Tag: Discovery

Discovery launches prepaid health cover

By Jamie McKane for MyBroadband

Discovery has launched a new digital prepaid health platform, available via a web portal and WhatsApp.

The company said this offering allows anyone living in South Africa to buy vouchers towards high-quality, primary healthcare services in the private healthcare sector, at highly competitive rates.

The first product available via this platform is a R300 GP consultation voucher, which can be redeemed at any dispensing general practitioner within the Discovery Prepaid Health network.

This voucher includes the medicines dispensed by the doctor after the consultation.

“We are very excited about this platform. Discovery Prepaid Health broadens access to high-quality treatment and medicine for all people in South Africa,” said Discovery Health CEO Dr Ryan Noach.

“Our vision is that buying prepaid vouchers for high-quality private healthcare becomes ubiquitous, akin to buying prepaid airtime for our mobile phones. One of the most compelling features is that there is no limit to the number of vouchers one can buy,” Dr Noach said.

“We have carefully selected the healthcare professionals who are pioneering the Discovery Prepaid Health offering with us, and we’re excited that every person in our country will have the opportunity to consult with them.”

How it works
Discovery Prepaid Health can be accessed by registering a user profile via the Discovery website or on WhatsApp on 080 033 7846.

Discovery clients can also access a link to these platforms through the Discovery corporate app.

Once registered, users can buy, load, and then redeem prepaid healthcare vouchers as follows:

  • Buy a Blu voucher or 1ForYou voucher with cash in-store, at one of 350 000 retail outlets
  • Buy a voucher through the Discovery Prepaid Health web-based app, or the Vitality Active Rewards Mall, using a debit or credit card
  • Load the voucher to their Prepaid Health balance using WhatsApp, www.discovery.co.za or the Discovery Prepaid Health app
  • Redeem: Use their Discovery Prepaid Health balance for any service available on the Discovery Prepaid platform. e.g. a GP and medication

“Disruption in the healthcare market is required to improve access and affordability of private healthcare for all South Africans so that they can choose quality, private primary healthcare when they wish to,” Dr Noach said.

Network of doctors
At launch, the Discovery Prepaid Health network will include doctors in the major metros within eight of the nine provinces and this will continue to be expanded, with new practices being added daily.

“Discovery Health has, over time, built strong private healthcare networks and a deep understanding of the healthcare system,” Dr Noach said.

“Leveraging our data analytics capabilities, we have been able to identify the intersection of optimal, quality healthcare and affordability, ideal for the currently uninsured market.”

Discovery Prepaid Health allows users to buy a voucher and share the link to it within 60 seconds via WhatsApp or the web.

The company said that this product aims to provide quality private healthcare to those who are not members of medical schemes in South Africa.

“In South Africa, whilst only 16% of the population has private medical scheme cover, our research shows that up to 50% of the population chooses to access primary healthcare in the private healthcare sector,” Dr Noach said.


Consumers slate Discovery bank in survey

By Londiwe Buthelezi for Fin24

BrandsEye’s annual SA Banking Sentiment Index reveals that African Bank had the most positive social media mentions this year.
On the other hand, Discovery Bank had the worst.

BrandsEye also found that, in the early days of the lockdown, customer queries on social media spiked by 61%.

The social distance between banks and their customers, created by Covid-19, has left many unhappy as overwhelmed banks fail to keep up with their customers’ frustrations on social media, according to the latest South African Banking Sentiment Index.

The index, compiled by customer experience data provider, BrandsEye, reveals that, during the early phases of the lockdown, more customers used social media to reach out to their banks. It spiked conversation volumes by 61%, while banks’ response rate to customers over the same period fell by 39%.

“With the influx of customers seeking assistance on digital channels, banks struggled to keep up with the demand for support on social media. 47.3% of priority customer conversation (those which require the banks’ attention and action) on social media went unanswered by the banks,” wrote BrandsEye.

Policing banks’ conduct towards their customers

While BrandsEye has compiled the South African Banking Sentiment Index annually since 2015, this year’s index was more than just about determining which bank has the most unhappy customers on social media.

The Financial Sector Conduct Authority (FSCA) used the index to gauge banks’ Banking Conduct Standard, which the regulator launched in July.

The Standard is based on the six Treating Customers Fairly (TCF) outcomes.

