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Implementation Completion Report (ICR) Review - Strengthening The Business Environment For Enhanced Economic Growth DPL

1. Project Data:   
ICR Review Date Posted:
Is this review for a Programmatic Series?
First Project ID:
Project Name:
Strengthening The Business Environment For Enhanced Economic Growth DPL
Project Costs(US $M)
 751.88  751.88
L/C Number:
Loan/Credit (US $M)
 751.88  751.88
Sector Board:
Cofinancing (US $M)
Board Approval Date
Closing Date
01/31/2012 01/31/2012
General industry and trade sector (33%), Central government administration (21%), General finance sector (21%), Telecommunications (13%), Micro- and SME finance (12%)
Regulation and competition policy (60%) Other financial and private sector development (20%) Tax policy and administration (10%) Public expenditure financial management and procurement (10%)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Iradj A. Alikhani
Fareed M. A. Hassan Ismail Arslan IEGPS2

2. Project Objectives and Components:

a. Objectives:

    The Overall Program Development Objective (PDO) is to support economic policies that will strengthen Mexico´s business environment and the micro-economic foundations for enhanced economic growth and employment generation (Program Document (PD) p.ii and para. 54). The formulation of the development objective in the Loan Agreement differs slightly but is the same in essence.

    Even though this was a single operation, it was part of a broader programmatic engagement (including investment lending, knowledge and coordination services) to support the Government’s competitiveness and growth agenda (PD para. 56).

b. If this is a single DPL operation (not part of a series), were the project objectives/key associated outcome targets revised during implementation?

c. Policy Areas:

The operation covered four mutually reinforcing areas (pillars) based on 14 prior actions taken by the Borrower and implemented prior to Board presentation (PD para. 54 and Loan Agreement (LA) Schedule I):
(i) strengthening the conditions for competition in crucial markets, in particular the telecommunications sector and public procurement:

    • Enhance the competition in the telecommunications markets by:
      1. the issuance of a concession on July 5, 2010 to use a pair of fibers of the state-owned power utility's fiber-optic network for the provision of telecommunication services.
      2. the issuance, through Decision of the Federal Telecommunication Commission (Cofetel) dated December 14, 2009, of bidding documents for public bidding of multiple concessions for the use of radio spectrum.
    • Enhance the competition, efficiency and transparency of public procurement of goods and services by the enactment of:
      3. A regulation of the Law of Acquisitions, Leases and Services of the Public Sector issued by the President and published in the Borrower’s Official Gazette on July 28, 2010 establishing, inter alia, the regulations for the use of framework agreements.
      4. Guidelines on Acquisitions, Leases and Services and Public Works and Services related thereto issued by the Ministry of Public Administration (SFP) and published in the Borrower’s Official Gazette on September 9, 2010, establishing, inter alia, the rules for the use of reverse auctions in public procurement processes.
(ii) streamlining business regulations that will lower trade and other transactions costs and facilitate the adoption of new technologies:
    • Taken steps for the reduction of business transaction costs and the facilitation of trade by:
      5. The enactment of a Presidential decree simplifying and reducing the number of tax declaration and payment procedures, published in the Borrower’s Official Gazette on June 30, 2010.
      6. The execution of a contract between the Borrower, through the Revenue Administration Service (SAT), and a technology integration company for the development and operation of an electronic single trade window, dated November 11, 2010.
      7. The enactment of four Ministerial Decisions that eliminate redundant certification requirements by recognizing the use, in the Borrower’s territory, of standards and conformity assessment procedures applied in the USA or Canada for electronic appliances and data processing equipment, issued by the Ministry of Economy (SE) and published in the Borrower’s Official Gazette on August 17, 2010.
(iii) improving the regulatory framework to foster financial sector access, stability and market transparency:
    • Adopted measures to enhance the access to finance and the stability of the financial system as evidenced by the enactment of:
      8. A resolution amending the General Provisions Applicable to Credit Institutions (including, inter alia article 325 Bis1 of the said general provisions) to facilitate the supply of financial services using mobile phone accounts, issued jointly by the Ministry of Finance and Public Credit (SHCP) and the National Banking and Securities Commission (CNBV), and published in the Borrower’s Official Gazette on April 15, 2010.
      9. A decree amending the Law of Credit Information Societies including Articles 19, 20, and 42, to support the enhancement of coverage, data quality and consumer service provided through credit bureaus, issued by the President and published in the Borrower’s Official Gazette on May 25, 2010.
      10. A decree establishing the Financial Stability Council issued by the President and published in the Borrower’s Official Gazette on July 29, 2010.
      11. Prudential regulation strengthening provisioning requirements for mortgage loans and non-revolving consumer credit issued by CNBV and published in the Borrower’s Official Gazette on October 12, 2010.
(iv) promoting public-private partnerships (PPP) in infrastructure to expand core infrastructure services essential to the productivity of Mexican firms:
    • Taken measures to foster private investment in infrastructure as evidenced by the enactment of:
      12. a decree amending the Law on Federal Roads, Bridges and Auto Transport to allow extensions of concessions during any of its stages, issued by the President and published in the Borrower’s Official Gazette on November 4, 2010.
      13. A circular letter issued by the National Commission for the Retirement Savings System (CONSAR) amending the investment regime of pension funds (SIEFORES) to authorize them to invest in structured securities up to 15% of their portfolio, depending on the risk profile of the relevant SIEFORE, published in the Borrower’s Official Gazette on June 11, 2010.
      14. Guidelines issued by the board of the National Infrastructure Fund (FONADIN) allowing it to participate as a minority investor in private equity funds specialized in infrastructure with the purpose of promoting the creation of such funds, dated May 14, 2010.

