Standard 11: Treasury Controls

the standard firms must implement strong treasury controls this includes multi layer authorization and verification for all fund transfers and cash movements; segregation of duties for cash management functions to prevent fraud; and fraud prevention and detection controls including transaction monitoring firms must maintain diversified banking relationships with regular monitoring of bank creditworthiness and document procedures for cash movements and reconciliation with appropriate approval workflows introduction treasury management in the digital asset sector bridges the gap between traditional banking and crypto native infrastructure maintaining stable banking relationships remains a significant hurdle, as many financial institutions continue to avoid the sector due to perceived risk while stablecoins offer a critical alternative for managing cash within the crypto ecosystem, they introduce their own set of counterparty risks that require constant oversight the 2023 failures of silvergate bank and signature bank underscored the danger of banking concentration firms reliant on a single institution risked losing all "on ramp" and "off ramp" capabilities overnight similarly, the 2022 collapse of terrausd demonstrated that stablecoins are not created equal; algorithmic versions lacking 1 1 reserves pose vastly higher risks than those backed by liquid, high quality assets standard 11 mandates robust treasury practices designed for resilience this involves diversifying banking relationships across multiple jurisdictions to prevent a single point of failure and conducting rigorous due diligence on any provider facilitating the movement of fiat currency it also requires a proactive assessment of stablecoin risk, focusing on the transparency of reserve backing and the reliability of redemption mechanisms firms must implement strict internal treasury controls, including the mandatory segregation of duties and dual authorization for every transaction, ensuring that no single individual can unilaterally move capital effective treasury management operates on the assumption that disruptions in banking or stablecoin stability are inevitable to meet this standard, firms must diversify their relationships before a crisis occurs, rather than reacting to one resilience is built through daily account reconciliation, continuous evaluation of stablecoin reserve attestations, and the maintenance of a "liquidity ladder" that ensures immediate access to operating capital while diversification may increase operational complexity and overhead, it is a necessary safeguard against the catastrophic risk of being "de banked" or holding impaired stablecoin assets 11 1 banking relationships stable and reliable banking relationships are the lifeline of a digital asset firm’s "fiat" operations however, traditional banks often remain hesitant to engage with the sector due to regulatory shifts and reputational concerns this scarcity of services makes diversification difficult yet essential; relying on a single institution creates a critical point of failure where a sudden "de banking" event can paralyze a firm's ability to pay expenses or fulfill investor redemptions investment managers must proactively build a network of multiple banking partners across varied jurisdictions to ensure operational continuity 11 1 1 bank selection and due diligence a formal process for selecting and monitoring banking partners is required to mitigate counterparty risk following the digital asset banking act of 2026, institutions must be evaluated on their ability to maintain full reserves and their commitment to transparency critical assessment areas industry expertise verify the bank's track record with digital asset firms they must demonstrate a capacity for high volume, rapid settlements and an understanding of on chain/off chain reconciliation financial & capital standing review regulatory capital ratios and financial stability under current standards, firms should prioritize banks that maintain a common equity tier 1 (cet1) ratio well above the regulatory minimum, typically targeting levels above 14% to ensure a buffer against market volatility regulatory status & compliance confirm the bank’s charter (federal vs state) and fdic insurance status assess the strength of their bsa/aml program specifically regarding digital asset "on ramps," ensuring they utilize modern blockchain intelligence tools for transaction monitoring relationship stability investigate the bank's history of "off boarding" crypto clients managers should evaluate the bank’s board level commitment to the sector to avoid sudden service terminations technology & api integration evaluate the bank's technological maturity institutional grade partners should provide api access for automated reconciliations and support international payment rails (e g , swift, fednow) with competitive cut off times 11 1 2 diversification of banking relationships firms must diversify their banking footprint to avoid over reliance on any single provider or regulatory jurisdiction multi bank requirements maintain active relationships with at least 2–3 institutions simultaneously these accounts should be "warm," meaning they process regular transaction flows rather than sitting dormant, to ensure the relationship remains active and familiar to the bank’s compliance team target balance allocation primary bank 40–50% of cash holdings secondary bank 30–40% of cash holdings tertiary bank 10–20% (serving as a ready to use backup) operational readiness testing conduct monthly test transactions (wire, ach) across all banking partners to verify system uptime and compliance workflows contingency & exit planning maintain documented "break the glass" procedures for rapid fund migration if a primary bank fails or issues an exit notice this includes