(On June 2024, 6, the content was significantly upgraded using Claude.ai. It also includes information on the situation in each country.)
At Identiverse 2022, I moderated a panel discussion titled "How to Implement Open Banking and Open Data Successfully."
Date and time: June 2022, 6 22:4 pm – 10:5 pm MDT
Location: Gayloard Rocky Conference Center Crest 3-5
The panelists are:
- Dave Tonge, CTO, Moneyhub
- Wesley Dunnington, VP of Architecture, Ping Identity
- Ralph Bragg, Chief Technology Officer, Raidiam
Dave Tonge is the co-chair of the OpenID Foundation's FAPI Working Group. He is also the CTO of MoneyHub, a Fintech company operating in Europe, and one of the key figures in the UK Fintech Association. He has provided numerous comments from a Fintech perspective on Open Banking and PSD2 legislation in the UK and Europe.
Wesley Dunnington is the chair of the Security Working Group of the Financial Data Exchange (FDX), an open banking standardization organization whose main members are banks and is active mainly in the U.S. He is also a board member of the OpenID Foundation and acts as a bridge between the OpenID Foundation and FDX.
Ralph Bragg is the CTO of Radium, a UK Fintech company. He was previously the UK Open Banking Implementation Entity, where he designed the Open Banking Directory and built conformance tests. With this knowledge, Radium provides services around the country, and is heavily involved in the directory and conformance tests for Open Banking in Brazil. He is a veteran member of the OpenID Foundation's FAPI WG.
In the panel discussion, I began by asking, "Why do we pursue Open Banking?" and then I asked the three panelists for their insights on what is important to actually implement Open Banking successfully.
Panel Contents
Here's a rough summary of this panel:
- The Importance of Open Banking
Open banking has been gaining attention worldwide as a key initiative to promote innovation and competition in financial services. Its main objective is to simplify access to banking data for third-party providers while at the same time protecting the security and privacy of users. - The technical side
Standardized security profiles such as FAPI and conformance testing are key to successful Open Banking implementations, as they ensure interoperability between different financial institutions and FinTech companies. - Global implementation status
Different countries and regions are taking different approaches:- UK and EU: Regulatory-led approach
- United States: Market-driven approach
- Brazil: Rapid implementation and innovative use cases
- Australia, Canada, and the Middle East: learning and adapting
- Challenges and learnings
- User experience matters
- The importance of the role of regulators
- Fraud Prevention and AML Initiatives
- The need for cooperation between banks and fintech
- Future prospects
- Open banking goes beyond simple data sharing and has the potential to lead to the creation of new financial services and business models, as well as contribute to the provision of cross-border financial services and the creation of a more inclusive financial ecosystem.
- Important Considerations
- Continuous improvement of standardization and conformance testing
- Balancing security and convenience
- Harmonizing regulations with market needs
- Achieving global interoperability
The panel emphasized that open banking is a key element in shaping the future of financial services, and that its success requires the right combination of technology, regulation and business models.
Details
You can also watch this panel discussion on YouTube. Unfortunately, I couldn't hear the Q&A part... The sections and timestamps are listed below, so you can jump to the part that interests you.
1. Introduction and panelists (0:00 – 1:38)
- Nat Sakimura presents a panel on implementing open banking and open data
- Panelists' biographies:
- Dave Tong: CTO of MoneyHub and co-chair of the OpenID Foundation's FAPI Working Group
- Ralph Bragg: CTO of Radium, involved in major open banking implementations
- Wes Dunnington: VP of Architecture at Ping Identity
2. Open Banking White Paper (1:43 – 3:26)
- Two white papers discussed:
- Published paper: "Open Banking, Open Data, and Financial Grade APIs"
- Working Draft: The Future State of Global Interoperability in Open Banking/Finance
- Request for Feedback on Working Draft
3. Key requirements for Open Banking (3:32 – 5:53)
- Two main themes:
- Simplify third-party provider connections to banks
- Protect user security and privacy
- Historical Background: UK Open Banking Standards (2015-2016)
- Goal: Consent-based data access, breaking down silos, and driving innovation
4. Open Banking Technology Components (5:54 – 11:45)
Functional API Specification
1. Definitions
- Functional API specifications define the specific content and format of data that banks and fintech companies will share.
- This includes account information, transaction history, and payment instructions.
