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    <description>Operational lapses in certification, agreement compliance, inward processing, investor request processing, and destruction-record maintenance were considered in light of the COVID period and related difficulties. Although the director had not obtained the requisite certification during the inspection period, that explanation was treated as plausible. The surrounding procedural defects, including delays in issuing duplicate certificates, transmission requests, change of address requests, and bank account detail changes, did not justify retaining the full monetary penalty. The penalty was therefore reduced, granting only partial relief.</description>
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