I. Introduction

On May 19, the U.S. Senate passed the procedural vote for the GENIUS Act with a high majority, marking the imminent arrival of the first nationwide regulatory framework for stablecoins in the United States, attempting to legally define and regulate the operational mechanism of the "digital dollar." This will not only reshape the power structure of the U.S. stablecoin market but may also trigger profound policy, economic, and geopolitical monetary chain reactions globally, reshaping the future landscape of financial markets.

The GENIUS Act represents a redefinition of U.S. financial sovereignty: embedding stablecoins within the structure of government bonds, incorporating on-chain assets into the dollar system, and evolving the "dollar peg" from price anchoring to liquidity and value anchoring. By legislating to guide global demand for stablecoins, it ultimately transforms into demand for U.S. Treasury bonds, consolidating the dollar's anchoring position in the new round of financial system reconstruction. Stablecoins will no longer be merely the "dollar shadow" of the crypto world but will become the sovereign currency's "extended tentacles" linking the crypto market and traditional finance. Once this regulation is successfully implemented, it will open a new cycle dominated by the dollar, potentially accelerating the large-scale adoption of stablecoins and providing institutional support for the next phase of RWA and digital government bonds.

This article will analyze the legislative content and institutional design of the GENIUS Act, systematically sorting its core provisions regarding regulatory definitions, licensing mechanisms, reserve requirements, and legal status, while also dissecting the limitations of the current version of the bill, including political maneuvering, applicability, and enforcement challenges. Based on this, the article will focus on assessing the direct and indirect impacts of the bill's passage on the U.S. Treasury market, the crypto stablecoin market, and the RWA sector, aiming to comprehensively present the financial logic and profound real-world implications hidden behind this "genius bill."

II. Overview of the GENIUS Act

Stablecoins have been around for over a decade, evolving from speculative mediums to payment tools, liquidity bridges, and even store-of-value assets globally, characterized by their "fiat-pegged and redeemable at any time" nature since the birth of Bitcoin. As of May 29, 2025, the market capitalization of stablecoins has approached $250 billion; however, stablecoin assets have long remained in a regulatory blind spot, lacking clear standards in legal definitions, risk isolation, and reserve disclosure.

Source: https://defillama.com/stablecoins

The passage of the GENIUS Act will establish a complete definition, entry thresholds, operational boundaries, and reserve management rules for stablecoins, formally "naming" this core product of global financial innovation. The GENIUS Act (full name: "Guiding and Establishing National Innovation for U.S. Stablecoins Act") is the Senate version proposed by bipartisan senators including Bill Hagerty, aiming to establish the first federal regulatory framework for payment stablecoins. The House of Representatives is advancing the STABLE Act (Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025), proposed by Republican Congressman Bryan Steil, which is similar in content to the GENIUS Act, both aiming to establish a comprehensive regulatory mechanism for stablecoin issuance.

1. Core Regulatory Content

The GENIUS Act requires any payment stablecoin issued in the U.S. to obtain a federal or state-level license, and unlicensed entities are prohibited from issuing stablecoins. The bill defines "payment stablecoins" as digital assets pegged to a fixed fiat currency (such as the dollar) that can be redeemed at a fixed value (such as $1), and clarifies that such stablecoins are not backed by federal deposit insurance. Issuers must hold 100% of the equivalent high-quality reserve assets, with at least $1 in compliant reserves required for every $1 of stablecoin issued.

Permissible reserve assets are limited to: cash and coins, demand deposits at banks and credit unions, short-term U.S. Treasury securities (<=93 days), repurchase/reverse repurchase agreements collateralized by government securities, government money market funds, central bank reserves, and other low-risk assets similar to government bonds approved by regulatory agencies. The bill strictly prohibits the diversion of reserve assets for other uses or re-hypothecation, allowing reserves to be used only in limited circumstances, such as for stablecoin redemptions or as collateral for repurchase agreements. These provisions ensure that stablecoins are 1:1 pegged with solid asset backing and eliminate risks from reserve diversion.

2. Information Disclosure and Auditing

To enhance transparency, the bill requires issuers to publish reports on the circulation and reserve composition of stablecoins at least monthly, detailing the current number of issued stablecoins and the corresponding asset structure of reserves. Reports must be certified by the issuer's CEO and CFO and regularly audited by registered accounting firms. Issuers with a market capitalization exceeding $50 billion must also submit annual audited financial statements.

