Form FR 3064a FR 3064a Debit Card Issuer Survey

FR 3064a
OMB No. 7100-0344
Approval expires January 31, 2020

DEBIT CARD ISSUER SURVEY

Survey Period:
Calendar Year 2017

1

General Instructions
About this Survey
Section 235.8(b) of the Federal Reserve Board’s Regulation II requires that issuers covered by the
interchange fee standards in Regulation II file reports with the Board. This survey serves as this report.
The survey solicits information from calendar year 2017 regarding (1) volumes and values of debit card
transactions; (2) volumes and values of chargebacks and returns; (3) the costs incurred in connection
with the authorization, clearance, and settlement of debit card transactions; (4) other costs incurred in
connection with particular debit card transactions; (5) costs incurred by debit card issuers to prevent fraud
in debit card transactions; (6) interchange fees charged or received by debit card issuers in connection
with debit card transactions; and (7) the incidence and loss associated with fraudulent debit card
transactions. For purposes of this survey, transactions over three-party systems are not included—see
glossary.
The survey should be filed by the entity that acts as issuer of the debit card involved in the transaction,
where the definition of the issuer is, as specified in Section 235.5(a) of Regulation II for purposes of
determining an issuer’s exemption status, the entity that holds the account that is to be debited. There
may be instances in which an entity provides third-party services (such as processing or program
management) to the issuer. In these cases, the issuer and not the third-party service provider should file
the survey containing information about the issuer’s debit cards and debit card transactions. In order to
file the survey, it may be necessary for the issuer to obtain information from its third-party service
provider, but it is nevertheless the responsibility of the issuer to file the survey. If an entity acts as both
issuer on its own behalf and third-party service provider for other issuers, the entity should only include
data for the debit cards and debit card transactions for which it acts as issuer, but not data for the debit
cards and debit card transactions for which it acts as third-party service provider and another entity acts
as issuer.
In addition, Section 235.8(c) of the Federal Reserve Board’s Regulation II requires that issuers covered
by the interchange fee standards in Regulation II retain records that demonstrate compliance with the
requirements of Part 235 for not less than five years after the end of the calendar year in which the debit
card transaction occurred.
Your Participation
To achieve the most reliable results, it is important that you respond completely and accurately. Please
leave no survey item blank.
There are three possible ways to answer a survey question:
Enter a Value: The actual numeric value of the data element.
Enter a Zero: When the calculated value equals zero. Please do not enter a non-numeric
value, e.g. “NA” or “NR,” when the value equals zero.
Enter “NR” (Not Reported): If your institution engages in the activity of the type being
measured but you are unable to report a figure that reflects that activity.
Please do not enter “NA.”
If for any reason you cannot provide complete data or you have questions please contact
Jessica Stahl at 202-452-6452 or e-mail debit.card.surveys@frb.gov for assistance.
The survey will be made available online at https://www.federalreserve.gov/debitcardsurveys.
Please complete the survey by May 1, 2018.

2

Response Confidentiality and Burden
The Federal Reserve Board regards the individual organization information provided by each respondent
as confidential (5 U.S.C. § 552(b)(4)). The Board, however, may publish aggregate or summary
information in a way that does not reveal your individual organization’s confidential information. If it
should be determined subsequently that any information collected on this form must be released, the
respondents will be notified.
Public reporting burden for this collection of information is estimated to be 200 hours per response,
including the time to gather data in the required form and to review instructions and complete the
information collection. Send comments regarding this burden estimate or any other aspect of this
collection of information, including suggestions for reducing the burden, to Secretary, Board of Governors
of the Federal Reserve System, 20th and C Streets, N.W., Washington, D.C. 20551, or via email to
regs.comments@frb.gov; and to the Office of Management and Budget, Paperwork Reduction Project
(7100-0344), Washington, D.C. 20503. The Federal Reserve may not conduct or sponsor, and an
organization (or a person) is not required to respond to, a collection of information unless it displays a
currently valid OMB control number.

3

Section I:

Respondent Information

1. Name of the debit card issuer covered in this response

2. Contact person(s) by section of the survey for which responsible
Name

Email

Section

Phone

Name

Email

Section

Phone

Name

Email

Section

Phone

Name

Email

Section

Phone

4

Section II: All Debit Card Transactions
(including general-use prepaid card transactions)
Please enter totals only for transactions and associated costs related to debit cards linked to U.S.-domiciled
accounts involving a merchant located in the United States during the calendar year (CY) 2017.
Include:

All debit card transactions (including general-use prepaid card transactions).
Both consumer and business card transactions.

