Finance companies and institutions: strategy

Portfolio Reporting for Financial Institutions: Origination, Risk and Cash

Learn to interpret portfolio reports, compare origination channels, and assess credit risk, costs, cash flow, settlement and reconciliation in Brazil.

Close-up of Bank of California with classic architecture and columns.
What you will find

For an investor assessing a Brazilian lending company or another appropriately authorized institution, monitoring a portfolio requires more than checking the amount financed and the cash collected. The report should explain how transactions originated, which criteria allowed them to proceed, what happened after disbursement, and how much of each receipt represents repayment of principal. A portfolio can grow while its quality deteriorates. It can also collect substantial amounts while producing an inadequate economic result, because most of that cash merely restores the capital originally advanced.

01

A report should explain where the result comes from

The central question is whether the institution can explain its results by contract, customer group, product and origination channel, using records that reconcile. An investor should be able to trace an aggregate balance back to the underlying business proposal. That trail includes who introduced the opportunity, who checked the documents, who made the decision, who released the funds and who monitored collections. A dashboard containing many indicators offers limited investigative value if these connections disappear when a discrepancy arises.

This article presents a method for reading and organizing such reports, particularly when assessing business finance, origination channels and correspondent relationships. Every numerical example is hypothetical arithmetic, rather than a market quotation, observed performance or KEZS transaction. The purpose is to help investors ask verifiable questions about risk, operations and economic results. A management report can support that investigation, but it does not promise approval, repayment, profitability, liquidity or preservation of capital.

02

Define the reporting perimeter before comparing portfolios

A report should first identify exactly what it covers. Assets owned by the institution, assigned credit rights, proposals under review and funds belonging to third parties are different categories. An institution may continue servicing a transferred transaction without retaining its economic exposure. Adding these categories together as though they were all proprietary assets can create apparent growth and count the same credit twice. The report must distinguish ownership, collection responsibilities, retained risk and any contractual repurchase obligations, including circumstances in which exposure could return.

Separate the instruments as well. Loans create contractual repayment obligations. Receivables involve existing rights whose eligibility must be established. Equity provides rights in a company and exposure to its business. Convertible instruments introduce conditions governing a possible conversion. Donations to nonprofit entities provide neither equity ownership nor a promised financial return. These distinctions change what arrears, maturity, distributions and losses mean. Combining incompatible instruments into one delinquency rate obscures their underlying rights rather than producing a useful portfolio measure.

In Brazil's business context, legal form and the purpose of funding also matter. A microentrepreneur registered as MEI cannot admit equity partners while retaining MEI status, so a contribution cannot automatically be treated as immediate equity participation. Expected future sales are also different from receivables that already exist and satisfy eligibility requirements. Request a perimeter map identifying the product, contracting entity, funding source, customer group and rights being monitored. Otherwise, structural differences may be mistaken for differences in performance.

03

Organize information around the project and its evidence

Project-based analysis begins with the business activity that explains the funding need. Buying inventory, financing a delivery and expanding a business location create different cash cycles. Reporting becomes more useful when it connects the contract to its stated purpose, expected repayment sources and evidence examined. This does not establish that the entrepreneur's account is true. It preserves the original hypothesis so that actual developments can be compared with it, including changes that require reassessment.

KEZS connects entrepreneurial projects and potential funders through technology and intermediation. Investors conduct their own due diligence and make their own decisions; KEZS does not assign a credit score. Organizing project information and transparent documentation can help participants formulate questions and compare opportunities, without implying any particular operational feature is available. An orderly document set does not replace an institution's policy, independent document checks or examination of the contractual structure. Its usefulness depends on the evidence it contains and how that evidence is assessed.

Each material assertion should have an identifiable status: a statement by the applicant, a document received, a verification performed or a projection. Expected revenue must remain labeled as an estimate even when presented in a polished chart. Corrections should preserve earlier versions and explain what changed. This allows an investor to distinguish genuine business improvement from revised assumptions. It also prevents later versions from erasing warning signs available when the original decision was made, and makes subsequent reviews more informative.