pre vetted alternative providers and pre authorized communication templates for investors and service providers takeaway message banking concentration creates operational risk that may not be apparent until crisis the 2023 failures of crypto focused banks left firms with concentrated banking relationships unable to access funds or execute transactions—in some cases creating existential challenges cash diversification across banking partners provides resilience that single bank relationships cannot best practice is maintaining relationships with multiple banking partners and distributing operating cash to avoid excessive concentration for each banking relationship, understand contingency options if that relationship terminates firms that survived the 2023 banking disruptions generally had diversified relationships enabling rapid transition when problems emerged 11 2 fiat on ramps and off ramps fiat on ramps and off ramps serve as the critical "digital plumbing" connecting the traditional financial system to the cryptocurrency market these gateways facilitate the conversion of government issued currency into digital assets and vice versa in today's market, these services are provided by a diverse array of entities—including centralized exchanges, otc desks, stablecoin issuers, and specialized payment processors—each with distinct regulatory profiles, cost structures, and settlement risks for institutional managers, selecting the right mix of providers is a strategic decision that directly impacts portfolio liquidity and operational cost 11 2 1 on ramp and off ramp providers institutional conversion requires bridging legacy banking rails (like swift, fednow, or sepa) with high throughput blockchain networks managers must evaluate providers based on transaction speed, liquidity depth, and total cost of ownership (tco) centralized exchanges (cexs) these are the most common entry points, offering familiar deposit/withdrawal interfaces while they provide high convenience, they create custodial risk during the "holding" period and processing times can range from instant for wires to several days for ach otc (over the counter) desks best suited for high volume conversions (typically $100k+) otc desks provide relationship based service with reduced price slippage and the ability to lock in rates before final settlement stablecoin issuers direct "mint and redeem" relationships with regulated issuers (e g , circle) eliminate the exchange intermediary this is often the preferred route for large treasury movements, as it leverages the genius act framework for 1 1 asset redemption prime brokers integrated providers that offer fiat services alongside custody and execution while fees may be higher, prime brokers reduce operational complexity by consolidating counterparty count into a single relationship traditional brokerages established firms that have integrated digital asset access these are useful for managers who prefer working within familiar regulatory structures, though they may offer a more limited selection of tokens 11 2 2 due diligence and monitoring due to the heightened fraud risk and regulatory scrutiny associated with fiat crypto movement, due diligence for ramp providers must be exhaustive failures in this area can lead to "liquidity bottlenecks," compliance violations, or even the loss of underlying banking rails key due diligence criteria regulatory status verify that the provider holds necessary money transmitter licenses (mtl) or is registered as a virtual asset service provider (vasp) under current standards (like the clarity act), providers must show clear evidence of federal and state level compliance compliance infrastructure evaluate the provider's aml/kyc program this includes their ability to comply with the travel rule, which requires sharing originator and beneficiary information for transfers above certain thresholds security & fraud controls assess their transaction monitoring tools and internal "four eyes" approval processes look for institutional grade certifications such as soc 2 type ii operational reliability review documented uptime statistics and historical settlement performance the provider must demonstrate the ability to process transactions predictably, even during periods of extreme market volatility ongoing monitoring monitoring does not end at onboarding managers must continuously track provider health, looking for "red flags" such as sudden changes in withdrawal timeframes, regulatory enforcement actions, or shifts in the provider's banking partners takeaway message many investment managers focus only on the fees charged by on ramp and off ramp providers, but they often overlook hidden risks a provider offering low fees might have weak compliance programs, which can lead to regulatory issues and disrupt operations similarly, a provider with limited operational capacity may struggle during periods of high transaction volume to manage these risks, investors should request a comprehensive list of providers along with due diligence documents, details of transaction volumes to ensure diversification, and assessments of compliance and operational capabilities they should also review procedures for handling provider disruptions during due diligence, a key question to ask is 'what happens if your main on ramp provider becomes unavailable? how quickly can you switch to an alternative?' if a provider cannot demonstrate backup options or shows long transition times, it indicates potential operational vulnerabilities 11 3 stablecoin management stablecoins are digital assets that aim to keep their value stable by being linked to traditional currencies like the us dollar they are important for financial markets because they allow quick transactions, operate around the clock, and help manage cash in the crypto space however, different stablecoins