Do Not Include: ATM or credit card transactions.

1. CY 2017 debit card transactions (including
general-use prepaid card transactions)
1a.

Value ($)

Volume

Value ($)

Settled purchase transactions (excluding
pre-authorizations, denials, adjustments, returns,
and cash back amounts)

Card-present vs. card-not-present transactions
1b.

Volume

Allocate “1a. Settled purchase transactions”
between the following categories:

1a:

1a:

1b.1 + 1b.2 = 1a

1b.1

Card-present transactions

1b.2

Card-not-present transactions

Volume

General-use prepaid card transactions vs. all
other debit card transactions
1c.

Allocate “1a. Settled purchase transactions”
between the following categories:
1c.1 + 1c.2 = 1a

1c.1

General-use prepaid card
transactions

1c.2

All other debit card transactions

5

1a:

Value ($)

1a:

General-use prepaid card exemption:
Volume

Exempt vs. non-exempt general-use prepaid
card transactions
1d.

Allocate “1c.1 General-use prepaid card
transactions” between the following categories:

1c.1:

Value ($)

1c.1:

1d.1 + 1d.2 = 1c.1

1d.1

General-use prepaid card transactions
exempt from the interchange fee
standards.

1d.2

General-use prepaid card transactions not
exempt from the interchange fee
standards.

2. CY 2017 chargebacks and returns
2a.

Volume

Value ($)

Total chargebacks
Report all chargebacks settled in CY 2017 regardless of
the date the original purchase transaction took place.

2b.

Allocate “2a. Total chargebacks” between the
following categories:
2b.1 + 2b.2 = 2a

2c.

2b.1

Fraud-related chargebacks

2b.2

All other chargebacks (not related to
fraud )

Total returns
Report all returns sent in CY 2017 regardless of the date
the original purchase transaction took place.

6

2a:

2a:

Specific Instructions for Question 3:
Include:

Costs of authorization, clearance, and settlement of all purchase transactions, chargebacks,
returns, and other non-routine transactions (e.g. errors).
Both costs associated with interbank settlement and account posting.
All fixed and variable cost components—see glossary.
In-house costs (including costs incurred by affiliated processors—see glossary), network
processing fees, and third-party processing fees.
Examples of in-house costs: Labor, equipment/hardware, and software associated with
authorization, clearance, and settlement of debit card transactions.
Examples of third-party processing fees: Billed processing fees net of any rebates received
tied to the authorization, clearance, and settlement of debit card transactions. This should
include billing for returns, chargebacks, and other error processing.
Examples of network processing fees: Switch fees and any other billed network fees tied to the
authorization, clearance, and settlement of debit card transactions net of any rebates received.

Do Not Include: Any costs that are not specifically related to the authorization, clearance, and settlement of
purchase transactions, chargebacks, and other non-routine transactions. For example, do not
include costs related to corporate overhead, account relationships, rewards programs, nonsufficient funds handling, non-sufficient funds losses, cardholder inquiries, card production and
delivery, or fraud losses. Also, do not include fraud prevention costs, even if those costs are
incurred as part of authorization. In the case of general-use prepaid card transactions, do not
include costs associated with funds loads or account set-up and maintenance.
For fees paid for third-party services such as processors and networks and network fees:
Report actual costs net of any rebates received.
For capital expenditures associated with authorization, clearance, and settlement:
Report costs that were depreciated or amortized during 2017 using the U.S. Generally Accepted Accounting
Principles (GAAP) or the International Financial Reporting Standards (IFRS).
For costs shared with other card programs or activities:
Allocate the costs based on the number of transactions. For example, if your institution has shared costs for debit
and credit card operations, allocate those costs to debit card operations based on the proportion of debit card
transactions to total debit and credit card transactions.
For in-house costs incurred as a result of outsourcing to an affiliated processor under the same holding
company:
Report costs incurred by the issuer, provided that the costs of the issuer are determined in a way that is
consistent with fees that the affiliated processor would charge to an unaffiliated debit card issuer.

