Wealth Advisors LLC, 7373 E. Doubletree Ranch Rd., Scottsdale, AZ 85258 |
| Form ADV Item 2 (Registration) | State registration — Arizona |
| Form ADV Item 5 (RAUM/clients) | $12,000,000, 18 clients |
| Form ADV Item 9 (Custody) | No |
| Form ADV Item 11 (Disclosure) | No across all questions |
| Form ADV Part 1B | Confirms no custody, no bonding triggered |
| Form ADV Part 2A fee | 1.00% AUM, billed quarterly |
| Form U-4 Item 15 (Exam) | CFP designation, waiving Series 65 |
| Arizona extras | Signs affidavit, submits fingerprint card, pays $250 + $40 |
Scenario 2 — Carlos and Dana Reyes, Two-Partner LLC Switching from SEC to State
Their firm dropped below $100 million and must move from SEC to Arizona registration.
| Form Section | What the Reyes Firm Enters |
|---|---|
| Form ADV Item 1 (Firm name) | Reyes Capital Management LLC, 1 N. Central Ave., Phoenix, AZ 85004 |
| Form ADV Item 2 (Registration) | State registration — Arizona (withdrawing from SEC via ADV amendment) |
| Form ADV Item 5 (RAUM/clients) | $74,000,000, 96 clients |
| Form ADV Item 9 (Custody) | No — assets at independent custodian |
| Form ADV Item 11 (Disclosure) | No for the firm |
| Form ADV Part 1B | Completes all Arizona-specific items fresh |
| Form ADV Part 2B | One supplement each for Carlos and Dana |
| Form U-4 (each partner) | Series 7 + 66 listed for both |
| Arizona extras | Two affidavits, fingerprints on file via CRD, pays $250 + $80 |
Scenario 3 — Aisha Bello, New Representative Joining an Established Phoenix Firm
Aisha is hired as an IAR at a firm that is already registered, so only her U-4 is filed.
| Form Section | What Aisha Enters |
|---|---|
| Form U-4 Items 1–7 (Identity) | Aisha Bello, full ten-year employment history, no gaps |
| Form U-4 Item 7 (Current employer) | Saguaro Financial Advisors LLC, 06/2026–present |
| Form U-4 Item 13 (Residence) | Ten-year address history, Phoenix |
| Form U-4 Item 14 (Disclosure) | No across all questions |
| Form U-4 Item 15 (Exam) | Series 65, passed 03/2026 |
| Fingerprints | New fingerprint card submitted to Division |
| Lawful presence | Proof of lawful presence provided |
| Fee | Firm pays $40 IAR fee through IARD |
| Brochure | Firm prepares her Form ADV Part 2B |
How to File the Completed Forms
Arizona uses one primary channel for the forms themselves and a separate channel for the paper supporting documents. Knowing both keeps your application from sitting half-finished.
- Online through FINRA IARD/WebCRD. Submit Form ADV and Form U-4 at iard.com; fees of $250 (firm) and $40 (each representative) are debited from your funded IARD Daily Account, plus a $15 FINRA annual IAR processing fee. Processing typically runs several weeks, and your proof of filing is the IARD confirmation and date-stamped filing record you should save.
- By mail to the Securities Division. Send the signed Affidavit of Adviser Activity, the fingerprint card with its processing fee, the audited balance sheet if required, and proof of lawful presence to the Arizona Corporation Commission, Securities Division, 1300 W. Washington St., Third Floor, Phoenix, AZ 85007. Keep your mailing receipt and a copy of everything sent as your proof of filing.
Pay the fingerprint processing fee by the method the current fingerprint packet specifies; the ACC page lists this fee as $22, though some third-party guides cite $24, so confirm the exact amount with the Division before mailing. Questions on status go to the Division at (602) 542-1426 or SEC-AOD@azcc.gov.
What Happens After You File
Once your filing lands, the Securities Division reviews it under A.A.C. R14-6-105, which sets the timeline for processing license applications. A reviewer reads your Form ADV, checks Part 1B against Arizona’s rules, verifies exams and fingerprints, and reconciles your brochures with your Part 1 answers. Expect to wait several weeks for a first response.
If the file is incomplete, you receive a deficiency letter listing what is missing or inconsistent. You then fix each item — often a Part 1B answer, a missing brochure, or an absent affidavit — and resubmit. The clock does not truly finish until the Division has a clean, complete file, so a fast, accurate first filing is the single best way to get licensed sooner.
When everything checks out, the Division grants the license, and you may legally give advice in Arizona. Your firm and each representative then carry ongoing duties, including filing a statement of material changes through IARD under A.R.S. § 44-3159 whenever key facts change, and renewing each year. Your registration does not lapse on its own as long as you renew on time.
Mistakes to Avoid When Filling Out the Forms
- Entering a trade name where the legal name belongs. This breaks the ACC entity cross-check and stalls your filing.
- Choosing SEC registration when you manage under $100 million. Your application is bounced and you must refile with the state.
- Leaving Part 1B blank or copying it from another state. Arizona returns the file because Part 1B is state-specific.
- Answering “no” to custody while controlling client funds. This misstatement triggers enforcement and the audited balance-sheet rules.
- Concealing a disciplinary event on Item 11 or U-4 Item 14. A hidden event found later is grounds for denial or revocation.
- Skipping the Arizona Affidavit of Adviser Activity. IARD never prompts for it, so a complete electronic filing still ends up incomplete.