In the past, TCF regulations only policed the conduct of insurers as the FSCA’s predecessor, the Financial Services Board, did not regulate banks.

Looking at data that BrandsEye collected from over two million social media posts about South African banks between September 2019 to August 2020, the FSCA’s divisional executive of regulatory policy, Caroline Da Silva, said 90.7% of customer complaints on social media included issues that touched on fair or unfair treatment of customers or TCF compliance themes.

These ranged from complaints about unauthorised debit orders to complicated product structures and misleading advertising.

“Social media is indeed a rich source of conduct-related conversation that banks ought to pay close attention to. As the regulator, we are concerned with the volume of complaints that BrandsEye has identified,” wrote Da Silva in the report.

The FSCA and BrandsEye said the fact that almost half of customer conversations that required the banks’ attention and action went unanswered “should be alarming for the industry” because had banks paid more attention to these, they would have avoided reputational damage and escalation of complaints to the regulator.

But because they are missing out on doing something when these complaints surface, “they risk facing heavy fines from the regulator as well as significant reputational risks that such sanctions would generate”, read the report.

African Bank scores highest and Discovery Bank the lowest

According to the report, Nedbank and African Bank were the two most responsive banks and Discovery Bank the least responsive.

It said Discovery Bank only replied to about one out of every 10 interactions that required its attention and action.

Overall, African Bank received the most positive posts on social media over the period of data collection, followed by Capitec. Discovery had the most negative customer sentiment, scoring the lowest in net sentiment, after FNB.

On the positive side, the net sentiment score for all eight banks included in the report – which include the big four, Capitec, TymeBank, Discovery Bank and African Bank – improved by 0.9% percentage points compared to 2019.

The net sentiment score tallies the percent of positive sentiments on social media posts, minus the percent of negative sentiments.

The sentiment score around all banks’ turnaround time – which is usually the biggest source of social media users’ frustrations – also improved, a phenomenon that BrandsEye attributed to the increased adoption of digital channels by banks as a result of Covid-19.


By Phumi Ramalepe for Business Insider SA

Discovery Health has dismissed 10 employees for being part of a private WhatsApp group that apparently aimed to get its Cape Town offices closed.

The 10 young call centre employees apparently asked to be allowed to work from home around the beginning of lockdown. Three of them said they contracted Covid-19.

Their lawyer says their privacy was violated. Discovery says the evidence it obtained through a whistleblower is grounds for dismissal.

Discovery Health fired 10 call centre employees during lockdown for being part of a WhatsApp group that, apparently, sought to “shut down” local Cape Town offices in March, for fear of the coronavirus.

Now the employees want compensation, and their jobs back, but Discovery says it had solid grounds to dismiss them – even though the chat group was private.

According to Discovery, another employee, who had been an active participant of the group, provided information about posts in the group. The company characterises the conversations as bringing it into disrepute, while, it says, the employees failed to raise their concerns internally.

“Ten employees were plotting to sabotage Discovery Health, including plans to involve external third parties to bring the company into disrepute,” said Ryan Noach, the CEO of Discovery Health.

“The motive appeared to be an attempt to achieve the closure of the local Discovery Health offices, in order not to have to work during the period.”

Although the group chat was private, Discovery insists that the employees were “acting subversively”, based on evidence from the whistleblower.

After investigations were conducted, the employees were dismissed in July.

The employees’ pro bono lawyer, Nkosinathi Malgas, said the employees were dismissed unfairly, and only created the WhatsApp group to support each other after Discovery Health refused to let all of them work from home while three of them contracted Covid-19.

“The contents of the WhatsApp group were them talking about their safety in the workplace, and they were supporting one another in terms of the emotional trauma that they were going through,” said Malgas.

Malgas argues that the employees’ right to privacy was also violated, since information that was meant to be private was used against them.

“Constitutional rights of citizens override any social [media] policy. This information was processed from their personal cellphones and these individuals have got a right to privacy.

“Their information is protected in terms of the Protection of Personal Information Act, and therefore anyone who wants to get into your personal information must do so with your consent as well as a court order,” said Malgas.

It would have been a different story had the employees used Discovery’s tools of trade, according to Malgas, rather than their own cellphones and a chat platform unconnected to the company.

Noach, however, insisted no one’s rights were infringed throughout investigations.