04

Measure the channel from the first proposal, without equating volume with quality

Origination reporting should cover the entire funnel. Suppose a channel produces 1,200 business contacts: 600 provide the minimum documentation, 300 satisfy initial criteria, 180 receive approval and 100 reach disbursement. Contact-to-disbursement conversion is approximately 8.3%, while approval-to-disbursement conversion is approximately 55.6%. These percentages describe different transitions. One channel may generate strong interest but little usable documentation; another may introduce fewer applicants while requiring less rework. Neither volume alone nor a single conversion percentage explains the channel's contribution.

Comparisons require consistent stage definitions and sufficient time for applicants to progress. Recently approved proposals may still become contracts. Older proposals may have been abandoned because of pricing, repayment terms, delays or product mismatch. Distinguish institutional rejection, customer withdrawal and outstanding documentation. Calling all three lost opportunities makes it difficult to determine whether the remedy belongs in marketing, assessment, the offer or operations. Measure the interval from complete documentation to decision, while also showing the earlier time spent assembling the file.

Cost per disbursed contract is more informative when it includes expenditure on proposals that never become transactions. Compensation based on approved volume can encourage weak applications or approvals unlikely to convert. Compensation payable only on disbursement can also create pressure to close. Report the channel's payment rules, cancellations and adjustments so that incentives and conflicts can be examined. Subsequent repayment cohorts must then pass through their scheduled maturities and collection events before the quality of the originated business can be assessed meaningfully.

05

Separate referrals, correspondent activity and credit decisions

A commercial introduction does not, by itself, determine the legal relationship between the parties. Referring an opportunity, collecting information and acting as a correspondent can involve different responsibilities. In Brazil, correspondent activity depends on the contractual relationship and scope established with the institution. Reports should not describe every commercial partner as a correspondent or imply that using a technology platform automatically grants that status. Identify the contracted entity, covered activities, supervision arrangements and actual limits of authority.

The funder retains the responsibilities assigned to it under applicable regulation. Outsourcing individual steps therefore does not make conduct risk or information quality solely the channel's concern. Useful monitoring includes returned proposals, registration inconsistencies, complaints, identified improper collection practices and procedural departures. Link each event to the activity involved and the person or function responsible for correction. An aggregate incident count without severity or cause cannot distinguish an isolated error from a recurring pattern, and may conceal substantial differences between channels.

Credit policy and approval authority should be visible as verifiable controls. A report can distinguish transactions following ordinary rules from exceptions, and identify which authorized role approved each exception. Commercial approval and credit approval should remain distinguishable, including where the organizational structure permits one person to perform both functions. Investors do not need unrestricted access to decision-makers' personal information. They need evidence that an authorized decision occurred, its rationale was documented, and review was proportionate to the risk accepted.

06

Monitor customer checks and financial crime controls without treating registration as security

Knowing a business customer involves checking identity, representation, business activity and other elements required by institutional policy and the applicable framework. Know-your-customer, or KYC, reporting should show verification progress and material outstanding items while restricting access to sensitive details. Completing registration checks does not demonstrate repayment capacity. A correctly identified company can encounter financial distress, while an economically attractive proposal may need to stop because unresolved inconsistencies prevent the institution from proceeding responsibly.

Useful indicators include transactions blocked by insufficient documentation, overdue reviews, changes in representatives and discrepancies between declared activities and the financial movements presented. Financial crime prevention also requires attention to warning signs during the relationship, according to the institution's obligations. Management reporting should reveal whether alerts receive substantive treatment and whether review backlogs exist, without disclosing protected information or confidential procedures. Closing an alert requires a supported reason; administratively clearing a backlog can reduce the reported count while leaving the underlying concern unresolved.

For investors, appropriate evidence usually combines aggregate indicators, descriptions of controls and authorized independent checks. There is no general need to circulate complete personal documents among everyone interested in the portfolio. Define the purpose, access permissions, retention and security of the information used. If a registration failure emerges after disbursement, show the affected exposure, the assessment performed and the response. Updating the customer record may resolve the immediate data problem, but it does not erase an earlier failure in decision-making or supervision.

07

Build a data dictionary that prevents incompatible numbers

Before discussing trends, establish what each field means. Outstanding principal, total future contractual payments, overdue charges, cash received and recognized revenue are not interchangeable. Reports should state the reporting cutoff, update rules and treatment of write-offs, renegotiations and partial payments. A ratio using principal in its numerator and a balance including charges in its denominator measures something different from a principal-only ratio. Make the formula available alongside a plain-language explanation of the question it is intended to answer.