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates
The Loan was approved by the Board on 1/18/2011, and became effective on 12/20/2011. The IBRD loan of US$751.88 million was fully disbursed in a single tranche upon effectiveness. The loan closed as scheduled on 1/31/2012.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:

Rated substantial – Improving Mexico’s competitiveness is at the core of the 2010 Country Partnership Strategy Progress Report (CPSPR) which describes Bank assistance in this area (paras. 14-18). The operation reviewed here was not specifically mentioned in the CPSPR. Nevertheless, it supports the aforementioned priority and conforms to the type of proactive Bank support to the Government’s 10-point agenda envisaged in the CASPR (para. 39-40) whereby: “additional Development Policy Lending (DPL) for reforms and budget support could address a range of areas.” The thrust of the operation was to contribute to improved productivity, an area that has hindered growth since the 1990s. As noted in the ICR (para. 26), the targeted policy areas were selected because they were Government priorities, and their selection was further validated by analytical work.

Even though the project was ambitious and tackled four distinct policy areas, it was also selective leaving aside important related issues listed in the 10 point agenda, such as labor productivity, tax evasion and, to a lesser extent, reducing monopolies (other than in telecoms). This was justified because other Bank instruments focused on these areas, including: (i) the Economic Policies in Response to the Crisis DPL; and (ii) Innovation for Competitiveness project; both of which closed on 12/31/2010. The project was complex and this was managed by 11 institutions as well as the Ministry of Finance. Nevertheless, this unbundling of responsibilities appears to have contributed to the empowerment of entities who managed the implementation of the reforms and their ultimate success. One instance where this arrangement did not work well was for M&E -- as discussed further-on.

b. Relevance of Design:

Rated substantial - The project consisted of 4 mutually reinforcing policy areas identified as priorities by Government, and validated by Bank and independent studies and learning products (ICR Box 1). Some of the reforms, for instance in the telecom sector, faced resistance from special interest groups and incumbent firms – as evidenced by legal actions that ensued. As noted in the ICR (para. 27), while the ambition of each action varied according to what was deemed feasible and within the capabilities of implementing agencies, grouped together these actions contributed to a better business environment.

Project design involved a single project as opposed to a programmatic series of loans. This option may have been driven in part by possible rejection by Government of implied future policy conditionality. However, a different type of “horizontal” programmatic approach was pursued instead, through a series of mutually supporting DPLs, investment lending and knowledge products.

The design of the operation and support to the Government’s 10-point agenda in the areas of reducing tax evasion and widening the tax base might have been strengthened by including reforms of corporate taxation which by one measure seems higher in Mexico than China, Brazil and Turkey: As reflected in the doing business indicator, taxation could be improved further: The partial inclusion of this area (reducing time required by business to comply with tax regulation), may have been justified by the fact that reforms were already being pursued by Government (PD para. 26), the Bank was providing TA on tax (ICR Box 1) and there was no need to make the operation more complex.