Additionally, issuers must establish a clear redemption mechanism to ensure that holders can quickly redeem stablecoins at face value. These frequent disclosure and external audit requirements will shift stablecoin operations from the previous "opaque black box" to transparency, aiming to dispel user concerns about the sufficiency of stablecoin reserves.

3. Licensing System and Tiered Regulation

The GENIUS Act establishes a "dual-track" regulatory system of federal and state licenses. Both bank and non-bank entities can apply to become stablecoin issuers but must register with the appropriate regulatory authority. The bill allows state regulatory agencies to oversee issuers that meet federal standards, provided that the state regulatory framework is "substantially equivalent" to federal standards.

For issuers opting for federal licenses, federal regulatory agencies will oversee them based on the nature of the institution: if the issuer is a non-bank, it will be overseen by the Office of the Comptroller of the Currency (OCC); if the issuer is a bank or its subsidiary, it will be overseen by the corresponding federal banking regulatory agency (OCC, Federal Reserve, or FDIC).

Issuers choosing state licenses will primarily be regulated by state authorities, but states may opt to enter into cooperation agreements with federal agencies (such as the Federal Reserve) for joint supervision. For interstate operations, licensed stablecoin issuers will gain mutual recognition across U.S. states, avoiding the previous limitations of being restricted by a single state's money transfer license, which will help form a unified national market.

4. Tiered Regulatory Requirements Based on Scale

The bill introduces a "$10 billion threshold" for tiered requirements based on the scale of issuers:

The Senate version (GENIUS Act) stipulates that if a state-regulated issuer's stablecoin circulation market capitalization reaches $10 billion, it must transition to federal regulation; otherwise, it cannot continue to expand issuance. Once this scale threshold is crossed, non-bank issuers will be regulated by the federal OCC, while bank issuers will be jointly regulated by federal banking regulatory agencies and states.

The House version (STABLE Act) differs in this regard, allowing state-regulated issuers to continue under state regulation regardless of scale, without a mandatory federal transition requirement. This difference reflects the divergence between the two chambers on the balance of "federal vs. state" regulatory authority, which needs to be resolved during the final coordination of legislation.

5. Legal Status and Consumer Protection

The bill clarifies the legal attributes of stablecoins: compliant payment stablecoins are excluded from the categories of securities and commodities, thus not considered securities or commodity contracts, thereby exempting them from SEC and CFTC regulation. At the same time, stablecoins are not considered bank deposits (and therefore do not enjoy FDIC deposit insurance). U.S. bankruptcy law will also be amended to prioritize the rights of stablecoin holders: in the event of the issuer's bankruptcy liquidation, the claims of stablecoin holders on reserve assets will take precedence over those of other general creditors. This bankruptcy priority ensures that even if the issuing institution collapses, users' rights to redeem equivalent reserve assets are legally protected, serving as an important consumer protection measure.

Additionally, the bill prohibits individuals with a history of financial crimes from serving as executives of issuers and requires stablecoin issuers to fully comply with U.S. anti-money laundering laws (AML) and sanctions compliance: issuers recognized as financial institutions under the Bank Secrecy Act must implement KYC identity verification, record transactions, and report suspicious activities. The Financial Crimes Enforcement Network (FinCEN) will develop specific anti-money laundering rules for digital assets and require issuers to have the technical capability to freeze, destroy, or prevent the transfer of specific stablecoins upon receiving lawful orders from courts or regulatory agencies.

6. Other Important Provisions

The GENIUS Act also includes several provisions aimed at the long-term development of the market:

• Custody and Payment Integration: It allows banks to provide custody services for stablecoins and their reserve assets for clients, using blockchain for settlement and issuing their own tokenized deposits. In other words, traditional banks can legally issue and circulate customer deposits in token form, allowing bank deposits to be transferred on-chain like stablecoins. This opens the door for banks to participate in the blockchain space and helps promote RWA on-chain innovation.

• Prohibition of Fund Mixing: For institutions providing custody of stablecoins or reserve custody, the bill requires that they be regulated financial institutions and prohibits mixing customer stablecoin reserves with their own funds, except in specific exceptional circumstances. Custodians must treat the stablecoin assets held by customers as client property and protect them from claims by other creditors in the event of the custodian's bankruptcy.