A useful data structure links identifiers for projects, proposals, contracts, installments, channels and financial events. These links allow an aggregate to be investigated without relying on business names entered in inconsistent ways. They also help reveal several proposals belonging to the same economic group or contracts dependent on the same payer. The dictionary should identify each field's source, update frequency and responsibility for resolving discrepancies. A completed field is not necessarily a validated field, and that distinction should remain visible to report users.

Consistency between reporting periods needs its own control. The closing balance of one period should connect to the next opening balance through explained disbursements, repayments, adjustments and write-offs. Version methodological changes and, where feasible, restate historical figures with a bridge between the old and new bases. An explained discontinuity can be assessed. An apparent improvement caused by an undisclosed denominator change undermines comparison and can support a decision based on a trend that never actually occurred.

08

A complete example of a portfolio and its contractual cash flows

Consider 100 hypothetical business loans, each with principal of R$ 10,000, for total disbursements of R$ 1,000,000. Each loan provides for four principal repayments of R$ 2,500 at 30-day intervals. For this exercise, contractual charges for each interval equal 1% of the principal scheduled to be outstanding at its beginning. The schedule remains fixed, with no capitalization, additional late-payment charges, taxes or other fees. These are simplifying assumptions for comparing reports, rather than a description of market terms or an effective investor return.

Scheduled payments per contract are R$ 2,600 on day 30, R$ 2,575 on day 60, R$ 2,550 on day 90 and R$ 2,525 on day 120. Across the schedule, that is R$ 10,000 in principal and R$ 250 in charges. Portfolio-wide scheduled receipts are R$ 260,000, R$ 257,500, R$ 255,000 and R$ 252,500, totaling R$ 1,025,000. Of that amount, R$ 1,000,000 simply returns the advanced principal. The remaining R$ 25,000 consists of scheduled charges before costs, losses and other economic effects.

At the first payment point, 90 businesses pay in full and ten pay nothing. Receipts total R$ 234,000, comprising R$ 225,000 in principal and R$ 9,000 in charges. At the day-35 reporting cutoff, overdue principal is R$ 25,000 and overdue charges are R$ 1,000. Outstanding principal totals R$ 775,000: R$ 750,000 in future principal repayments plus R$ 25,000 already overdue. The balance reconciles directly: R$ 1,000,000 disbursed minus R$ 225,000 repaid equals R$ 775,000 outstanding.

09

Read arrears at both installment and borrower-exposure level

Continue the example. Six of the ten late-paying businesses pay their first installments on day 45, producing R$ 15,600: R$ 15,000 in principal and R$ 600 in charges. On day 60, the 96 businesses now following the schedule pay their second installments. This produces R$ 247,200, comprising R$ 240,000 in principal and R$ 7,200 in charges. The remaining four businesses pay neither installment. At the day-65 cutoff, cumulative cash receipts are R$ 496,800, including the first collection and the subsequent payments.

Cumulative principal repayments reach R$ 480,000, leaving R$ 520,000 outstanding. Overdue principal is R$ 20,000: R$ 10,000 from the four unpaid first installments and R$ 10,000 from their unpaid second installments. Overdue charges total R$ 700, comprising R$ 400 from the first installments and R$ 300 from the second. Charges received total R$ 16,800. Consequently, the R$ 496,800 in collected cash reconciles to R$ 480,000 in principal plus R$ 16,800 in charges, without treating the entire receipt as income.

Overdue principal represents approximately 3.85% of the R$ 520,000 outstanding. However, each of the four delinquent businesses still owes R$ 10,000 in principal, including future installments. Total exposure to these borrowers is R$ 40,000, approximately 7.69% of the outstanding balance. On day 65, their first installments are 35 days overdue and their second installments five days overdue. A measure counting the whole principal balance of contracts more than 30 days overdue shows R$ 40,000; one counting only overdue principal shows R$ 20,000. Both can inform analysis when their definitions are explicit.

10

Turn the payment schedule into a liquidity assessment

Contractual cash flow is different from actual cash flow. By day 60, scheduled receipts in the example total R$ 517,500, but actual receipts total R$ 496,800. The R$ 20,700 shortfall consists of R$ 20,000 in overdue principal and R$ 700 in overdue charges. There was also an earlier interval, between days 30 and 45, during which R$ 15,600 arrived later than expected. Although eventually collected, that temporary delay could have required additional cash to meet the institution's own obligations.