Despite shortcomings in how some results were measured, the project design was based on a clear and logical results chain.

The ICR contains a balanced discussion of the above areas together with a favorable assessment, but does not propose a rating for relevance, which is rated substantial herein.

4. Achievement of Objectives (Efficacy) :

Rated substantial - The project contributed to the Government's objective of improving Mexico’s competitiveness by strengthening the business environment and the micro-foundations for enhanced growth and employment generation. Two global reports (Index of the Global Development Forum and Doing Business) cited in the ICR (para. 30) provide evidence to this effect. The ICR (par. 32) also discusses how the reforms are associated with employment gains in the formal economy. Attribution to the project is partial as other factors also affected employment: global recovery helped it, while the conservative fiscal stance by Government may have slowed it down. Furthermore, reforms were regulatory in nature as legislative actions are difficult. Therefore concentration of economic power in key sector continues to affect competitiveness (ICR para. 28). The passage of the Federal Competition Law (ICR para. 19) therefore constitutes a key advance.

Even though other factors outside the project may have contributed to the objective, there is good logical link between the actions supported by the project and progress towards PDOs. The ICR provides further evidence (section 2.1) on progress towards achieving objectives under the project’s four policy areas.

Objective 1: Strengthening the conditions for competition in crucial markets, in particular the telecommunications sector and public procurement – substantial achievement:
    • Improved competition in the telecommunications markets is reflected in the increase in broadband connection, which once mobile connection is included surpasses project targets. There was also a parallel 38% increase in internet users. These results can be linked directly to the leasing to the private sector of state-owned fiber-optic network and concessions for the use of radio spectrum (both of which were prior actions under the project), and the introduction of 4G service. One measure for the effectiveness of the actions is that progress was achieved despite resistance from vested interested, notably through lawsuits.
    • Reverse auctions were fully implemented and contributed to enhanced competition, efficiency and transparency of public procurement of goods and services – the actual number exceeds target by a factor of more than three, even though they concern a small percentage of overall procurement. Furthermore, based on updated figures provided by the Borrower, competition is greater -- the average number of bidders has risen from 3 in 2010 to 4.2 in 2012. These achievements were underpinned by prior-actions supported by the project. However, progress on the implementation of frameworks agreements (detailed in PD para. 66) was slower than expected.
    • The ICR notes that the full impact of the above measures is likely to be more evident in the medium-term. For instance, broadband connections were delayed due to initial technical problems with the fiber-optic cables (paras. 20 and 21).

Objective 2: Streamlining business regulations that will lower trade and other transactions costs and facilitate the adoption of new technologies modest achievement:
    • The objective was to be achieved through the reduction of business transaction costs and the trade facilitation. The main achievement was a significant reduction in time needed to comply with tax regulations, which would especially help Small and Medium Enterprises (SMEs). These gains are being consolidated through electronic filing (ICR para. 16). As noted earlier, this was one of the broader elements of the tax reform agenda.
    • The ICR (para. 16) was unable to quantify savings associated with the implementation of the zero based regulation program (PD para. 72), but presents data that indicates progress.
    • Even though regulatory reforms were implemented, trade facilitation experienced difficulties due to delays in the implementation of an electronic system. These issues have been overcome and the new electronic platform is progressively becoming operational -- information from January 2012 indicates that 21 out of 60 processes were linked to Revenue Administration Services and the rest were being connected. More recent public information indicates that the system became fully operational in June 2012;
    • The rating for this objective, which is in-line with the ICR appreciation, considers what can be established at the present time. The full impact of these reforms should be quantifiable by the time the proposed IEG assessment (see below) takes place and may result in a higher rating.