3. CY 2017 costs of authorization, clearance, and
settlement
3a.

Costs of authorization, clearance, and
settlement

3b.

Allocate “3a. Costs of authorization,
clearance, and settlement” between the
following categories:
3b.1 + 3b.2 + 3b.3 = 3a

3b.1

In-house costs

7

Dollars ($)

3a:

3c.

3b.2

Third-party processing fees

3b.3

Network processing fees

Does your institution outsource processing to a
processing affiliate under the same holding
company?

[ ] Yes

[ ] No

[ ] Yes

[ ] No

If yes, costs should be included as in-house costs in
3b.1.

3d.

Does your answer in “3a. Costs of
authorization, clearance, and settlement”
include an allocation of the debit card portion of
shared costs?

If yes, please comment on what types of costs are shared and with which other activity(ies):

8

Specific Instructions for Question 4:
Include:
All relevant costs that are associated with debit card transactions.
All fixed and variable cost components.
Examples for cardholder inquiries: Inquiries about transactions details, errors, and
potential fraudulent activity.
Examples for cardholder rewards: Rewards paid out to cardholders during 2017 even if
those rewards were not earned in 2017.
Examples for non-sufficient funds handling: Costs of collection activities and reporting the
account to credit agencies.
Do Not Include: Any costs that are NOT associated with debit card transactions.
Examples for cardholder inquiries: Inquiries regarding account balances, rewards
programs, credit card transactions, and ATM transactions.
Examples for cardholder rewards: Rewards program administration costs and affinity
partner revenue-sharing, and rewards earned by cardholders in 2017, but not paid out in
2017.
Examples for non-sufficient funds handling: Amount of or losses from such transactions.
For capital expenditures:
Report costs that were depreciated or amortized during 2017 using the U.S. Generally Accepted Accounting
Principles (GAAP) or the International Financial Reporting Standards (IFRS).
For costs shared with other card programs or activities:
For cardholder inquiries: Allocate the costs based on the number of inquiries. For example, if your institution
has a shared call center for debit and credit cards, allocate those costs to debit card transactions based on
the proportion of inquiries related to debit card transactions relative to total cardholder inquiries.
For non-sufficient funds handling: Allocate the costs based on the number of non-sufficient funds
transactions. For example, if your institution has shared costs for non-sufficient funds handling of debit card
and check transactions, allocate those costs to debit card operations based on the proportion of nonsufficient funds debit card transactions to total non-sufficient funds transactions.

4. CY 2017 costs associated with a particular
debit card transaction that are not
authorization, clearance, and settlement costs
Cardholder inquiries

Dollars ($)

4a.

Costs of cardholder inquiries associated with
particular debit card transactions

4b.

Allocate “4a. Costs of cardholder inquiries
associated with particular debit card transactions”
between the following categories:
4b.1 + 4b.2 = 4a

4b.1

Costs related to possible fraudulent
debit card transactions

9

4a:

4b.2

Costs not related to possible fraudulent
debit card transactions

Cardholder rewards
4c.

Dollars ($)

Costs of cardholder rewards associated with
particular debit card transactions

Non-sufficient funds handling
4d.

Dollars ($)

Costs of non-sufficient funds handling
associated with particular debit card transactions

10

5. CY 2017 fraud prevention and data security
costs
5a.

Total fraud prevention and data security
costs

Less: 5a.1
to

Transactions monitoring costs tied
authorization

Less: 5a.2

Your answer to “4b.1 Costs related to
possible fraudulent debit card
transactions”

5b.

Dollars ($)

4b.1:

Fraud prevention and data security costs
net of transactions monitoring and
cardholder inquiry costs
5b = 5a – 5a.1 – 4b.1

5c.

Fraud prevention activities
Below are some common fraud prevention activities that
an issuer may engage in. The list is not meant to be
exhaustive but rather serves as a way to track the
prevalence of existing fraud prevention techniques.
Check all that apply.

[ ] Transaction monitoring
[ ] Merchant blocking
[ ] Data security
[ ] PIN customization
[ ] Other
Other fraud prevention activities:
In order to track both existing and emerging fraud prevention and detection techniques, please list
activities not listed above and provide a brief description.

11

Dollars ($)

6. CY 2017 interchange fee revenue
6a.

Total interchange fee revenue received
(gross interchange fee revenue)
6a.