have different structures, which means they carry different levels of risk for example, terrausd's failure showed that stablecoins without reserves, called algorithmic stablecoins, are very different from those backed by real assets it is important for investment managers to carefully evaluate stablecoins to understand their risks and make informed decisions about their use in financial strategies table 1 stablecoin types true 181,480 left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type 11 3 1 stablecoin due diligence a thorough evaluation of a stablecoin must move beyond its "market peg" to analyze the underlying mechanics of its stability and the legal rights of the holder reserve assets analyze the composition of the backing priority should be given to issuers holding 1 1 reserves in cash and u s treasury bills evaluate the liquidity of these assets and verify if they are held in segregated, bankruptcy remote accounts review the frequency and quality of independent attestations or audits (ideally monthly or real time) to ensure reserves consistently match circulating supply redemption mechanism a stablecoin is only as good as the ability to exit determine who is eligible to redeem (e g , all holders vs only "authorized participants") and the typical timeframe for processing fiat payouts review historical performance during market stress to see if the issuer maintained a 1 1 redemption rate when liquidity was thin regulatory status verify the issuer’s licenses (e g , nydfs bitlicense or trust charter) regulatory oversight ensures minimum capital requirements and consumer protections review the terms of service to clarify whether holders have a direct legal claim on the underlying reserves issuer financial condition assess the issuer’s business model and capitalization a stable issuer should have diversified revenue sources and reputable institutional shareholders, reducing the risk of a "run" caused by the issuer's own insolvency technology and security for blockchain based assets, review smart contract audits from reputable firms evaluate the "mint and burn" controls to ensure no single party can unilaterally inflate the supply, and check the historical reliability of the protocol during high volume periods 11 3 2 stablecoin exposure limits to mitigate the risk of a stablecoin "de pegging" event, firms must implement and enforce clear concentration limits individual stablecoin limits maximum exposure to a single asset should be capped based on its risk tier tier 1 (fiat backed) well established, regulated stablecoins (e g , usdc) may have limits up to 30–40% of nav tier 2 (emerging/collateralized) newer or crypto collateralized assets should be limited to 5–10% prohibited assets algorithmic stablecoins without 1 1 liquid reserve backing should generally be avoided for institutional treasuries aggregate stablecoin limits define a total cap for all stablecoin holdings combined to prevent an over concentration in "synthetic" cash versus actual fiat banking balances this forces a balance between operational speed and capital safety dynamic adjustment limits are not static the operations team must review these caps monthly or immediately upon news of reserve discrepancies, regulatory actions, or redemption delays any decision to reduce a limit must be documented and executed across the entire portfolio takeaway messge the collapse of terrausd in 2022 highlighted that not all stablecoins are the same algorithmic stablecoins, which do not have real world reserves backing them, behave very differently from fiat backed stablecoins when confidence in an algorithmic stablecoin drops, it can trigger a 'death spiral,' where selling pressure causes the coin to lose its peg faster instead of restoring it investment managers should evaluate stablecoins carefully they should request a clear policy on stablecoin use, detailed documentation for each stablecoin they hold, current exposure levels with limits, and procedures for ongoing risk monitoring during due diligence, a key question to ask is "how do you assess each stablecoin's risk? what makes them different? how would you handle a situation where a stablecoin starts losing its peg?" providing generic answers that treat all stablecoins the same indicates a lack of understanding of their different risk profiles proper assessment and understanding are essential for managing digital assets effectively 11 4 cash controls and treasury operations strong internal controls are essential for mitigating cash management risks these controls are designed to prevent fraud, eliminate operational errors, and block unauthorized transactions while maintaining the velocity required for digital asset markets the effectiveness of these controls depends on genuine independence; nominal controls—where one person effectively manages multiple stages of a transaction—provide only a false sense of security 11 4 1 segregation of duties clear segregation of duties in cash management prevents single individual from controlling entire transaction cycle key segregations include initiation vs approval the individual initiating a wire transfer, ach movement, or stablecoin "burn/mint" instruction must be distinct from the individual approving it the initiator must document the business purpose and verified destination, while the approver independently validates the legitimacy of the request custody vs authorization personnel with direct access to banking portals or cryptographic keys must not have the authority to unilaterally authorize transactions in high stakes environments, access rights—rather than just job titles—should define authority, with oversight teams defining the policy engines and thresholds that the execution teams must follow reconciliation independence to prevent the masking of unauthorized activity, the individual performing