• Prohibition on Paying Interest to Holders: Both the GENIUS Act and the STABLE Act explicitly prohibit stablecoin issuers from paying any form of interest or returns to holders. Stablecoins cannot directly provide interest returns to users like bank deposits or money market funds. This aims to avoid direct interest competition between stablecoins and bank savings and is one of the more controversial provisions.

• Transition Period Arrangements: Considering the realities of the existing market, the bill sets a maximum 18-month rectification buffer period for current stablecoin issuers. For example, existing major stablecoin issuers like USDT and USDC need to apply for licenses within a specified period after the bill takes effect or adjust their organizational structure to comply with regulations; otherwise, they will be prohibited from providing stablecoin services to U.S. users after the grace period ends. This "reconciliation" clause ensures a smooth market transition, allowing currently operating stablecoins to integrate into the new regulatory framework.

III. Limitations and Progress of the GENIUS Act

Under the bipartisan struggle, the bill text has undergone multiple revisions. The main concerns include insufficient consumer protection, regulatory loopholes for anti-money laundering and foreign stablecoins (such as USDT), and doubts about potential benefits to the Trump family's cryptocurrency-related businesses. Subsequently, intensive negotiations between the two parties led to several modifications to strengthen consumer protection. For example, provisions were added to reinforce the applicability of existing federal and state consumer protection laws, clarifying that stablecoin issuers remain subject to state laws on financial consumer protection, such as anti-fraud laws, and will not be exempt from state law responsibilities due to federal licensing. Additionally, ethical provisions were added to ensure that government officials cannot participate in issuing stablecoins, responding to "conflict of interest" accusations.

1. Differences Between Bill Versions

The House's STABLE Act and the Senate's GENIUS Act are consistent in core spirit but differ in several provisions:

• Issuer Scale and Regulatory Restrictions: The Senate version stipulates that if a state-regulated issuer's issuance scale exceeds $10 billion, it must transition to federal regulation; the House version has no such requirement, allowing state regulation to continue indefinitely.

• Geographic Restrictions on Licensed Issuers: The GENIUS Act only allows domestic U.S. entities to become licensed issuers, prohibiting unlicensed foreign stablecoins from being sold to the public in the U.S. after a three-year transition period unless the relevant foreign regulatory authority reaches an equivalency agreement with the U.S. This means that overseas stablecoin issuers like Tether will be considered "non-compliant" stablecoins by the U.S. financial system if they do not establish a regulated entity in the U.S. In contrast, the House STABLE Act is relatively open to foreign compliant stablecoins: it allows issuers from countries recognized by the U.S. Treasury as having "equivalent" regulation to circulate their stablecoins in the U.S. on the condition that they agree to accept U.S. regulatory inspections and reporting obligations.

2. Limitations of the GENIUS Act

Although the GENIUS Act is seen as an important milestone in U.S. crypto policy, it has several limitations and concerns:

• Limited Scope: The bill focuses on fiat-pegged payment stablecoins and does not address other types of crypto assets. For example, algorithmic stablecoins do not fall under the definition of "payment stablecoins" and will remain in a legal gray area. Decentralized stablecoins like DAI, which lack a centralized issuer, are almost unable to meet licensing application, AML compliance, and other requirements. Therefore, while the GENIUS Act encourages centralized compliant stablecoins, it objectively suppresses decentralized attempts.

• Regulatory Enforcement Limitations: The bill requires foreign stablecoins to reach a regulatory equivalency agreement within three years to be sold in the U.S. However, in practice, if some foreign entities provide stablecoins to U.S. users through decentralized exchanges or peer-to-peer wallets, how regulatory authorities will monitor and enforce compliance remains a challenge. There are still many unregulated trading venues and wallets globally, and the U.S. cannot eliminate their use.

• Political Risks: The bill's introduction and passage are influenced by the political backdrop of the Trump administration, attempting to consolidate the dollar's position through stablecoins. Although ethical provisions were ultimately added to the bill, a change in party control could still affect its fate. If the Democratic Party returns to power in 2028, there is a possibility of re-evaluating stablecoin policies. Therefore, the long-term stable implementation of the GENIUS Act depends on stablecoins proving their value and consolidating stakeholder support within a few years.