Objective 3: Improving the regulatory framework to foster financial sector access, stability and market transparency substantial achievement:
    • The DPL supported measures to enhance access to finance and stability of the financial system. One of the specific indicators used presented design issues (ICR para. 17) and two others concerning provisioning of bad loans listed in PAD annex 2 were consolidated under a single heading elsewhere in the PAD (Box 3) -- the ICR uses the latter presentation. Nevertheless, it appears that the two largest credit bureaus now covering the vast majority of debtors and banks have improved their provisioning of bad loans, thus contributing to financial stability. On the other hand mobile banking did not appear to have developed as projected at the time the ICR was written. A more recent publication by CGAP provides indications that such services are now beginning to be provided: This area may be another instance where the full impact of the reforms will be more visible over time
    • The project promoted the establishment of the Financial Stability Council and the publication of the first report on financial stability. A recent IMF report highlights the importance of this area, pointing out both progress to-date as well as areas where further reforms are needed, including reducing market concentration, which is a weakness noted in the ICR for other sectors too;
Objective 4: Promoting public-private partnerships in infrastructure to expand core infrastructure services essential to the productivity of Mexican firms substantial achievement:
    • The prior policy action concerned measures to foster private investment in infrastructure. As explained in the ICR (para. 18) the quantification of impact is hindered by measurement and attribution problems associated with the indicator, which focuses on improved availability of funding for PPPs. Fortunately, the assessment of this reform is helped by recent independent studies. In particular an OECD study issued in 2012 points to improved conditions for private sector participation in water: It appears that the reform of the PPP law enacted in January 2012 (ICR para. 19) and other actions supported by the project have contributed to this finding. A 2012 consultant report presents similarly positive findings on the facilitating role of FONADIN in PPPs, notwithstanding remaining challenges:

5. Efficiency (not applicable to DPLs):

6. Outcome:

The loan supported major reforms aimed at improving the business environment and promoted measures that contribute to financial sector development stability, supply response and improved competitiveness. The project was well aligned with priorities expressed in the Bank strategy and benefitted from sound design, even if M&E indicators had shortcomings. Similarly, by targeting important reform areas the project is associated with important results such as improved internet access, more competitive and transparent procurement, increased financial sector stability and a more conducive environment for PPPs. Only one policy area, aimed at reducing the cost of doing business, felt short of achieving its objectives, except for reducing the time required to comply with tax obligations -- this was due to delays in implementation that have been and/or are being addressed. While the DPL was stand-alone, it was part of a broader engagement with Mexico which reduces the risk of reversals and/or reforms not being sustained. The satisfactory rating takes into account the above factors.

a. Outcome Rating: Satisfactory

7. Rationale for Risk to Development Outcome Rating:

The PD (paras. 129-135) had identified several broad risks, which provide good coverage of issues, and the ICR (para. 37) briefly describes the status of risks to development outcomes at closing, including macroeconomic, external and domestic factors that failed to materialize: (a) a sharp downturn in the US economy did not happen; and (b) Mexico has benefitted from relatively stable access to financial markets; (c) there was only moderate delay in the implementation of the Single Trade Window; and (d) the PPP framework was enacted in January 2012 (ICR para. 19). The ICR (para. 28) mentions that future legislative approval may remain difficult. Therefore sustaining and deepening reforms that require further legislative actions may suffer from setbacks. Furthermore, a risk that has not materialized concerns oil prices, which have remained high and production volumes have been maintained at a fairly stable level with an upward trend expected from 2012 onward;; The ICR also mentions an emerging risk, judged manageable, related to uncertainty over the policy stance of the newly elected Government. The track record since then confirms that this risk is unlikely to materialize.

However, some domestic risks materialized and remain significant: (a) security concerns and cost of protection increase cost of doing business and deter new investors; this especially affects Small and Medium Enterprises (SME); and (b) legal injunctions continue to hamper the development of telecoms. Furthermore, uncertainty over European recovery remains a potential risk. Some of these risks and any new ones may be mitigated through the programmatic approach in Bank support mentioned in Section 2(a) above. Furthermore, the ICR notes that modest growth associated with low productivity gain (paras. 1 and 3) has affected Mexico since the mid-1990s. It is unclear whether dissatisfaction with the status quo would provide the impetus for deeper reforms, or on the contrary political and other considerations slow down the process further.