“It should also be entirely clear, that all device information utilised in this disciplinary investigation was submitted voluntarily and without coercion, by a whistleblower who made their personal device available.

“There was certainly no infringement of any personal confidential device information whatsoever,” Noach said.

An arbitration that wasn’t
Discovery and the employees had been due to appear before the Commission for Conciliation, Mediation and Arbitration (CCMA) on Monday, but Discovery did not show up, according to Malgas.

A clause in the employees’ contracts stipulates that any dispute related to labour matters, dismissals or termination of employment will be referred to a private arbitration, Malgas said, which means they will have to pay a potion of the cost of such private arbitration.

Discovery tells a different story, however. It had applied for the CCMA matter to be heard virtually, the company said.

“The Commissioner tasked to deal with the matter was unfortunately unavailable and the file was handed to another. It was unfortunate that technical issues were experienced on the side of the CCMA and we could not engage further,” Noach said.

Discovery warns of 90% profit plunge

Source: EWN

South African insurer Discovery said on Monday its full-year profits could fall by up to 90%, hit by a 3.3-billion rand ($191-million) provision to cover the potential impact on claims and policy lapses due to the coronavirus.

It also said it would not pay an annual dividend, with the payouts to be considered when appropriate, sending its shares down 5.5% before recouping some losses.

The company said the hefty provision covered the potential impact on claims and anticipated policy lapses as stretched customers stop paying, while the outlook also covered the impact of long-term interest rates.

It warned its headline earnings per share – the main profit measure in South Africa – for the year to June 30 were expected to be between 70% and 90% lower than the 789 cents reported a year earlier, though it said the final outcome was subject to a high degree of volatility.

“Discovery is confident that the group is strong under high stress scenarios, with sufficient liquidity and solvency to weather uncertain conditions,” it said, adding capital ratios and cash buffers were expected to remain within or above target.

The provision, Discovery said, was intended so that all of the currently expected impact of the novel coronavirus as far ahead as 2022 was carried in this financial year.

Changes to interest rates in South Africa after the government lost its final investment-grade credit rating earlier this year, and historically low interest rates in the United Kingdom where it has a unit, were expected to have a further substantial impact on performance.

Discovery’s profits have been falling in recent years as it ploughed money back into new businesses including a hefty investment in launching a digital bank, which it said now has 177,000 clients and 2.1 billion rand in retail deposits.

So far, lapses in most of its businesses had been low, it said, while new business annualised premium income was up 4% for the 11 months to May 31.

Source: CNBC Africa

South African insurance company Discovery and mobile operator Vodacom are teaming up to offer a free, online doctor consultation service to all South Africans with coronavirus-related concerns.

Discovery had already set up an online service for its own customers but had put it on ice due to a regulatory hold-up. Now it will be open for anyone.

The R20-million ($1.11-million) cost of the first 100 000 consultations will be split between the two companies. Doctors sign up to the service voluntarily, with more than 5 000 registered so far.

Vodacom will also provide free access to the platform via mobile data, but only with a Vodacom sim card, meaning users will have to already be a customer or sign up to Vodacom to access the service.

Discovery CEO Adrian Gore said there was no financial benefit to the insurer from the partnership, and it would not receive a share in any revenues Vodacom earned from new customers.

He added that sources of funding would have to be explored if the number of consultations went above 100,000.

Gore also told Reuters that the company was modelling the potential impact the coronavirus will have on claims, with its businesses in South Africa and Britain a focus.

“Covid-19 claims are certainly going to go up and we’re modelling that, but the cost of other health events are going down quite dramatically, people are not going for elective surgery, so there’s a bit of a counter balance,” he said.

There was also a much higher risk of mortality claims too, he continued, adding the insurer was “preparing carefully” for this outcome.

Discovery takes aim at controversial NHI bill

After the publication of the NHI Bill on Thursday last week, medical aid behemoth Discovery has released a statement regarding how they will tackle negotiations to keep private medical schemes part of the healthcare landscape.

The controversial Bill could spell the end of medical aids – and Discovery Health alone employs more than 4 000 people.
According to a recent Business Tech article, there are currently 8.9-million South Africans covered by registered medical aid schemes.

The statement from Discovery reads:

The extent of negative sentiment from press, investment markets and other stakeholders has been substantial. Discovery continues to study the Bill and to engage with numerous stakeholders, and their views will evolve over time. In the interim, we feel it is important to share current views with our clients.