Interchange fees reimbursed to acquirers
as a result of chargebacks or returns
Report reimbursements for all chargebacks or
returns sent in CY 2017 regardless of the date
the original purchase transaction took place.

6b.

6a:

Allocate “6a. Interchange fees reimbursed
to acquirers as a result of chargebacks
or returns” between the following
categories:
6b.1 + 6b.2 = 6a

6b.1 Interchange fees reimbursed to
acquirers as a result of
chargebacks
6b.2 Interchange fees reimbursed to
acquirers as a result of returns

7. CY 2017 fraudulent transactions: number
7a.

Total number of fraudulent transactions

7b.

Allocate “7a. Total number of fraudulent
transactions” between the following categories:

Number

7a:

To the extent possible, include each fraudulent
transaction in only one category consistent with how
your institution categorizes the loss associated with the
fraudulent activity.

7b.1

Card-not-present

7b.2

Counterfeit

7b.3

Lost and stolen

7b.4

Other
Please describe the types of fraudulent transactions included in “7b.4 Other”:
To the extent possible, list the type of fraud and the number of transactions associated with
that fraud.

12

8. CY 2017 fraud losses: value (all types)
8a.

Dollars ($)

Gross value of fraudulent transactions

Less: 8a.1 Fraud-related chargebacks net of
representments
Report all chargebacks sent in CY 2017
regardless of the date the original purchase
transaction took place.

Less: 8a.2

Losses absorbed by cardholders
Report all losses absorbed in CY 2017
regardless of the date the original purchase
transaction took place.

8b.

Losses incurred by issuer
8b = 8a – 8a.1 – 8a.2

9. CY 2017 fraud losses: value (card-not-present)
9a.

Gross value of fraudulent transactions

Less: 9a.1 Fraud-related chargebacks net of
representments
Report all chargebacks sent in CY 2017
regardless of the date the original purchase
transaction took place.

Less: 9a.2

Losses absorbed by cardholders
Report all losses absorbed in CY 2017
regardless of the date the original purchase
transaction took place.

9b.

Losses incurred by issuer
9b = 9a – 9a.1 – 9a.2

13

Dollars ($)

10. CY 2017 fraud losses: value (counterfeit)

Dollars ($)

10a. Gross value of fraudulent transactions
Less: 10a.1 Fraud-related chargebacks net of
representments
Report all chargebacks sent in CY 2017
regardless of the date the original purchase
transaction took place.

Less: 10a.2 Losses absorbed by cardholders
Report all losses absorbed in CY 2017
regardless of the date the original purchase
transaction took place.

10b. Losses incurred by issuer
10b = 10a – 10a.1 – 10a.2

11. CY 2017 fraud losses: value (lost and stolen)
11a. Gross value of fraudulent transactions
Less: 11a.1 Fraud-related chargebacks net of
representments
Report all chargebacks sent in CY 2017
regardless of the date the original purchase
transaction took place.

Less: 11a.2 Losses absorbed by cardholders
Report all losses absorbed in CY 2017
regardless of the date the original purchase
transaction took place.

11b. Losses incurred by issuer
11b = 11a – 11a.1 – 11a.2

14

Dollars ($)

12. CY 2017 fraud losses: value (other)

Dollars ($)

12a. Gross value of fraudulent transactions
Less: 12a.1 Fraud-related chargebacks net of
representments
Report all chargebacks sent in CY 2017
regardless of the date the original purchase
transaction took place.

Less: 12a.2 Losses absorbed by cardholders
Report all losses absorbed in CY 2017
regardless of the date the original purchase
transaction took place.

12b. Losses incurred by issuer
12b = 12a – 12a.1 – 12a.2

15

Section III: All Single-Message Debit Card Transactions
(excluding general-use prepaid card transactions)
Exact copy of Section II (except 1c and 1d would be removed) but for
single-message debit programs only.
Section IV: All Dual-Message Debit Card Transactions
(excluding general-use prepaid card transactions)
Exact copy of Section II (except 1c and 1d would be removed) but for
dual-message debit programs only.
Section V: General-Use Prepaid Card Transactions
Exact copy of Section II except 1c will be modified to include a
breakout of single-message and dual-message transactions as below,
and 1d would be removed.
Volume

General-use prepaid card transactions
processed over single-message vs. dualmessage payment card networks
1c.