- Forgetting the fingerprint card or fee. The background review cannot finish, freezing the whole application.
- Uploading no Form ADV Part 2A or 2B. The brochures are mandatory, and the file is rejected without them.
- Leaving employment-history gaps on Form U-4. Any unexplained gap draws a deficiency letter.
- Assuming a lapsed Series 65 still counts. An expired exam without a qualifying designation leads to denial.
- Underfunding the IARD Daily Account. If the account cannot cover the fees, FINRA does not transmit your filing.
- Writing a jargon-heavy Part 2A. Arizona requires plain English, and a dense brochure draws a correction request.
Do’s and Don’ts
Do’s
- Do gather every document first, because a complete file is the fastest path to a granted license.
- Do use your exact legal entity name, since the ACC matches it against your Arizona registration.
- Do disclose every event when unsure, because over-disclosure is safe and concealment is fatal.
- Do write Part 2A in plain English, as Arizona requires brochures clients can actually understand.
- Do save all confirmations and receipts, since they are your only proof of when you filed.
- Do confirm the current fingerprint fee with the Division, because published amounts vary between $22 and $24.
Don’ts
- Don’t give advice before your license is granted, because unlicensed activity violates A.R.S. § 44-3151.
- Don’t use a P.O. Box as your principal office, since the address must be a physical records location.
- Don’t copy Part 1B from another state, because Arizona’s questions differ.
- Don’t inflate client or asset numbers, as misstatements invite enforcement.
- Don’t forget the paper documents mailed to Phoenix, since IARD only handles the electronic forms.
- Don’t let your renewal lapse past December 31, because late renewal can interrupt your right to operate.
Pros and Cons of Filing on Your Own vs. With Help
Pros of filing yourself
- Lower cost, because you avoid consultant fees that can run into thousands of dollars.
- Deeper knowledge, since you learn your own compliance obligations firsthand.
- Full control, as you decide exactly how every answer reads.
- Faster small fixes, because you respond to deficiency letters without a middleman.
- Direct agency contact, which builds your relationship with the Division.
Cons of filing yourself
- Higher error risk, because Part 1B and custody questions are easy to misread.
- More time spent, since the learning curve is steep for a first filing.
- Missed nuances, as edge cases like limited custody are simple to overlook.
- Slower approval, because beginner mistakes draw deficiency letters that reset progress.
- Compliance gaps, since a do-it-yourself brochure may miss required disclosures.
Form ADV vs. Form U-4 at a Glance
| Feature | What It Covers |
|---|---|
| Form ADV | The firm — its name, owners, services, fees, custody, and disclosures, filed once for the business |
| Form U-4 | Each individual representative — identity, employment history, exams, and personal disclosures |
| Who files | A firm files ADV; every advising person files a U-4 (a solo founder files both) |
| Where filed | ADV through the IARD module; U-4 through the WebCRD module, same login |
| Core fee | $250 for the firm via ADV; $40 per representative via U-4 |
FAQs
How much does it cost to register an investment adviser in Arizona? Yes, there are set fees: $250 for the firm and $40 per representative through IARD, plus a $15 FINRA annual IAR processing fee and a fingerprint processing fee.
Do I have to use the FINRA IARD system to file? Yes, Arizona receives both Form ADV and Form U-4 only through the FINRA IARD/WebCRD system, so you must set up a FINRA Entitlement account before filing anything.
Do I register with Arizona or the SEC? No, you do not choose freely; advisers managing under $100 million generally register with Arizona, while those at or above $100 million register with the SEC and notice file.
Do I write my legal firm name or my brand name in Form ADV Item 1? Yes, you write the exact legal entity name in Item 1 and disclose any brand or DBA in the separate other-names field to pass the entity check.
Do I have to complete Form ADV Part 1B if I already finished Part 1A? Yes, Part 1B asks Arizona-specific questions Part 1A does not cover, and skipping it is a top reason the Division returns applications.
Do I answer “yes” to custody if I only deduct my fees from client accounts? Yes, fee deduction can count as limited custody depending on safeguards, so review the custody rule under A.A.C. R14-6-206 before answering.
Do I report a dismissed criminal charge on the disclosure questions? Yes, the forms ask about charges, not just convictions, so report it and attach a Disclosure Reporting Page rather than risk concealment.
Do I need to pass the Series 65 exam? No, not always; you can use Series 7 plus Series 66, or a qualifying designation such as CFP, CFA, ChFC, or PFS to satisfy the requirement.
Do I need to submit fingerprints if they are already on file? No, if your prints are already on file with the Division, CRD, or IARD, you may skip submitting a new fingerprint card.
Do I need an audited balance sheet? No, not unless you take custody of client funds or collect large prepaid fees, in which case A.A.C. R14-6-206 requires one.
Do I mail anything, or is everything online? No, not everything is online; you mail the Arizona affidavit, fingerprint card, and any balance sheet to the Securities Division while the forms and fees go through IARD.
Do I have to renew my registration every year? Yes, both the firm and each representative renew by December 31 each year, paying $250 and $40 respectively, or the registration can lapse.
Do I need to report changes after I am licensed? Yes, you must file a statement of material changes through IARD under A.R.S. § 44-3159 whenever key facts about your firm change.
Do I need proof of lawful presence? Yes, Arizona residents must document lawful presence under A.R.S. § 41-1080 before the license is granted.
Related reading
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