2. Standardization Challenges
- Complete international standardization of functional API specifications is difficult.
- This is because different countries and regions have different financial products and regulations.
3. Flexibility is key
- A certain degree of flexibility will be required to accommodate regional and national specifics.
- Example: Data structure for a country-specific retirement plan such as a 401(k)
4. Ease of implementation
- Differences in functional API specifications are relatively easy to address.
- This can mainly be solved by creating a mapping code.
5. Focus Shift
- The FAPI Working Group initially also aimed to standardize functional API specifications.
- We then shifted our focus to security profiles.
6. The evolution of open banking
- Functional API specifications are evolving as open banking develops.
- It is being expanded as new financial products and services emerge.
7. Diversity of Use Cases
- There is a need to support a variety of use cases.
- Obtaining Account Information
- Payment Instructions
- Credit check, etc.
8. The Importance of Data Models
- It is important to define a consistent data model.
- This makes it easier to interpret the data across different systems.
9. Version Control
- Regular updates and good version control are key.
- There is a balance to be struck between adding new features and maintaining backwards compatibility.
10. Implementation Priorities
- Standardization of security profiles should be a priority.
- After security, we recommend focusing on the functionality aspects.
Functional API specifications are an important element in defining the basic functions of open banking, but complete international standardization is a challenge. Approaches that focus on standardizing security and authentication while allowing a certain degree of flexibility in the functional aspects are being adopted.
Security Profile (FAPI)
1. Definition of FAPI
- FAPI: Financial-grade API security profile.
- A highly secure profile based on OAuth 2.0 and OpenID Connect.
2. Purpose
- High level of security for financial data and transactions
- Establishing secure communications between banks and fintech companies
3. Main Features
- Strong Client Authentication Mechanisms
- Secure handling of tokens (unification to Sender Constrained Token)
- Strict encryption and signing requirements
4. FAPI Version
- FAPI 1.0: the currently widely adopted version
- FAPI 2.0: A new version that is simpler and easier to implement
5. Standardization is important
- Ensuring interoperability between different financial institutions and fintechs
- Reducing the implementation burden on developers
6. Conformance Testing
- A rigorous conformance test suite is provided
- This ensures consistency and reliability across various implementations.
7. Global Recruitment
- It is used in many countries, including the UK, Brazil, and Australia.
- It contributes to improving the interoperability of international financial services.
8. Security Verification
- Performing Formal Verification
- Proving safety through mathematical methods
9. Implementation Challenges
- Complex implementation due to high technical requirements
- Challenges in integrating with existing systems
10. Future Outlook
- Expanding to open finance and open insurance
- Application to a wider range of financial services
11. Impact on the Industry
- Lowering barriers to entry for fintech companies
- Raising API Security Standards for Banks
12. Regulatory Relations
- Regulators in many countries recommend or require FAPI
- Tendency to be adopted as part of compliance requirements
FAPI is a profile that is essential for security in open banking, and its adoption is expanding worldwide. With its high security requirements and rigorous conformance testing, it contributes to the realization of safe and reliable financial APIs.
Consent and Authorization Management
1. Importance
- Core elements of open banking
- The basis for protecting user data and ensuring privacy
2. The Need for Standardization
- FAPI 2.0 is standardizing consent and authorization
- The goal is to establish a consistent consent process
3. User Experience
- Simplifying the consent process and ensuring transparency are issues
- It is important to design a consent flow that is easy for users to understand
4. Granularity of consent
- A mechanism is needed that allows for detailed control over the scope and duration of data access
- Flexibility for users to select specific data items and time periods
5. Withdrawal and management of consent
- The importance of a mechanism for users to easily withdraw consent
- Providing a dashboard that allows users to check and manage consent status at a glance
6. Regulatory Compliance
- Ensuring consistency with data protection regulations such as GDPR
- Flexibility to meet local and regional regulatory requirements
7. Security implications
- Consent processes coupled with strong authentication mechanisms
- Security measures to prevent unauthorized access and misuse of consent
8. Bank Liability
- The importance of banks' responsibility to implement proper consent management
- Ensuring transparency to maintain user trust
9. The role of fintech companies
- Responsibility to clearly explain the scope and purpose of consent
- Ensuring proper use and protection of data
10. Continuous Improvement
- Continually improving the consent process based on user feedback
- Flexible evolution to accommodate new technologies and use cases
11. Education and awareness
- Educating users about the importance of consent and authorization
- Raising awareness about the benefits and risks of open banking
Consent and authorization management is a critical component of the success of open banking and is key to gaining and maintaining user trust. It is important to balance standardization and ease of use, while ensuring security and transparency.