• International Coordination: Stablecoins are inherently cross-border, and U.S. legislation alone cannot resolve all issues. The EU has already passed the MiCA regulation to manage crypto assets, including requirements for stablecoin issuance and reserves. The People's Bank of China has strictly prohibited the issuance or trading of any stablecoins domestically. The GENIUS Act will become an international reference, but countries have varying attitudes, and multiple regulatory models may coexist or even conflict in the future.

3. Progress of the GENIUS Act

On May 19, several previously cautious "crypto-friendly" Democratic senators announced their acceptance of the revised proposal and expressed their willingness to vote in favor of the bill. That evening, the Senate broke the impasse with a vote of 66 in favor and 32 against, successfully advancing the bill into the full chamber debate and voting process.

In early June, the Senate is expected to formally vote to pass the GENIUS Act, requiring only a simple majority to be sent to the House for consideration. In the House, the Financial Services Committee has already passed the STABLE Act with bipartisan support in March and submitted it to the full chamber, awaiting scheduling for a vote. As the two chambers' versions need to be coordinated and unified, congressional members plan to complete the merged bill and send it to President Trump for signing before the summer recess. President Trump has publicly supported stablecoin legislation multiple times, claiming that "crypto will expand the global dominance of the dollar." It is anticipated that the GENIUS Act could officially become law around August 2025, marking the first piece of legislation in the U.S. specifically targeting stablecoins.

IV. Impact of the GENIUS Act on the U.S. Treasury Market

As of May 2025, the total federal government debt of the United States has exceeded $36 trillion, accounting for approximately 123% of GDP, with the debt scale reaching a historical high. The normalization of fiscal deficits and surging interest burdens have put the Treasury market in a dual dilemma of continuous expansion and tight funding sources. The bill's requirement for stablecoin reserves to primarily invest in high liquidity assets such as short-term U.S. Treasury securities is expected to convert global demand for digital dollars into a rigid demand for U.S. Treasuries, alleviating financing pressure and strengthening the dollar's dominant position in the crypto financial system.

Source: https://fiscaldata.treasury.gov/datasets/debt-to-the-penny/

• Enhanced Demand for Treasuries: Currently, most major dollar-pegged stablecoins (such as USDT and USDC) have already allocated a significant amount of U.S. Treasuries as reserves. Once the regulation takes effect, it will direct a massive pool of crypto funds toward U.S. government bonds. For instance, as of the first quarter of 2025, Tether held $120 billion in U.S. Treasuries within its reserves, ranking it as the 19th largest "institution" holder of U.S. Treasuries globally. The robust growth of stablecoins will provide the U.S. Treasury with a new stable source of funding, becoming a strategic opportunity to strengthen dollar hegemony and reduce government financing costs, converting global demand for digital dollars into real purchasing power for U.S. Treasuries.

• Fund Flows and Impact on Banks: The large-scale adoption of stablecoins will also affect the flow of traditional bank deposits and money market funds. When users transfer funds from banks to stablecoins, stablecoin issuers will invest the corresponding funds in U.S. Treasuries or deposit them in demand accounts at large banks. This may lead to deposit outflows from small and medium-sized banks, potentially triggering a chain of liquidity risks. In response, the GENIUS Act mitigates the direct competition of stablecoins with bank savings to some extent by prohibiting interest payments on stablecoins. At the same time, the bill grants regulatory agencies like the Federal Reserve the authority to intervene: when stablecoin issuance encounters violations or unusual activities, the Federal Reserve and OCC can take action in "exceptional emergency situations," including halting new coin issuance if necessary. This allows regulators to monitor large-scale flows of stablecoin funds, providing early warnings and interventions for systemic risks.

• Potential Risks: Currently, the scale of short-term debt held by stablecoins is relatively small compared to the total U.S. Treasury debt of $36 trillion, but if a major stablecoin collapses, the sell-off of short-term Treasuries in its reserves could trigger a fire-sale, impacting the liquidity of the entire short-term debt market. The GENIUS Act aims to minimize the credit risks and spillover effects of stablecoins through requirements for 100% high-quality reserves and priority liquidation rights. Overall, the implementation of the bill will make stablecoins highly transparent and regulated funding pools, similar to money market funds, providing stable buying support for U.S. Treasuries and closely binding U.S. government interests with global demand for digital dollars.