Allocate “1a. Settled purchase transactions”
between the following categories:
1c.1 + 1c.2 = 1a

1c.1

Single-message transactions

1c.2

Dual-message transactions

16

1a:

Value ($)

1a:

Glossary of Terms
Acquirer: A person that contracts directly or indirectly with a merchant to provide settlement for the
merchant’s electronic debit transactions over a payment card network. An acquirer does not include
a person that acts only as a processor for the services it provides to the merchant.
Cardholder inquiries associated with debit card transactions: Cardholder communication
with a debit card issuer related to specific debit card transactions, such as inquiries about
transactions details, errors, and potential fraudulent activity. These do not include inquiries that are
not related to specific debit card transactions, such as account balances, rewards programs, credit
card transactions, and ATM transactions.
Cardholder rewards: Incentive payments given to cardholders as a result of particular debit card
transactions.
Card-not-present fraud: Fraud related to card-not-present transactions.
Card-not-present transaction: Settled purchase transaction where the purchaser does not
physically present the card to the merchant, such as an Internet, telephone, or mail order transaction.
Card-present transaction: Settled purchase transaction where the purchaser physically presents
the card to the merchant.
Chargeback: Transaction initiated by the issuer that reverses a purchase transaction, in whole or in
part (due, for example, to customer disputes, fraud, processing errors, authorization issues, and nonfulfillment of copy requests), and transfers value from the acquirer to the issuer.
Costs of authorization, clearance, and settlement: These costs include in-house costs, thirdparty processing fees, and network processing fees. These costs do not include, for example, costs
related to corporate overhead, account relationships, rewards programs, non-sufficient funds
handling, non-sufficient funds losses, cardholder inquiries, card production and delivery, fraud losses,
and fraud-prevention costs, even if those costs are incurred as part of authorization. These costs do
not include costs associated with funds loads (or deposits) or account set-up and maintenance.
These costs should be provided for purchase transactions, chargebacks, and other non-routine
transactions.
Counterfeit fraud: Fraud identified as having occurred through the use of a counterfeit reproduction
of a debit card.
Debit card: Any card or other payment code or device, issued or approved for use through a payment
card network to debit an account, regardless of the means of authorization, and regardless of whether
the issuer holds the account. A debit card includes any general-use prepaid card. It does not include
(1) any card or other payment code or device that is redeemable upon presentation at only a single
merchant, or an affiliated group of merchants for goods or services, or (2) a check draft or similar
paper instrument, or an electronic representation thereof.
Debit card transaction: Use of a debit card (including a general-use prepaid card) by a person as a
form of payment in the United States to initiate a debit to an account. It does not include transactions
initiated at an ATM.
Dual-message transaction: Transaction type by which authorization information is carried in one
message and clearance information is carried in a separate message. Typically, these transactions
are authenticated with a signature.

17

Exempt general-use prepaid card transaction: Transaction using a general-use prepaid card
that is exempt from the interchange fee standards in Regulation II, specifically (1) a transaction made
using a general-use prepaid card that has been provided to a person pursuant to a federal, state, or
local government-administered payment program through which the cardholder may use the debit
card only to transfer or debit funds, monetary value, or other assets that have been provided pursuant
to such program; (2) a transaction made using a general-use prepaid card that is (i) not issued or
approved for use to access or debit any account held by or for the benefit of the cardholder (other
than a subaccount or other method of recording or tracking funds purchased or loaded on the card on
a prepaid basis), (ii) reloadable and not marketed or labeled as a gift card or gift certificate, and (iii)
the only means of access to the underlying funds, except when all remaining funds are provided to
the cardholder in a single transaction.
Fixed costs: Costs that do not vary with changes in the number or value of transactions over the
course of the reporting period. For in-house fixed costs, these include all capital expenditures that
were depreciated or amortized. For third-party processing fees, these include fees that are not
assessed on a per-transaction or ad valorem basis. For example, fees associated with minimum
volume commitments to third-party processors should be reported as fixed costs.
Fraud-related chargeback: The value of a fraudulent debit card transaction that is charged back to
acquirers.
Fraud-related chargebacks net of representments: The value of fraudulent debit card
transactions that are charged back to acquirers less the value of representments made by acquirers
to debit card issuers.
General-use prepaid card: A card or other payment code or device that is (1) issued on a prepaid
basis in a specified amount, whether or not that amount may be increased or reloaded, in exchange
for payment and (2) redeemable upon presentation at multiple unaffiliated merchants for goods or
services. NOTE: An institution is an issuer of a general-use prepaid card if that institution serves as
a BIN sponsor for a prepaid card program such that (1) the institution authorizes the cardholder to
use the card to perform electronic debit card transactions that access the funds in a pooled account,
and (2) the cardholder’s relationship is with that institution. Include in your response information
regarding prepaid cards for which your institution serves as a BIN sponsor in this way.
Gross value of fraudulent transactions: The total value of fraudulent debit card transactions
before any recoveries or chargebacks.
In-house costs: Costs of authorization, clearance, and settlement functions that are not outsourced to
third parties. Include costs incurred by the card issuer or its affiliated processor (i.e., a processor in
the same holding company).
Losses absorbed by cardholders: The value of losses that an issuer recovers from its
cardholders. Include any chargebacks to cardholder accounts.
Lost and stolen fraud: Fraud identified as having occurred through the use of a lost or stolen debit
card.
Network processing fees: Total fees charged by payment card networks for services that are
required for the network processing of transactions. They do not include any fees for optional
services related to transaction processing that may be provided by a payment card network or an
affiliate of a payment card network. They do not include any network fees, such as membership or
license fees, that are not directly linked to the processing of transactions.