The NHI is a huge, complex and multi-decade initiative and a considerable amount of debate and effort will be required to make it workable. Discovery’s overall position on NHI is unequivocal: we are supportive of an NHI that assists in strengthening and improving the healthcare system for all South Africans – little is more important. You will know that we have consistently expressed our support and made our capabilities available for its development. We are committed to assisting where we can in building it, and making it workable and sustainable. Of course, debates about its timing, affordability, execution and more will no doubt be complex.

A central issue that we are close to and upon which we must comment is the future role of private healthcare and medical schemes – what it means for medical schemes to provide “complementary cover ” to the NHI and when this will take effect. Our strong view is that substantially limiting the role of medical schemes would be counterproductive to the NHI because there are simply insufficient resources to meet the needs of all South Africans – this is an unavoidable reality.

Limiting people from purchasing the medical scheme coverage they seek will seriously curtail the healthcare they expect and demand. This will erode sentiment, denude the country of skills and impact the economy. Crucially, by preventing those who can afford it from using their medical scheme cover, and forcing them into the NHI system, this approach will also have the effect of increasing the burden on the NHI and will drain the very resources that must be used for people in most need. This would be detrimental to all South Africans, and would undermine the objectives of the NHI as we understand it.

While this is our strong view, the Bill needs clarification since it makes the point that the “complementary role” for medical schemes will only apply once the NHI is “fully implemented”. It defines “referral pathways” to which it will apply, indicating that where patients choose not to follow the referral pathways, the NHI will not reimburse their care, and that they can then claim from private health insurance. The Bill clearly gives rise to different interpretations – we will engage actively and constructively on this issue to ensure that the important role of medical schemes and private healthcare remains part of the healthcare system, together with the NHI. We provide more technical detail on the role of medical schemes within the proposed NHI below.

Having said this, we remain deeply confident that the resulting environment will be rational and workable. Our plans for Discovery Health and for the Discovery Health Medical Scheme remain the same. If anything, the future will be more complex and the need to invest in capabilities and technology are likely to increase substantially. That is what we plan to do.

Discovery is committed to playing its role in building a positive future – for our members, South Africa’s doctors and healthcare professionals, and for all South Africans.

The role of medical schemes as envisaged in the NHI Bill
The Bill contains only one paragraph (Section 33) referencing the role of medical schemes. This paragraph indicates that “once National Health Insurance has been fully implemented as determined by the Minister through regulations in the Gazette, medical schemes may only offer complementary cover to services not reimbursable by the Fund”.

While it appears as if the intention of the Bill is to prevent schemes from covering services provided by the NHI, we believe that in reality, medical schemes should and will continue to cover all of the healthcare services which they currently cover for the foreseeable future. We believe this to be the case for the following reasons:

– There is no clear definition of services to be covered by the NHI, and it appears that this definition will be expanded on an incremental benefit and geographic basis, with an initial focus only on primary and maternity care and other high priority services for vulnerable populations.

– Even for the limited initial definition of NHI benefits, we expect the actual implementation of universal coverage to be considered and deliberate, as there are extensive financial, legislative and administrative challenges to be overcome, as the Minister and other policy makers have acknowledged.

– There is uncertainty as to when the NHI will be considered “fully implemented”. In our view, given the constraints, it is likely that this point is most likely to be quite far in the future.

– The specific language of the Bill is open to interpretation. The Bill states that medical schemes cannot cover services “reimbursable” by the NHI. At the same time, the Bill clearly states that to obtain reimbursement, patients will have to follow the ‘referral pathway’ dictated to them by the NHI’s contracted providers. If patients decline to follow these referral pathways, their care will not be reimbursable by the NHI. When read together, the Bill appears to accommodate medical schemes being able to fund any services that are not reimbursable by the NHI due to patients choosing not to use NHI pathways. This would ensure that medical schemes are “complementary” and continue to absorb the current costs which they carry.

– We believe that the limitation of the rights of citizens to purchase additional health insurance, even after they have contributed to the NHI, would be globally unprecedented and inappropriate. As noted above, we believe that this approach will actually harm the NHI by draining resources from those most in need.