V. Impact of the GENIUS Act on the Stablecoin Market

Currently, fiat-collateralized stablecoins dominate the total supply of stablecoins, with a supply of $115 billion, accounting for 90.5%; crypto asset over-collateralized stablecoins supply $11.3 billion, accounting for 8.9%; and algorithmic stablecoins only account for 0.6%. Among them, dollar-pegged fiat stablecoins like USDT and USDC hold overwhelming shares. The GENIUS Act will reshape the competitive landscape and regulatory ecology of the current stablecoin market. The main impacts are reflected in the issuer landscape, market confidence, and the compliance transformation of existing stablecoins.

Source: https://dune.com/KARTOD/stablecoins-overview

• Issuer Landscape and Competitive Dynamics: Under the new law, stablecoin issuance will transition from previous wild growth to a licensed competitive era. Non-bank entities can legally issue stablecoins by applying for licenses, no longer limited to banks issuing digital dollars. It is foreseeable that after the regulation is implemented, large financial institutions and tech giants in the U.S. may accelerate their entry into the stablecoin space. Currently dominant stablecoins like USDT and USDC will face challenges from new competitors on Wall Street, with various companies likely to offer more favorable rates and services to attract users. For users, this means safer and more diverse stablecoin options, along with potential cost reductions and improved services.

• Changes in the Existing Stablecoin Landscape: As the largest stablecoin by market capitalization globally, USDT is issued by the offshore-registered Tether company and has long operated outside U.S. regulation. Once the GENIUS Act takes effect, unlicensed foreign stablecoins will gradually be marginalized in the U.S. market. During the approximately 18-month transition period set by the bill, if Tether wishes to continue serving U.S. users, it may need to establish a subsidiary in the U.S. and apply to become a licensed issuer, complying with U.S. regulations and meeting reserve and auditing requirements. Otherwise, after the three-year grace period, U.S. entities (including exchanges, brokers, etc.) will be prohibited from providing trading and turnover services for non-compliant foreign stablecoins. Some analysts believe that Tether's historically opaque operations and complex offshore structure, if forced to disclose reserve details and accept U.S. regulation, may expose hidden risks, thereby undermining market confidence in USDT. In contrast, Circle's USDC is almost certain to emerge as a compliance winner. Circle is already registered in the U.S., regularly discloses reserves, and undergoes audits, strictly adhering to KYC/AML in collaboration with Coinbase, presenting itself as a "model stablecoin." Circle is expected to apply for a federal OCC issuer license or come under Federal Reserve supervision, making USDC one of the first officially recognized compliant stablecoins.

• Market Confidence and Adoption Scale: Stablecoin legislation will significantly enhance public and institutional trust and acceptance of stablecoins. A series of mandatory reserve and disclosure requirements will accelerate the mainstream adoption of stablecoins: consumers will feel more secure using stablecoins for payments and transactions, and businesses will be more willing to accept stablecoins as a payment method. It is expected that more online platforms and offline merchants will support stablecoin settlements. U.S. users are likely to pay with digital dollars in their mobile wallets at coffee shops and supermarkets, just as conveniently as using cash or credit cards. Furthermore, the launch of compliant stablecoins will facilitate the conversion between fiat and cryptocurrencies, reducing transaction friction and costs, thereby promoting innovation in the financial industry.

• Impact of the Prohibition on Interest Payments: The bill's prohibition forces stablecoins to abandon paying interest to users, making stablecoins more likely to be used for payment settlements and short-term value storage rather than long-term holding for interest differentials. This may make stablecoins more like "digital cash" rather than "digital deposits." For funds seeking returns, they may prefer to remain in traditional banks or invest in money market funds (with annual returns around 5%). However, stablecoin issuers themselves will continue to profit from reserve assets, and to compete for users, they may indirectly provide incentives, such as transaction fee discounts and airdrop rewards.

VI. Impact of the GENIUS Act on the RWA Market

With the implementation of the stablecoin bill, the U.S. financial system is quietly opening its doors to the tokenization of real-world assets (RWA). The GENIUS Act not only regulates stablecoins but also sends a clear signal: mainstream financial institutions can participate in blockchain activities within a regulated framework, including issuing on-chain financial products. This will promote the tokenization process of various real financial assets, bringing about institutional changes and new investment opportunities.