The PD did not provide an overall initial risk rating for the operation, which the ICR rates as Moderate. The ICR’s analysis appears to cover most of the risks. However, should the remaining risks materialize the rating may prove optimistic. Nevertheless, in the absence of compelling evidence to the contrary, the review herein also rates risks to development outcome at the upper range of moderate .

a. Risk to Development Outcome Rating: Moderate

8. Assessment of Bank Performance:

a. Quality at entry:

The project was based on sound analytical underpinnings (PD paras. 48-53), its design was relatively complex and ambitious yet achievable, and implementation was reinforced by other Bank activities that contributed to the overall program. The DPL design was responsive to client needs. Risks were adequately identified and mitigated. A weak point concerned M&E and unclear institutional responsibility for collecting and reporting data, which affected the assessment of certain aspects of project impact. The support provided to Mexico’s budget also enabled the country to continue to give priorities to medium- to long-term issues. This analysis is consistent with the ICR’s (para. 38) as is the satisfactory rating for quality at entry.

Quality-at-Entry Rating: Satisfactory

b. Quality of supervision:

Two implementation status reports were filed for this project – the last in August 2011. There was no field supervision, except for the ICR mission that took place in 2012 after project closing. The TTL for the project changed in 2011. The ICR (para. 39) highlights the following aspects of Bank supervision: (a) deficiencies in the monitoring system were not addressed even though some indicators needed to be improved and implementation arrangements were not in place; (b) there was no mid-term review (MTR); (c) adequate documentation was available to prepare the ICR. The reference to the MTR is a mistake as it was not contemplated in project design -- but somehow introduced in ISRs. The ICR does not discuss how the policy dialogue on project objectives was sustained with counterparts during implementation, but indicates that such a dialogue is ongoing.

The reforms supported by the project were all encompassed by prior action and there was no specific need for extensive supervision within the narrow confines of the project. Nevertheless, a field visit may have helped resolve the institutional issues that affected M&E and delayed effectiveness, and would have supported a deeper policy dialogue. For these reasons, in line with the ICR, supervision rating is moderately satisfactory.

The satisfactory rating for Bank performance takes into account the above ratings as well as the satisfactory project outcome.

Quality of Supervision Rating: Moderately Satisfactory

Overall Bank Performance Rating: Satisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

Government commitment to the program was reflected in the 10-point reform plan. Furthermore, there are indications that the newly elected Government will sustain the reforms initiated under the DPO. The high level ownership is reflected in the satisfactory rating for Government performance, even though there was a delayed in effectiveness. The ICR (Footnote 25) indicates this was due to the need to find a suitable execution agency. However, supervision documents suggest that an alternative/additional reason was the need for Mexico not to exceed a certain debt ceiling set for 2011 -- an issue that was eventually resolved.

Government Performance Rating: Satisfactory

b. Implementing Agency Performance:

The primary implementing agency was the Ministry of Finance and Public Credit, which coordinated with 11 other agencies. In a few areas where progress was relatively limited, counterparts have continued to deepen actions supported by the DPO (ICR para. 42). A problem encountered during implementation was unclear responsibility for M&E, which was eventually overcome. The satisfactory rating reflected current information, which may be revisited in the context of the proposed IEG assessment to reflect continued deepening of the reforms beyond the initial scope of the project.

Implementing Agency Performance Rating: Satisfactory

Overall Borrower Performance Rating: Satisfactory

10. M&E Design, Implementation, & Utilization:

a. M&E Design:

The project’s M&E is integrated in the PD’s Operation Policy Matrix (Annex 2). This matrix lists outcome indicators associated with prior actions, and provides information of pre-2010 actions as well as those (in general terms) foreseen in the medium-term. The presentation excludes complementary reforms that might be part of the broader program being supported by the operation. The relevance of such as a presentation is heightened by the fact that this operation was part of broader engagement by the Bank on competitiveness issues (ICR Box 1) and it would have been useful to visualize activities that contribute to or complement expected outcome. The M&E included a baseline (typically for 2010) and targets (2011).