Liquidity reporting should compare contractual inflows, actual inflows, funds effectively available and committed outflows. Suppose an additional hypothetical obligation of R$ 250,000 falls due on day 35, with no other available funds. The R$ 234,000 collected on day 30 leaves a R$ 16,000 funding gap. Later payments from six businesses cannot retroactively satisfy that need. The institution would require a previously available funding source or another measure permitted by its structure. Its conditions and cost should also appear in the assessment.

This prevents an investor from equating short maturities with guaranteed liquidity. Even short-term credit can create mismatches, especially where payment dates are concentrated or liquidity depends on assigning assets. A possible future asset sale belongs in the assumptions, with its conditions and uncertainty stated. Only funds actually available support the immediate cash position. Reports can compare delayed-payment scenarios and obligations across maturity bands, showing when action would be required and which resources are demonstrably accessible, rather than assuming that a financing opportunity will appear.

11

Explain settlement and reconciliation through to the money's destination

Receiving a payment notification is different from correctly identifying a payment and settling the relevant obligation. Distinguish the instruction received, confirmation from the provider involved, availability of the funds and allocation to a contract. Money can reach an account but remain unidentified; a system can also record a payment before confirmation. Keeping these states separate helps prevent continued collection on an installment already paid or premature discharge based on an unconfirmed receipt. A report should make unresolved states visible rather than treating every notification as settled cash.

Consistent reconciliation compares contractual records, financial movements and accounting entries within the structure used. In the example, the R$ 15,600 received on day 45 must be allocated to six first installments and split into R$ 15,000 in principal and R$ 600 in charges. Automatic allocation to second installments would misstate arrears even though total cash remained correct. Rules for partial payments, early repayments, reversals and unidentified funds should be clear and reflect the relevant contracts. Correct totals alone do not establish correct allocation.

Investors can monitor the amount and age of reconciliation differences, who is handling them and which adjustments were made. A small, persistent discrepancy may reveal a deeper problem than a large difference resolved promptly. Where rights are assigned or third parties participate, also establish who is entitled to each cash flow and when onward transfers occur. Corrections should preserve the original amount, cause, authorization and reporting effect. Changing an aggregate without resolving the source leaves the same error able to reappear at the next close.

12

Compare cohorts, products and concentrations at similar stages of maturity

A recently originated portfolio has had fewer opportunities to become overdue. Comparing a channel that has just begun disbursing with one whose borrowers have passed several payment points therefore favors the newer channel artificially. Cohort reporting groups transactions by their origination period and follows them at comparable ages. For the example loans, performance could be compared at the first and second scheduled payments. The relevant questions become how much each cohort collected against amounts already due, and how its problem exposures developed.

Comparisons should also preserve meaningful differences in borrower cash cycles, collateral and funding purpose. A raw delinquency rate alone cannot fairly compare all such groups. Useful analysis may control for product, term, loan-size band and business segment, without creating subdivisions so small that one event appears to establish a trend. Show both contract count and outstanding balance for each group. A percentage has a different evidential weight when based on two contracts than when drawn from a larger portfolio that has passed through more payment events.

Concentration analysis must extend beyond the number of CNPJs, Brazil's business registration identifiers. Twenty companies may depend on the same purchaser, sales platform or local industry. In the hypothetical portfolio, 20 original contracts represent R$ 200,000. If all relied on one decisive cash source, 20% of initial principal would share that economic dependency. This describes potential concentration, rather than an assumed loss. Reports should explain the evidence supporting the links and track the resulting exposure. Separate registrations do not establish independent sources of repayment.

13

Calculate the economic result after costs and losses

Return to the R$ 25,000 in scheduled charges for the full portfolio. Assume R$ 12,000 in origination costs, R$ 4,000 in verification costs and R$ 3,000 in administration and monitoring over the cycle. Total costs are R$ 19,000, leaving R$ 6,000 before funding costs, taxes, losses and other excluded effects. This is a partial margin within the exercise, rather than an investor's rate of return. It illustrates how R$ 1,000,000 in disbursements can coexist with limited room to absorb additional expense or deterioration.