• Tokenized Deposits and Bank Innovations: The bill explicitly allows regulated banks to use distributed ledger technology to issue tokens representing customer deposits, known as "tokenized deposits," meaning banks can attempt to issue on-chain dollar deposits and conduct on-chain settlements. For the RWA market, active participation from banks will bring a wealth of real assets on-chain: banks can attempt to issue tokenized rights to loans, receivables, real estate investment trusts, and other assets to qualified investors, providing products with higher liquidity and transparency. The on-chain transformation of traditional financial assets is expected to accelerate under regulatory protection.

• Improvement of the Stablecoin Ecosystem Benefits RWA: Stablecoins are referred to as the "bridge" connecting the crypto world and real assets. Other RWA tokens (such as on-chain bonds and notes) can leverage stablecoins as value carriers during trading and settlement, eliminating the need for fiat currency settlements and significantly improving efficiency. For example, a bond token based on Ethereum can be purchased and transferred instantly using USDC, unrestricted by bank operating hours. This creates conditions for introducing 24/7 trading and instant settlement into the bond market.

• Growth and Opportunities in the RWA Market: Over the past two years, the concept of RWA has begun to rise in the crypto space, with many protocols attempting to introduce U.S. Treasuries, corporate bonds, mortgages, and other assets in token form into DeFi. Although the scale is still small, it is growing rapidly. The world's largest asset management company, BlackRock, launched a tokenized money market fund called BUIDL on the Avalanche chain in March 2024, which has exceeded $2.9 billion in assets as of May 29. MakerDAO plans to invest up to $1 billion in tokenized U.S. Treasuries, and on-chain real assets are attracting interest from various capital sources. Major institutions have begun to lay out in this emerging field: Goldman Sachs is developing a digital bond platform, JPMorgan is expanding its Onyx on-chain settlement network, and SWIFT is also testing blockchain for cross-border asset transfers, indicating that the RWA market scale may experience exponential growth in the coming years.

Source: https://defillama.com/stablecoin/blackrock-usd

• Risks and Challenges: Compliance costs will be a significant bottleneck for RWA tokenization: the auditing, reporting, and other requirements of the new stablecoin regulations will incur substantial expenses, which may be a burden for small innovators attempting RWA. Overly stringent rules may cause some creative ideas to "die in the womb." Additionally, RWA tokens involve technical and legal challenges such as cross-chain governance and legal ownership proof, which are still under exploration. If regulators lack flexibility in formulating specific rules, it may limit the adaptability of RWA models.

It is expected that in the future, we will see more regulatory sandbox projects allowing financial institutions to experiment with issuing more types of on-chain assets. After the success of stablecoins, the next legislative focus may shift to the formulation of rules for security tokens, decentralized finance (DeFi), and other areas, further improving the regulatory framework for digital assets.

VII. Conclusion: The Digital Expansion of Dollar Sovereignty

The passage of the GENIUS Act not only establishes a stablecoin regulatory mechanism for the first time in the U.S. through federal law but also represents a rare strategic alignment between national will and market innovation. It signifies that the U.S. officially regards stablecoins as an important component of financial infrastructure, bridging the institutional gap between cryptocurrencies and traditional finance. From the refinancing logic of the U.S. Treasury market to the reshaping of the stablecoin competitive landscape and the policy incentives for RWA tokenization, the signals released by the GENIUS Act are clear: the dollar must not only dominate the settlement system of the real world but also lead the flow of value on-chain. Stablecoins become a new "value extension tool" for the dollar, with their reserve allocation rights becoming a new bargaining chip in U.S. financial policy.

This "genius bill" is not without its flaws. It still faces controversies and uncertainties regarding decentralized stablecoins, cross-border issuance regulation, and political neutrality. The flexibility of enforcement after regulation is implemented, market feedback, and international coordination will determine whether it becomes a true global standard or a "stablecoin special zone" in the U.S.

Nevertheless, this "genius bill" has already legitimized stablecoins, taking a critically important step in U.S. digital financial regulation, and will accelerate the advancement of broader digital asset legislation, including DeFi, crypto securities, and CBDCs. The ultimate goal of this process is not just to "regulate stablecoins," but to create a "stable regulatory environment for the crypto world," which will continue to profoundly change the structure of global financial markets and the landscape of the digital economy.

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