18

Non-sufficient funds handling costs: Costs of handling of events in which an account does not
have enough funds to settle an authorized debit card transaction between the time of authorization of
that transaction and the settlement of that transaction.
Return: Transaction initiated by the acquirer that reverses a purchase transaction, in whole or in part
(due, for example, to the return of goods and services by the cardholder), and transfers value from
the acquirer to the issuer.
Settled purchase transaction: A debit card transaction that has been settled. Exclude
transactions that are pre-authorizations, denials, adjustments, returns. Exclude cash back value but
not transactions.
Single-message transaction: Transaction type by which authorization and clearance information is
carried in one message. Typically, these transactions are authenticated with a PIN.
Third-party processing fees: Fees paid to unaffiliated service providers for services related to the
authorization, clearance, and settlement of debit card transactions that are performed by those
service providers on behalf of the debit card issuer. Service providers may include payment card
networks or affiliates of payment card networks to the extent that such parties provide optional
services related to transaction processing. They do not include other fees charged by a payment
card network for services that are required for the network processing of transactions or fees charged
by an affiliated processor (i.e., a processor in the same holding company).
Three-party systems: Systems where debit transactions are processed by an entity that acts as
system operator and issuer, and may also act as the acquirer. This entity that receives information
from the merchant or acquirer also holds the cardholder’s funds. Therefore, rather than directing the
transaction information to a separate issuer, this entity authorizes and settles the transaction itself.
As these entities do not connect (or “network”) multiple issuers and do not route information to
conduct the transaction, they are not “payment card networks” with respect to these transactions.
Total fraud-prevention and data-security costs: Costs related to activities aimed at identifying
and preventing debit card fraud, costs related to the monitoring of the incidence of, reimbursements
received for, and losses incurred from debit card fraud, costs related to responding to suspected and
realized debit card fraud in order to prevent or limit losses, costs incurred in securing the data
processing and communications infrastructure of debit card operations, and costs incurred in the
development or improvement of fraud-prevention technologies.
Total interchange fee revenue received: Total value of fees received that are established,
charged, or received by a payment card network and paid by a merchant or an acquirer for the
purpose of compensating an issuer for its involvement in the debit card transaction.
Total number of fraudulent transactions: The total number of all fraudulent debit card
transactions identified by the issuer. Include fraudulent transactions charged back to acquirers.
Transactions monitoring costs: Costs related to programs that monitor transactions in order to
assist in the authorization process by providing information to the issuer before the issuer decides to
approve or decline the transaction. These costs include the costs of neural networks and fraud-risk
scoring systems.
United States: The states, territories, and possessions of the U.S., the District of Columbia, the
Commonwealth of Puerto Rico, or any political subdivision of any of the foregoing.
Variable cost: Costs that directly vary with the number or value of transactions over the course of the
reporting period. In-house variable costs, for example, may include certain labor costs. Variable

19

costs related to third-party processing fees are those fees assessed on a per-transaction or ad
valorem basis.

20