reconciliations must be independent of both the initiation and approval functions any discrepancies or "breaks" must be escalated directly to senior management or the risk committee 11 4 2 dual authorization all outbound cash movements require approval of at least two authorized individuals authorization requirements should include authorization thresholds while a minimum of two signers is required for all movements, higher value transactions should trigger additional layers of scrutiny for example standard movements 2 of 3 authorized signers material thresholds (e g , >$1m) requires 3 of 5 signers, including a c level executive (cfo or ceo) genuine independence to prevent collusion, signers should not have direct reporting relationships (e g , a junior staff member should not be the sole approver for their direct supervisor's transaction) address whitelisting approvers must verify that the destination address or bank account is on a pre approved "whitelist " any transfer to a new address must undergo a separate, higher intensity verification process before the transaction can be initiated immutable audit trail all steps—from request to final execution—must be logged in an immutable system (often a soc 1/soc 2 audited environment) capturing the identity, timestamp, and rationale for each approval 11 4 3 reconciliation daily reconciliation is the "early warning system" for treasury operations waiting for month end reconciliation allows errors to propagate and makes identifying the root cause of on chain anomalies nearly impossible three way reconciliation institutional best practice requires a "three way tie out" comparing internal ledgers the firm’s proprietary records of expected balances on chain data real time blockchain balances for stablecoins and tokenized deposits bank/custodian statements official third party records bank reconciliation compare internal cash records with bank statements daily all variances must be investigated and resolved immediately, with outstanding items tracked until clearance stablecoin verification for blockchain native assets, internal balances must be reconciled against live blockchain data every 24 hours any "unexpected" transactions on chain—even if they result in an increase in funds—must be investigated as potential control failures or security breaches administrator tie out internal cash positions should be reconciled with the fund administrator's records daily to ensure the accuracy of the net asset value (nav) calculation takeaway message payment controls require segregation between initiation and approval—no single individual should be able to complete a payment unilaterally this fundamental control prevents both fraud and error, ensuring every material payment receives independent review before execution best practice is implementing payment workflows with separate initiation and approval steps, enforced through system controls where possible approval authority limits should be documented, with higher value payments requiring additional authorization periodic review of payment activity against expected patterns can identify anomalies warranting investigation 11 5 banking relationship management managing banking relationships for digital asset firms requires a proactive, partnership oriented approach banks are under continuous pressure from regulators to scrutinize crypto linked entities, even those with impeccable compliance records as an investment manager, your objective is to demonstrate that your firm is a high transparency, low risk client that strengthens—rather than compromises—the bank’s own safety and soundness profile this requires a shift from viewing the bank as a mere service provider to treating it as a key stakeholder in your risk management framework 11 5 1 banking relationships the primary challenge in these relationships is an information imbalance banks often lack a granular understanding of the specific technological controls and multi layered compliance systems used by institutional digital asset managers to address this, your framework should focus on educating banking partners about digital assets, offering clear transparency to build trust, and showing that your operations meet high institutional standards it is also important to have backup plans in case your efforts to educate do not succeed, ensuring continuous support and reassurance for your banking relationships table 2 banking relationship lifecycle true 154,168 65927419354838,168 65927419354838,169 68145161290323 left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type takeaway message effective relationship management is a cornerstone of successful fiduciary practices, especially within the realm of digital asset management it helps your firm distinguish itself as a trustworthy and reliable client in a highly competitive industry where trust and transparency are paramount consistent and clear communication demonstrates professionalism and fosters confidence among your partners and clients regular updates, such as quarterly reports, are essential for keeping relationship managers well informed about your firm's activities, growth trajectory, and strategic initiatives educating your relationship managers and relevant stakeholders about transaction patterns is equally important understanding the typical transaction behaviors associated with digital assets—such as large international transfers, frequent transactions, and specific transfer patterns—helps banks and financial institutions comprehend your business needs this knowledge reduces the likelihood of suspicion or unnecessary scrutiny, facilitating smoother operational processes 11 5 2 banking contingency planning banking termination in the digital asset sector is rarely an isolated event; it often stems from broader regulatory shifts or internal bank policy changes a systematic