Discussion on the importance of standardization and conformance testing
The importance of standardization and conformance testing was discussed, including:
1. Significance of Standardization
- Ensuring interoperability
- Reduce development costs
- Fostering innovation
2. Role of FAPI
- Standardization of security profiles
- Defining high-level security requirements based on OAuth 2.0 and OpenID Connect
3. The Importance of Conformance Testing
- Ensuring consistency of implementation
- Guaranteed security level
- Achieving interoperability
4. The UK example
- Adoption of a common API
- Strict compatibility testing
- Contributing to improving the reliability of the ecosystem
5. Conformance Testing Challenges
- Differences between test and production environments
- The Need for Continuous Testing and Certification
- Ensuring transparency of test results
6. Market vs. regulation
- Standardization challenges in a market-driven approach
- Regulators drive adoption of standards
7. Difficulties in Global Standardization
- Differences in regulations between countries and regions
- Challenges in integrating with existing systems
8. Evolution of Conformance Testing
- Addressing new threats and use cases
- Continuous improvement of testing methodology
9. Developer Perspective
- Reducing development burden through standardization
- Recognizing the importance of passing conformance tests
10. Impact on the entire ecosystem
- Lowering barriers to entry
- Increased reliability drives user adoption
11. Future Outlook
- Expanding to Open Finance
- The Importance of Standardization in Cross-Border Trade
12. Lessons Learned
- Standards alone are not enough, conformance testing is key
- Consistency in implementation details is important
Standardization and conformance testing were emphasized as essential elements for the success of Open Banking, and in particular the importance of conformance testing, which goes beyond simply defining standards to ensure their accurate implementation, was reiterated, ensuring security, interoperability, and ultimately trust in the entire ecosystem.
5. Open banking implementation status in each country (11:46 – 23:19)
The situation in the UK and Europe
On the state of Open Banking in the UK and Europe, the following was said:
- Regulatory-driven approach:
- Both the UK and the EU have adopted a regulation-led approach.
- In the EU, it is based on PSD2 (the amended Payment Services Directive), and in the UK, it is based on a directive from the Competition and Markets Authority (CMA).
- UK pioneering initiative:
- The UK is one of the most advanced countries in Europe in implementing open banking.
- A high level of standardization has been achieved through the adoption of common APIs and rigorous compatibility testing.
- EU Challenges:
- Within the EU, the level of implementation varies from country to country, and complete uniformity has not been achieved.
- Although there are "common standards" such as the Berlin Group and STET standards, they are highly optional and full compatibility is not guaranteed. In reality, there are 4000 standards in disarray. As a result, four or five giant aggregators have emerged to ensure connectivity. We hope that this will be improved in PSD3.
- UK FAPI Adoption:
- The UK has adopted FAPI (Financial Grade APIs) to increase security and interoperability.
- This lowers the barrier to entry for fintech companies and encourages innovation.
- User experience is key:
- In the UK in particular, there is a strong focus on improving the user experience.
- For example, smooth app-to-app redirection must be implemented.
- Going beyond data sharing:
- Services are being developed that go beyond simple data sharing, such as sharing payment instructions and account information.
- In the UK in particular, there is also growing integration with government services such as paying taxes.
- Conformity testing and certification:
- The UK has a rigorous compliance testing and certification process which contributes to the trust of the ecosystem.
- In the EU, challenges remain in this regard.
- Market Maturity:
- In the UK, open banking services are used by millions of active users each month, and the market is reaching a mature stage.
- In other EU countries, uptake varies.
- Development of the Fintech Ecosystem:
- The advancement of open banking is accelerating the growth of fintech companies, particularly in the UK.
- A variety of innovative services have emerged, including personal financial management, credit checking, and payment services.
- Future challenges:
- Continuing to strengthen data security and privacy protections.
- Expansion to cross-border transactions and broader financial services (open finance).
- Increase user awareness and usage.
- Differences between the EU and the UK:
- After Brexit, differences are emerging between the regulatory environments of the UK and the EU, and attention is focused on how this will develop in the future.