The timing of expenditure matters too. If the R$ 16,000 in origination and verification costs is paid at the outset, initial operational cash outflow exceeds the principal advanced under the contracts. The remaining R$ 3,000 may be incurred during administration, while charges arrive with borrower payments and are exposed to delay. Separate accrual-based economic reporting from cash reporting so that upfront expenses do not disappear from channel comparisons. Explain allocations of shared staffing and technology expenses, because different allocation methods can materially change the margin attributed to a channel.

For a sensitivity calculation, a definitive R$ 10,000 principal loss reduces the R$ 6,000 partial margin to negative R$ 4,000 before the other excluded items. This calculation retains all R$ 25,000 in charges solely to isolate the principal-loss effect. If some charges are also uncollected, the result is worse. Distinguish arrears, estimated losses and final write-offs, and explain how later recoveries affect the economic assessment. Investors should be able to identify observed amounts, estimates and the assumptions responsible for changes between reports.

14

Use adverse scenarios to support decisions and negotiations

A useful adverse scenario begins with a plausible cause and follows its consequences. If an important purchaser delays payments to financed businesses, those businesses may miss installments despite continuing to sell and deliver. Estimate the exposure dependent on that purchaser, the resulting cash-flow delay and additional monitoring costs. Applying an unexplained percentage reduction to the portfolio balance reveals much less. Distinguish recoverable delay, persistent deterioration and document fraud, since each requires different investigation, responses and recovery assumptions.

The four borrowers still overdue in the example create a concrete decision point. The institution can investigate interrupted receipts, loss of a customer or a structural inability to pay. A renegotiation should appear with its new terms, authorizations and cash-flow effects while preserving the earlier history. Extending maturity may reduce installments while increasing funding and carrying costs. An upfront payment can lower exposure but does not establish that the remainder will be paid. The reporting should support these judgments without removing the original delinquency from view.

Weak channel results may justify reconsidering compensation, required documentation, target customers or referral limits, subject to contracts and applicable rules. A manager may argue for continuing because the cohort remains small, while an investor may seek restraint until more scheduled payments have occurred. Resolve that disagreement using previously defined criteria and additional evidence. Recording the conditions for maintaining, reducing or stopping a strategy makes the decision auditable. It also exposes conflicts when commercial targets create pressure to change risk tolerance without an explicit discussion of the possible costs and losses.

15

Protect evidence and recognize the limits of technology

A reliable report maintains traceability from indicators to supporting documentation, with access proportionate to each participant's role. Contracts, supporting evidence and sensitive business information should not circulate indiscriminately to make a dashboard appear convincing. Investors can receive aggregate information and controlled access to samples or documents relevant to due diligence. The design should permit meaningful investigation while limiting unnecessary exposure of personal information, trade secrets and customer data. Transparency depends on the quality and availability of appropriate evidence, rather than the widest possible distribution of files.

Technology-based records can preserve versions and help detect changes, but record integrity does not establish that the content is true. Recording a reference on a blockchain does not prove that a receivable exists, that its purported holder has valid legal title or that a reserve is solvent. It provides no payment guarantee. Private documents should not be placed on public blockchains. Any recording method should distinguish evidence that a file has remained intact from economic and legal evidence about the transaction described in that file.

The same distinction applies to regulated activity. A professional interface, business registration or CNAE economic activity classification does not authorize financial activities or public distribution of securities. Products and channels require appropriate structures and providers for their actual regulatory classification. Brazil's Central Bank, the CVM securities regulator, Portal do Empreendedor and ANPD data protection authority provide reference entry points for further inquiry. Those references do not prove KEZS or third-party authorization. Investors must examine the specific structure and responsibilities rather than infer compliance from the technology's presentation.

16

Close the cycle with accountable owners, corrections and verifiable decisions

Portfolio closing should bring together functions that see different parts of the same exposure. Origination explains customers and channels; credit addresses assessment and approval authority; compliance monitors relevant controls; operations handles settlement and reconciliation; collections reports contacts and agreements; accounting supports economic records. Governance varies by institution, but each discrepancy needs a defined owner. Investors should know who consolidates reporting and who confirms critical data, without assuming independence between functions that are not actually independent. Accountability also requires knowing who can authorize a correction and follow it through.

An identified error should lead both to correction of the underlying records and assessment of affected decisions. If paid installments were labeled overdue, collection activity, indicators and any relevant customer communications may need correction. If channel compensation relied on duplicated disbursements, revisit the calculation and address the difference. The corrected report should explain which figures changed and why. Reissuing a dashboard without explaining its effects leaves investors holding incompatible versions and may allow the operational cause to remain unresolved.