response prevents operational paralysis and preserves the firm’s ability to fulfill its fiduciary obligations early detection is critical, as warning signs often precede formal termination notices by weeks, providing a window for proactive preparation termination warning indicators firms must train treasury and compliance staff to recognize "soft" signals that a relationship is deteriorating enhanced due diligence (edd) escalation requests for information that go beyond standard annual reviews, particularly those focused on downstream customer activity or specific blockchain transaction types transaction friction a measurable increase in the frequency of "flagged" wires, manual documentation requests for routine ach movements, or unexplained processing delays service degradation slower response times from the institutional desk, limited access to new features (e g , api keys), or the sudden removal of previously approved payment rails personnel shifts changes in relationship management, particularly a move to less experienced staff or a "generalist" desk that lacks digital asset expertise policy "clarification" new internal bank circulars or updated terms of service that restrict "high risk" activities or specifically cite new interpretations of the digital asset banking act of 2026 as a reason for service limitations termination response protocol when a formal termination notice arrives—typically providing a 30 to 60 day window, though sometimes requiring immediate closure—the following protocol should be activated professional acknowledgment respond to the notice without emotional or legal confrontation maintaining a professional tone preserves the possibility of negotiating a timeline extension for orderly fund migration immediate backup activation activate the "warm" secondary and tertiary accounts established direct all new incoming wires to these alternative venues immediately stakeholder notification inform the fund administrator, legal counsel, and the board manage investor communication carefully, framing the transition as an execution of the firm's documented contingency plan rather than an emergency fund liquidation & transfer prioritize the movement of large fiat balances and stablecoin reserve holdings ensure all funds are wired to the new banking partners with confirmed receipt well before the deadline to prevent assets from being frozen in a "suspense account" during the closure process operational updates update all direct debit instructions, management fee accrual accounts, and payroll systems to ensure no service provider payments fail during the transition counterparty alignment notify key otc desks and exchanges of the change in "settlement instructions" to ensure trading activity remains uninterrupted transition execution & audit to ensure a "clean break" and prevent future operational or regulatory issues statement preservation download and secure the complete transaction history and all audited statements these are essential for upcoming year end audits and tax filings closure confirmation obtain a formal "account closure letter" from the bank to document that the relationship ended in good standing and that all client obligations were satisfied process review following the transition, the treasury committee should conduct a "post mortem" to identify the root cause of the termination and update the bank selection criteria to avoid similar risks in the future allocator due diligence considerations institutional allocators evaluate cash management through banking diversification, stablecoin risk assessment, and treasury control rigor inability to demonstrate multiple banking relationships, produce stablecoin due diligence, or explain dual authorization procedures reveals inadequate cash management controls banking relationships and diversification who are your banking partners and what is your process for selecting and monitoring them? how many active banking relationships do you currently maintain? single banking relationships create existential vulnerability describe any past banking relationship terminations and your response how you handled disruptions reveals crisis management capability how do you manage banking concentration risk operationally? what specific contingency plans exist for banking disruptions? how do you manage exposure to fiat on ramps and off ramps? provide list of providers and due diligence documentation stablecoin risk management what is your policy on stablecoins and what is your current exposure to each? firms treating all stablecoins as equivalent ignore material counterparty risk differences walk through your stablecoin due diligence—what analysis of reserve backing, redemption mechanisms, and issuer financial condition supports usage decisions? what ongoing monitoring occurs for stablecoin risks? static assessments without continuous monitoring miss emerging threats what exposure limits apply to each stablecoin based on risk assessment? treasury controls and authorization walk through your cash management controls including segregation of duties and authorization requirements what is your process for authorizing wire transfers and cash movements? single person authorization indicates inadequate fraud prevention who can initiate, approve, and execute cash movements? lack of genuine segregation creates fraud vulnerability provide sample bank account reconciliations demonstrating daily reconciliation discipline how quickly are reconciliation breaks investigated and resolved? delayed investigation allows errors to compound fraud prevention and detection what fraud awareness training do you conduct and how frequently? untrained staff represent primary fraud vulnerability describe specific fraud attempts you have successfully prevented inability to cite examples suggests either perfect security (unlikely) or undetected