The UK and European open banking landscape is a good example of the benefits and challenges of a regulatory-led approach: the UK in particular has a success story that other countries can learn from, but there are still challenges to be overcome before there is a unified implementation across the EU.
Brazil's rapid implementation
- Rapid implementation
- The panel highlighted that Brazil has implemented open banking at a very fast pace compared to other countries: Brazil completed its implementation in just one year, compared to over five years for the UK.
- Adoption of international standards
- Brazil learned from the experiences of other countries and adopted international standards (especially FAPI), which allowed it to avoid “reinventing the wheel” and to leverage already proven methods.
- A comprehensive approach
- Brazil has taken a comprehensive approach that includes payments from the start, meaning the implementation takes into account financial services as a whole, not just data sharing.
- Regulatory and market cooperation
- Regulators and market participants worked closely together to ensure effective implementation, which resulted in the harmonization of technical standards and regulatory requirements.
- Innovative Use Cases
- In addition to implementing existing features, Brazil is also introducing new and innovative use cases, such as an instant payment system called "Pix" and decoupled payments (paying for goods directly from your bank account with one click).
- Unified authentication and authorization
- Brazil has adopted a central authentication and authorization system to make it easier for fintech companies and banks to work together, improving interoperability between systems while maintaining security.
- Continuous development
- After the basic implementation of Open Banking, Brazil is quickly expanding it to other financial services sectors, such as the insurance sector (Open Insurance).
- Technical consistency
- Brazil's adoption of FAPI and rigorous conformance testing has enabled a high degree of technical consistency, allowing developers to access the entire banking system with a minimal amount of code (the panel noted "220 lines of Node.js").
- The Brazilian example shows that a clear vision, adoption of international standards, regulatory and market cooperation, and openness to innovation can lead to a fast and effective implementation of open banking, making it a model for other countries to follow in their own implementation of open banking.
Australia's Challenges and Course Correction
The challenges and course corrections in Australia’s open banking implementation can be summarised as follows:
- Initial challenges:
- Developing its own security profile: Australia initially did not adopt international standards and instead sought to develop its own security and authentication mechanisms.
- Slow implementation: Development of proprietary systems has delayed implementation and slowed progress compared to other countries, particularly Brazil.
- Interoperability issues: The proprietary approach created challenges in interoperability with the international financial system.
- Increased Complexity: Customized solutions have become complex to implement and maintain for banks and fintech companies.
- Course correction:
- Decision to adopt FAPI 2.0: The Australian banking industry has decided to adopt the international standard, FAPI 2.0.
- Regulatory support: The decision was the result of lobbying from banks and was also supported by regulators.
- Improved interoperability: The transition is expected to improve interoperability with international financial systems.
- Accelerated implementation: Adoption of existing international standards is expected to speed up the implementation process.
- Developing the ecosystem: The changes are expected to enable Australia's open banking ecosystem to develop more quickly.
- Lesson:
- Importance of International Standards: This case study shows the importance of adopting international standards.
- Need for flexibility: The importance of flexibility to reassess early decisions and move to more effective approaches was highlighted.
- Importance of industry voice: Feedback from the banking industry led to policy changes, demonstrating the importance of listening to the industry voice.
The Australian experience illustrates the challenges in implementing open banking and the importance of a flexible approach to overcoming them. This experience provides valuable lessons for other countries as they implement open banking.
The US market-driven approach
- Market-driven, not regulatory-driven:
- Unlike Europe and the UK, the US has no mandatory government regulations.
- Instead, market demand and competition are driving the development of open banking.
- The importance of consumer demand:
- Consumer demand for fintech companies and innovative financial services is on the rise.
- This puts market pressure on banks to provide data access.
- Financial Data Exchange (FDX) Role:
- FDX is an industry-led, not-for-profit organization developing open banking standards.
- FDX has adopted FAPI as the normative standard and is working to align with international standards in terms of security.
- Incremental progress:
- Standardization and interoperability are being achieved step by step.
- Initially, each bank tended to develop its own API, but standardization is gradually progressing.
- Authentication and Authorization Challenges:
- Since there is no uniform certification and authorization system, separate agreements with each bank may be required.
- This is particularly a barrier for smaller fintech companies.