A practical review can finish with three records: what the evidence establishes, what remains uncertain and what decision follows. In the example, R$ 496,800 collected and R$ 520,000 in outstanding principal are calculable positions. Recovery from the four overdue borrowers remains uncertain. Revising exposure, collection activity or origination depends on an authorized assessment. Connect conclusions to responsible people and review criteria. Reporting then supports verifiable choices with costs and risks visible, while investors retain responsibility for diligence and investment decisions and remain exposed to possible loss.

FAQ

Frequently asked questions.

Which report should an investor request first?

Start with a statement bridging opening and closing balances through disbursements, principal repayments, adjustments and write-offs, accompanied by overdue and future installments. It should identify the reporting perimeter, cutoff and main formulas. Channel, cohort, product and concentration breakdowns can then explain the movements. Beginning with an origination ranking can conceal differences in maturity and cost. If the institution cannot reconcile its balance, the investor lacks a consistent foundation for interpreting the remaining indicators, however polished their presentation.

Does a low delinquency rate show that an origination channel is good?

Not on its own. The channel may have recent transactions, different repayment terms, more renegotiations or different arrears definitions. Compare similarly mature cohorts and consider recoveries, losses, costs and operational incidents. Check whether channels serve materially different customers. Economic contribution depends on the result after these effects, rather than a single headline rate. A low rate in a small sample is an initial observation with limited evidential weight; it may justify continued monitoring without establishing a sound basis for increasing exposure.

What changes in reporting when receivables are assigned?

Identify the rights transferred, who now bears the risk and which obligations remain with the assignor. Monitor eligibility, supporting documentation, payment events and any repurchase conditions under the contractual structure. Existing eligible receivables must remain separate from hoped-for sales. Avoid counting one asset simultaneously as the institution's own portfolio and a third party's portfolio. Continuing to collect payments does not, by itself, establish continued ownership. Reporting must also clarify who is entitled to each receipt and when the servicing entity must pass it on.

How can an investor identify renegotiation that conceals deterioration?

Check whether improved arrears figures reflect actual receipts or merely changed payment schedules. Appropriate reporting preserves history, identifies renegotiated contracts and shows cash paid upfront, revised flows, concessions and subsequent payment failures. Renegotiation may have a sound economic rationale, but it does not erase the earlier risk. If troubled contracts disappear from problem indicators as soon as an agreement is signed, comparability suffers. Request a combined view of the original portfolio and renegotiated terms so that the effects of changed classification remain visible.

Does an investor need every customer document?

Access should serve the analysis and respect applicable restrictions. Aggregate indicators, controlled samples and independent checks can support due diligence without widespread circulation of personal documents. Where a particular document is necessary, establish who may access it, for what purpose and in which environment. Refusing indiscriminate disclosure does not establish a lack of transparency. Equally, data protection should not become a reason to prevent all verification. The objective is sufficient evidence through proportionate, secure arrangements that allow relevant claims to be tested.

How does portfolio monitoring differ from an investment decision?

Monitoring organizes facts, estimates and departures from expectations to inform a decision; it does not automatically establish suitability. Investors must examine contractual rights, structure, costs, conflicts and possible losses, and conduct their own diligence. Carefully monitored portfolios can produce negative results. Strong collections in one period do not ensure continued performance, and reporting does not make an instrument liquid when exit depends on specific conditions. Its value lies in reducing ambiguity and making risks examinable, without guaranteeing returns, repayment or preservation of capital.

How often should reports be reviewed?

Frequency should reflect relevant events and the ability to respond. Settlement issues, reconciliation differences and operational alerts may require attention close to the event, while cohort and profitability analysis require consistent reporting closes. The goal is timely detection and a comparable evidence base, rather than the maximum number of dashboards. An extraordinary review may be needed after a concentration is affected, a documentation failure emerges or payment behavior changes materially. Give each routine an owner, update deadline and rule for escalating exceptions to the appropriate decision-maker.

References and context

Institutional reference points for checking applicable rules and guidance. Calculations and scenarios are original examples, not quotes, historical results or individualized recommendations.

AI-assisted educational content. Decisions require verification of the information, instruments and providers in each actual case.

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