Nevertheless, as candidly stated in the ICR (Para. 23) not all the indicators were relevant to measure program impact either because they were misaligned with the actions or because targets were too modest. Another issue was that the one year project implementation was insufficient to observe certain changes. Finally, the M&E design called for a monitoring mechanism with responsibilities devolved to agencies (PD para. 48, 4th bullet) that were not fully aware of it (ICR para. 24).

b. M&E Implementation:

M&E implementation was affected by the above-mentioned design issues with two indicators (Financial sector and PPP, ICR paras.17-18) as well as unclear institutional responsibility for collecting and providing the necessary information.

a. M&E Utilization:

A combination of short implementation period and agencies that were not collecting information on indicators meant that M&E utilization was mainly to compile the information at closing needed by the Bank, in preparation of the ICR – one indicator (6, ICR Table 1)) could not be measured. The ICR does not mention any other utilization of the information or the existence of another M&E system used by stakeholders to monitor progress attributable to reforms.

Imperfections in indicators and lack of readiness of institutions to fulfill their M&E responsibilities are well documented in the ICR, which does not rate this aspect of the project. On the basis of information provided, the rating for M&E is modest.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:

The PD (para, 108) indicates that policies supported by the operation would have a negligible effect on the environment. It further goes on to mention that indirect effects, notably from PPPs and other investments (paras. 118-120), would be adequately addressed and mitigated by national environmental policies.

b. Fiduciary Compliance:

The DPL did not include any specific action in the area of Public Financial Management (PFM). This was based on the assessment of the borrower‘s PFM which had concluded that the fiduciary arrangements for this financing are adequate. There is not any indication from public sources that a Public Expenditure Financial Assessment (PEFA) has been conducted recently on Mexico to further elaborate on this conclusion. The loan contributed to improvements in Mexico's national procurement system.

c. Unintended Impacts (positive or negative):

d. Other:
The ICR (section 3.4) identifies two contributions by the project and provides pertinent information on both: (1) social development impact is likely to be noticeable (para. 34), especially for SMEs and through improved financial inclusion; (2) the operation supported improvements in the country’s capacity and institutions (para. 35).

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Risk to Development Outcome:
Bank Performance:
Borrower Performance:
Quality of ICR:
- When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:

The lessons listed in the ICR (section 6) are mostly generic: (a) importance of strong country ownership and commitment; (b) critical relevance of prior analytical work; (c) need to incorporate a solid M&E, including well thought through outcome indicators. Broader lessons from the present review are as follows:
    • When legal reforms are not immediately attainable, the reform agenda may be pursued somewhat successfully through regulatory and administrative measures. Resulting outcomes may help eventually overcome vested interest and political reticence against deeper reforms.
    • In some cases, a "horizontal" programmatic approach may be an appropriate way to tackle issues on multiple fronts through analytical work, investment lending and a stand-alone DPL.
    • As stated in the ICR analysis (not under lessons learnt), the full results of a DPL that is not part of a series may not be adequately measured at project closing.

14. Assessment Recommended?

The project, in conjunction with other DPLs, investment lending and advisory services supported the objective of improvement in Mexico’s competitiveness. Taken together they represent a “horizontal” approach towards programmatic support, in contrast to the more usual sequential approach. An important purpose of the Assessment would be to review whether such a complementary packaging resulted in additionally in the form of complementary, more ambitious and mutually reinforcing targets and possibly better outcomes, while avoiding excessive complexity and/or delays associated with the longer horizon of the serial approach. It should be noted that further assessment has already been recommended by IEG for one of the projects (Innovation for Competitiveness; P089865) that were part of this programmatic support. Even though another related project (Economic Policies; P118070) was not recommended for assessment, issues raised under that project's lessons learnt could be part of the proposed follow-up.

15. Comments on Quality of ICR:

The ICR text is clear and concise, and thus highly readable. The document provides a good description of the implementation experience, highlights and explains the key achievements and important issues, and is quite candid in its assessment of shortcomings. Even though the text is brief, it focuses on outcomes and on what matters, its analysis is logical and credible and no major relevant point appears to have been overlooked. thanks to additional explanation provided in extensive footnotes. The ICR thus provides a sound basis for assessing the project. In sum the quality of the analysis is high, and IEG rates the ICR as exemplary, in spite of some minor shortcomings, such as a missing acronym (WEO), some repetition (Box 2) and an erroneous reference to a mid-term review, which was not called for in the PD but entered as a step in ISRs.

a. Quality of ICR Rating: Exemplary

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