- Build the data directory:
- FDX is developing a directory of registered entities that will provide a market-driven central source of information.
- Security and Conformance Testing Challenges:
- Adoption of FAPI is progressing, but rigorous conformance testing has yet to be fully implemented.
- This leaves consistency of implementation a challenge.
- Impact on existing businesses:
- The advancement of open banking may force existing intermediaries such as data aggregators to change their business models.
- Potential restrictions:
- There are currently no regulations, but there are discussions about the possibility of some regulation being introduced in the future.
- Innovation and competition:
- A market-driven approach encourages innovation and competition.
- However, due to delays in standardization, interoperability remains a challenge.
- The US market-driven approach encourages innovation but also poses challenges in terms of standardization and interoperability, and its success depends on balancing industry voluntary initiatives with consumer demand.
Canada's early stages
- Establishment of a regulatory body:
- Canada is currently in the process of establishing a regulator to oversee open banking.
- The body is expected to play a role in guiding and overseeing the implementation of open banking.
- Learn from international best practices:
- Canadian regulators are looking to learn from the experiences of other countries.
- In particular, it seeks to draw lessons from the UK’s implementation of open banking and the US’s market-led approach.
- Dialogue with stakeholders:
- The regulator is in dialogue with a range of experts, including open banking stakeholders in the UK and FDX stakeholders in the US.
- This allows us to gain first-hand insight into their success stories and challenges.
- A cautious approach:
- Canada is in the careful planning stages rather than rushing into implementation.
- This shows that they are taking the time to learn from the experiences of other countries and find the best approach.
- Finding a balance:
- It seeks a balance between regulatory and market-driven approaches.
- We aim to balance consumer protection with promoting innovation.
- Standardization Interest:
- We are considering adopting international standards (especially FAPI).
- This could be an important step towards ensuring international interoperability in the future.
- Industry Participation:
- We are actively listening to the views of industry players, including banks and fintech companies.
- In this way, we aim to develop a practical and actionable framework.
- A consumer-centric approach:
- Our goal is to provide consumers with more choice and better financial services.
- Data security and privacy protection are key focuses.
- Possibility of phased implementation:
- Rather than implementing everything at once, we are looking at a phased approach.
- This allows you to learn at each stage and make adjustments as needed.
- Hopes for the future:
- The hope is that open banking will foster financial innovation and strengthen Canada's financial services industry.
- Canada's approach is thoughtful and comprehensive, learning from international experiences while developing a model that is tailored to Canada's unique circumstances. It is hoped that this early preparation and planning will set the stage for future success.
Growing interest in the Middle East and Africa
- Rapidly growing interest:
- Interest in open banking is growing rapidly in many countries across the Middle East and Africa.
- This is part of a broader effort to develop the digital economy and promote financial inclusion.
- Influence of the British model:
- Many Middle Eastern countries are following the UK's open banking model.
- This is based on our past relationship with the UK and the success of the UK model.
- Adoption of international standards:
- An increasing number of countries are considering adopting international standards such as FAPI (Financial Grade API).
- This aims to ensure interoperability with the global financial system.
- Active regulatory engagement:
- Regulators in many countries are actively involved in developing open banking frameworks.
- This is in line with the government's policy of promoting the digital economy.
- Wide range of applications:
- Many countries are considering opening up access to a wider range of financial services beyond simply sharing banking data.
- This could include insurance, investments and other financial services.
- Accelerating Digital Transformation:
- Open banking is seen as a catalyst to accelerate digital transformation across the region.
- This is expected to encourage the growth of fintech companies and the modernization of existing financial institutions.
- Promoting financial inclusion:
- In Africa in particular, open banking is gaining attention as a means to promote financial inclusion.
- This is expected to provide new financial services to people who have not had access to traditional banking services.
- Approaches tailored to national circumstances:
- Each country is tailoring its open banking approach to suit its own national circumstances.
- It takes into account the regulatory environment, technology infrastructure, consumer needs, and more.
- Addressing technical challenges:
- We are tackling technical challenges such as data security, privacy protection, and API standardization.
- Many countries are following international best practices.
- Future Outlook:
- Open banking is part of a broader digital economy strategy.
- Many countries aim to foster financial innovation and digital economic growth through open banking.
- The development of open banking in the Middle East and Africa is still in its early stages, but many countries are actively working in this area. A balance between a locally tailored approach and adopting international best practices will be key to future success.