– In virtually every other country with some form of NHI or equivalent nationally funded healthcare system, citizens are fully entitled to purchase additional private health insurance cover, including cover that overlaps with services covered by the national system. A restriction on choice of medical scheme cover is not dissimilar to limiting the rights of citizens to purchase private education for their children or private security, on the basis that the public system already provides state schooling and security services.

– We will of course engage actively with the policy makers directly, and via the Health Funders Association, and BUSA, with the aim of addressing these specific issues and are optimistic about a positive outcome to these engagements.

The financing of the NHI system
The Bill makes no reference to the likely costs of the NHI once fully implemented but senior Department of Health officials have been quoted as estimating a total cost of approximately R245 billion in 2019 terms. This presumably refers to the incremental cost of the NHI over and above the current R223bn national budget for healthcare. Over 85% of the current budget is allocated to the 9 provinces and funds the current public healthcare system. Any fundamental change that improves quality and access and that is able to contract private providers will therefore require substantial additional funding. We understand that National Treasury will soon be publishing a costing document, and that this is likely to be based on an incremental approach to providing NHI benefits.

In our view, the government faces significant challenges in securing the funding required to implement the envisaged NHI, including the current and likely future fiscal constraints facing government.

The Bill specifies that payroll taxes and a surcharge on personal income tax could be considered as sources. Such taxes would need to be determined by National Treasury. At the presentation of the Bill, the Minister of Health indicated that no tax changes are envisaged over the 3 year period of the current Medium Term Expenditure Framework.

The Bill also refers to a redirection of the current medical scheme tax credit, which would effectively increase personal income tax revenue to the fiscus by approximately R17bn. The Provisional Report of the Health Market Inquiry argued for a restructure of the tax credit to create a greater income cross subsidy. We do not expect an immediate abolition of the medical scheme tax credit, but do expect National Treasury to continue to cap the nominal Rand value of the tax credit each year, as has been the case for the past two years.

Department of Health officials have also suggested that government could fund the NHI by removing the current medical scheme subsidy provided to government employees, which is worth approximately R30bn. This is obviously possible but would be a material change to the employment conditions of public sector employees and their trade unions.

In summary, there are material challenges to raising new revenues to supplement the current government budget for healthcare, and this is unlikely to change in the foreseeable future. This in turn implies that the roll out of the NHI as envisaged will be constrained unless there is a substantial improvement in the country’s economic prospects.

The role of private hospitals and health professionals
The Bill envisages that the NHI Fund will contract on a voluntary basis with private hospitals and professionals and other services to supplement the current public sector delivery system. The NHI Bill provides limited detail on how the procurement of services from private providers will be carried out. The lack of substantial additional funding noted above will constrain the ability of the NHI to procure extensively from private providers. Overall, for the foreseeable future we expect that the NHI will contract with some GPs to supplement its public primary care services, and also that it will contract for certain high priority services to address specific gaps in public sector provision. If this is achieved, it will already be a significant step forward. Beyond that, we expect that the vast majority of NHI services will continue to be delivered by public sector clinics and hospitals, and that private hospitals, specialists and other providers will continue to be funded by medical schemes.

It is our strong view that we have a brilliantly committed, highly skilled and world-class healthcare professional community in South Africa. These professionals work hard, provide excellent care and are committed to our country. We will work hard to defend their rights to fair remuneration, to an optimal working environment that promotes sustainability and ideal patient care, and to retaining and supporting them within our broader healthcare system.

The NHI Bill Process
The NHI Bill will now be tabled in Parliament, implying that a Portfolio Committee process will commence, allowing for public consultation. Discovery will participate actively in the parliamentary process through BUSA and BLSA, as well as the Health Funders Association and on its own account.

It is also expected that there will be a parallel process within NEDLAC, which will create further opportunities for engagement and influence over the final content of the Bill.

It also appears that the Minister intends engaging actively with stakeholders and this will create opportunities to engage on these vital issues. There are good indications that the current Minister is open to the potential for public private partnerships, and we welcome the opportunity to partner in delivering on the vision for a stronger and more accessible healthcare system for all South Africans.

Following the Portfolio Committee process, the Bill will be debated in the National Chamber of Provinces and the National Assembly. We thus do not expect the Bill to be promulgated until early 2020 at the earliest, and are optimistic that we can work with the policy makers to secure a positive result in the final NHI Bill and for the implementation of the NHI itself.

Discovery HQ costs R23m a month

According to a report by Netwerk24, Discovery is paying approximately R280-million a year – or R23-million a month – to rent its new offices in Sandton.