attempts how do you detect transaction anomalies systematically? manual review without automated detection misses sophisticated fraud what red flags trigger enhanced scrutiny and investigation? show your documented incident response plan and testing results untested plans fail during actual fraud events documentary evidence requirements cash management policy with control procedures and authorization matrices list of all banking partners and on ramp/off ramp providers with due diligence files stablecoin policy and current exposure report by stablecoin with risk ratings stablecoin due diligence documentation including reserve analysis and ongoing monitoring sample bank reconciliations demonstrating daily discipline with break resolution tracking wire transfer authorization logs showing dual approval and segregation of duties fraud prevention training records and incident response testing documentation banking relationship contingency plans with testing results common pitfalls and remediation banking concentrated with single provider all operating cash and investor flows through one bank—creating existential risk if that relationship terminates or bank fails the 2023 failures of silvergate and signature left firms with concentrated banking unable to operate remediation maintain relationships with at least two banking partners, with operating cash distributed to avoid single bank dependency exceeding 50% test backup relationships periodically—a backup you've never wired to may not work when needed urgently stablecoins treated as equivalent to cash all stablecoins used interchangeably without assessing reserve composition, attestation quality, redemption reliability, or regulatory status material differences in risk profile ignored for operational convenience remediation conduct due diligence on each stablecoin used reserve composition and verification, attestation frequency and auditor quality, redemption track record, and regulatory standing set exposure limits reflecting risk assessment avoid algorithmic stablecoins or those lacking credible reserve verification dual authorization is nominal two signatures required but both approvers report to the same person, or one routinely defers to the other, or ceo can override when convenient the control exists in procedure but not in practice remediation ensure genuine independence approvers with separate reporting lines and no ability for one to pressure the other eliminate override authority entirely—no exceptions for urgency or seniority test periodically that system controls actually enforce dual authorization reconciliation delayed or incomplete cash and stablecoin balances reconciled weekly or monthly rather than daily breaks accumulate undetected, errors persist, and fraud risk increases with each day of delay remediation reconcile all cash and stablecoin positions daily against independent sources investigate variances immediately—not flagged for later review assign reconciliation to operations or finance function independent from those initiating transactions no contingency for banking or stablecoin disruption assumption that current banking and stablecoin arrangements will remain available when disruption occurs, scrambling for alternatives under time pressure while operations are impaired remediation document contingency procedures for banking disruption (primary bank fails or terminates relationship) and stablecoin stress (depeg, redemption halt, regulatory action) identify specific alternatives and required transition steps test annually that contingency paths remain viable fiat on/off ramp providers inadequately diligenced conversion providers selected for speed and cost without assessing licensing, compliance programs, security controls, or operational reliability provider failure or regulatory action disrupts fund operations remediation conduct due diligence on all on/off ramp providers covering regulatory licenses and compliance status, aml program adequacy, security practices, and operational track record diversify across providers to avoid single source dependency for fiat conversion segregation of duties documented but not enforced policy requires separation between transaction initiation and approval, but system access or informal practices allow individuals to perform both functions control exists on paper only remediation verify segregation through control testing—attempt transactions that should be blocked and confirm they are enforce role based system permissions that technically prevent circumvention audit access logs for patterns suggesting control bypass cash control procedures undocumented or unclear treasury operations rely on institutional knowledge rather than written procedures approval authorities undefined, escalation paths unclear, responsibilities assumed rather than assigned remediation document treasury procedures covering approval authorities by transaction type and amount, segregation requirements, reconciliation responsibilities, and escalation procedures review annually and update when personnel or systems change ensure documentation enables continuity if key personnel are unavailable treasury operations lack independent oversight treasury function operates without periodic review by compliance, risk, or internal audit control weaknesses persist undetected because no one outside treasury examines the operation remediation implement periodic treasury review—quarterly by risk or finance function, annually by internal audit or external party assess control design and operating effectiveness track findings to remediation with defined timelines and accountability key controls & documentation true 165,203,146 05740181268882,146 94259818731118 left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content type left unhandled content 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