6. Learnings and Challenges (23:20 – 37:09)
Lessons and challenges cited included:
The Importance of Conformance Testing
- Ensure consistency of implementation
- Verify compliance with security requirements
- Ensure interoperability between systems
- Increased trust across the ecosystem
- Improve development efficiency and quality
User Experience Considerations
- Balancing ease of use and safety
- A transparent and simple consent process
- Smooth transitions between apps (e.g. app-to-app redirection)
- The Importance of User Education and Awareness
- Continuous feedback and improvement
The role of regulators and market dynamics
- Balancing regulatory vs. market-driven approaches
- Promoting standardization and innovation
- Ensuring consumer protection and data security
- Creating a fair and competitive environment
- Facilitating cross-border trade
A Fintech Perspective on Implementation
- The importance of access to standardized APIs
- Issues and Importance of Passing Conformity Tests
- Balancing cooperation and competition with banks
- Opportunities for developing innovative services
- Adapt to regulatory requirements and get to market quickly
These aspects are interrelated and a balanced consideration of all these elements is essential for the success of the open banking ecosystem: conformance testing provides the technical foundation, user experience drives adoption, regulation ensures fairness and a fintech perspective drives innovation.
7. Open Banking Use Cases and Innovations (37:10 – 40:16)
Brazil's Payments Advancements
- Rapid Open Banking implementation (within 1 year)
- Introducing the Pix System: Making instant payments a reality
- Introducing decoupled payments: one-click direct bank payments
- Strong regulatory support and industry cooperation
- Ensuring safety by adopting advanced technical standards (FAPI)
- Accelerating Fintech Innovation
The challenge for intermediaries in the ecosystem
- The changing role of traditional data aggregators
- API standardization reduces the need for a middle layer
- The need to transition to new value-added services
- Shift from data access to data analysis and utilization
- Increasing importance of security and proof of authenticity
- The need to balance regulatory compliance with technological innovation
Impact on traditional financial services providers
- Mandatory data sharing through APIs
- Intensifying competition with new entrants
- Accelerating Digital Transformation
- Redefining customer relationships (seeing open banking as an opportunity)
- Searching for new revenue models (API as a Product)
- Increased investment in security and compliance
- The importance of collaboration and partnerships with FinTech
These aspects point to the profound transformation of the financial services industry that Open Banking will bring: the Brazilian example shows the potential for rapid implementation and innovation, intermediaries are having to explore new roles, and traditional financial institutions are being forced to adapt and innovate. Overall, these changes are leading to the creation of a more open, efficient and innovative financial ecosystem.
8. Q&A session (40:17 – 52:46)
- Discussion of bank incentives for data sharing
- Anti-fraud and anti-money laundering considerations
- Cross-border banking challenges and opportunities
Bank incentives for data sharing
- Regulatory compliance: Often enforced as a legal requirement
- Recognizing our role as stewards of customer data
- Potential new revenue streams: API as a Product
- Improve customer service and loyalty
- Providing innovative services through collaboration with fintech
- A strategic imperative to maintain market share
Anti-fraud and anti-money laundering considerations
- New payment methods increase fraud risk
- The Importance of Strong Customer Authentication (SCA)
- The Need for Real-Time Monitoring and Behavioral Analysis
- Utilizing eKYC (electronic customer identification)
- Sharing data between banks to improve fraud detection
- Working with regulators to develop a risk management framework
Cross-border banking challenges and opportunities
- The complexity of navigating different regulatory environments
- Aligning with data localization requirements
- Making cross-border payments more efficient and cheaper
- Promoting global financial inclusion
- Increasing importance of international standardization (FAPI, etc.)
- Simplify multi-currency trading
- Expectations for building an international open banking ecosystem
These aspects show that open banking goes beyond just data sharing and is a key element in shaping the future of financial services. Banks have new opportunities and challenges, and security and regulatory compliance remain important. At the same time, improving cross-border transactions has become a key goal in the evolution of global financial services.
9. Closing Remarks (52:47 – 53:11)
- Final thoughts on customer experience and consistent API implementation
- Reference to the white paper for further information
The panel covered a wide range of topics regarding open banking implementation, challenges and opportunities in different global markets, and highlighted the importance of standardization, security and user experience in a successful open banking ecosystem.