By 2022, Discovery anticipates paying R400-million a year, and R600-million in 2028. After 15 years the building will not be transferred to Discovery, and a new rental agreement has to be drawn up. Growthpoint is the majority shareholder in the building.

Business Insider reports that Discovery has entered into a 15-year rental contract with property group Growthpoint, which developed 1 Discovery Place for more than R3-billion. The building has a roof-top running track and a gymnasium that can accommodate up to 3 000 members.

This comes after Discovery clients were hit with a weighted 9.2% increase across medical plans for 2019. In addition, Discovery Vitality plans were increased by between 8.4% and 12.5%.

According to Business Tech, Discovery has 2.8-million beneficiaries, and with an open medical scheme market share of approximately 56%.

Image credit: Discovery

Total’s oil and gas discovery worth R1trn

By Paul Burkhardt, Bloomberg/Fin24

Total SA said it has opened up a new “world-class” oil and gas province off the coast of South Africa after making a significant gas-condensate discovery there will provide a boost for the economy of R1-trillion over the next 20 years.

Success in the nation’s first deep-water well is a potential boon for a country that imports most of its oil, processing the remainder of its fuels from coal and natural gas.

“We are very pleased to announce the Brulpadda discovery, which was drilled in a challenging deep-water environment,” Kevin McLachlan, senior vice president of exploration at Total, said in a statement on Thursday.

“Total has opened a new world-class gas and oil play and is well-positioned to test several follow-on prospects on the same block.”

Total, the operator, now plans to acquire 3D seismic data before drilling as many as four more exploration wells at the license.

“It’s a catalytic find,” Niall Kramer, chief executive officer of the South African Oil & Gas Alliance, an industry lobby group, said by phone. The country has only drilled in shallow waters before, with little to show for it, he said. “There’s nothing that has been on this kind of scale.”

Exxon, Eni

The new oil and gas region, with estimated volumes of around 1 billion barrels according to consultant Wood Mackenzie, has drawn interest from explorers including Exxon Mobil and Eni SpA, which also hold stakes in the waters.

“It’s probably quite big,” Total CEO Patrick Pouyanne said Thursday on a conference call. “Having said that, the region is quite difficult to operate: huge waves, the weather isn’t very easy.”

Total was drilling about 175 kilometers (109 miles) offshore in the Outeniqua Basin to a final depth of 3 633 meters (11 900 feet). The discovery, which also includes some light oil, could prompt a rush of activity offshore by other companies, especially since South Africa is due to introduce new oil and gas legislation later this year aimed at spurring exploration.

Africa as a whole has seen an increase in drilling, with oil and gas rigs around the continent topping 100 in recent months, according to Baker Hughes data. The count was as low as 77 in 2017.

Total has a 45% working interest in Block 11b/12B, Qatar Petroleum holds 25%, CNR International 20% and Main Street, a South African consortium, 10%.

Meanwhile, Minister of Mineral Resources Gwede Mantashe told delegates on the last day of the 2019 Investing in African Mining Indaba on Thursday that his department’s plan to separate oil and gas from the Mining Charter and develop separate legislation for the extraction method would yield immediate impact.

He lauded Total’s discovery as one of the outcomes.

Discovery launches new ‘tech-led’ bank

Source: Fin24

Discovery has launched its much anticipated bank, hailed as the first in rewarding good financial behaviour.

Speaking at the launch of Discovery Bank at the firm’s headquarters in Johannesburg, CEO Adrian Gore said, “The purpose of the bank is making people healthy in a financial sense”.

“It is a tech-led bank that is aimed at incentivising behavioural change,” said Gore.

He said the bank would be mobile-led and accessed from your phone. It will also be linked to the company’s Vitality Rewards programme.

“Everything is on the face of the app, the functionality is amazing with real time EFT payment to all banks,” he said.

Gore said, however, they would not be disclosing the bank fees as yet.

He said 10% of the bank would be owned by black depositors, adding however that it was not a BEE scheme.

In terms of the interest rates structure, Gore said it would be market-related combined with the client’s vitality status.

Clients would also be able to withdraw cash at any ATM while Gore said there are plans to set up one branch inside the company’s Sandton offices.

He said the bank’s target market was “very broad” – from a high LSM to the lower level.

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