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Headquarters: 1601 Dodge Street
Omaha, NE 68197
(877) 458-0021
www.tributarycapital.com
enelson@tributarycapital.com
April 2026
This brochure provides information about the qualifications and business practices of Tributary Capital
Management, LLC. If you have any questions about the contents of this brochure, please contact us at
(877) 458-0021. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission (SEC) or by any state securities authority.
Additional information about Tributary Capital Management, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Material Changes
Material Changes since the Last Update
This brochure dated April 27, 2026, reflects an other-than-annual updating amendment. The following
material changes were made to the brochure since the last filing dated March 19, 2026.
• Effective April 1, 2026, Tributary Capital Management has added a team of five investment
professionals dedicated to Large Cap Strategies. This team will manage the Equity Income, Large
Cap Core Equity and Multi-Cap Core Equity Strategies and operate independently of the existing
Tributary Small and Small/Mid Cap Team.
Full Brochure Availability
The Firm Brochure for Tributary is available by contacting Elizabeth Nelson at (877) 458-0021 or
enelson@tributarycapital.com.
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Item 3: Table of Contents
Item 1 - Cover Page
Item 2 - Material Changes .......................................................................................................... 1
Item 3 - Table of Contents .......................................................................................................... 2
Item 4 - Advisory Business ......................................................................................................... 3
Item 5 - Fees and Compensation ............................................................................................... 4
Item 6 - Performance-Based Fees & Side-by-Side Management ............................................... 5
Item 7 - Types of Clients ............................................................................................................ 5
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 5
Item 9 - Disciplinary Information ................................................................................................. 7
Item 10 - Other Financial Industry Activities and Affiliations ....................................................... 7
Item 11 - Code of Ethics, Participation in Client Transactions, Personal Trading ........................ 8
Item 12 - Brokerage Practices .................................................................................................... 8
Item 13 - Review of Accounts ................................................................................................... 12
Item 14 - Client Referrals and Other Compensation ................................................................. 12
Item 15 - Custody ..................................................................................................................... 12
Item 16 - Investment Discretion ................................................................................................ 12
Item 17 - Voting Client Securities ............................................................................................. 13
Item 18 - Financial Information ................................................................................................. 13
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Item 4: Advisory Business
Firm Description
Tributary Capital Management, LLC (“Tributary”), originally formed on January 1, 2005, is an SEC-
registered investment advisor headquartered in Omaha, Nebraska. Tributary and First Investment Group
(formerly a department of First National Bank of Omaha “FNBO”) merged in May 2010. The event
constituted a change in ownership only, as the investment strategies and personnel remained the same for
each of the prior firms. Firm equity assets, including model portfolios, wrap accounts, separately managed
accounts and mutual funds (excluding sub-advised funds) were $2,716.49 million as of December 31, 2025.
(Tributary’s regulatory assets under management as defined in ADV Part I were $1,900.96 million as of
December 31, 2025.)
Principal Owners
We are a wholly owned subsidiary of FNBO, a wholly owned subsidiary of First National of Nebraska, Inc.
Types of Advisory Services
We provide investment management services to institutional and individual investors. We construct our
investment portfolios based on our clients’ investment objectives and specified restrictions or guidelines.
Our separately managed account portfolios include small, small/mid, large, all cap, all cap plus and equity
income. We also offer individually managed accounts that are customized and do not follow an investment
strategy. They are customized to each investor’s specific situation and managed according to instructions
provided by the client.
We serve as the registered investment advisor for the Tributary Funds, Inc., (the “Tributary Funds”) a
registered open-end investment company that offers six investment portfolios:
• Tributary Small Company Fund
• Tributary Small/Mid Cap Fund
• Tributary Balanced Fund
• Tributary Short-Intermediate Bond Fund
• Tributary Income Fund
• Tributary Nebraska Tax-Free Fund
We have retained First National Advisers, LLC (“FNA”), an affiliate registered with the SEC, to serve as the
fixed-income sub-advisor to the Tributary Balanced, Short-Intermediate Bond, Income and Nebraska Tax-
Free Funds.
Tributary participates as a portfolio manager in several “wrap fee” programs in which program clients pay a
fee(s) for advisory, brokerage and custodial services to the wrap sponsor. Tributary exercises investment
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discretion over the program client’s portfolio and transactions are executed without a commission. In these
programs, a third party offers a Tributary managed strategy to its clients. Tributary receives an investment
advisory fee from the third-party wrap fee program sponsor for this service.
We provide clients access to our strategies by signing an investment management agreement. The
agreement may be terminated by the client by providing prior written notice of termination. Tributary may
typically terminate the agreement by providing the client with sixty (60) days prior written notice of
termination.
Tributary also provides investment advisory services via model delivery to third-party investment managers
and Turnkey Asset Management Programs (TAMPs). In these relationships, Tributary provides purchase
and sale recommendations in the form of a model portfolio but is not responsible for creating or executing
any trades.
Item 5: Fees and Compensation
Description
Client billing is handled on a client-by-client basis based on the details of the advisory agreements. We use
a percentage of assets under management based on the period-end market value of the account when
calculating fees for our clients. Tributary’s preferred method is to bill clients quarterly in arrears. We charge
a prorated fee for accounts initiated or terminated during a month or quarter. In some instances, advisory
fees may be negotiated based on specific account characteristics such as account size, investment strategy
and relationship type; therefore, fees may differ between accounts. In addition to Tributary’s fees, clients
may incur brokerage (please refer to the Brokerage Practices section), custody, transaction and other
administrative fees. Our standard fee schedule is as follows:
Small, Small/Mid, All Cap
Large Cap, Multi Cap &
& Individually Managed
Equity Income
First $10 million
0.65%
0.80%
Next $15 million
0.55%
0.75%
Next $25 million
0.45%
0.70%
Above $50 million
0.40%
0.65%
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Other Fees
Some of our accounts may hold mutual funds or exchange-traded funds (ETFs) as part of their overall asset
allocation. All fees paid to Tributary are separate and distinct from the fees and expenses charged by mutual
funds and/or ETFs to their shareholders. These fees and expenses are described in the fund’s prospectus
and will generally include a management fee, shareholder servicing fee and other expenses that are
deducted from fund assets and therefore reduce the net asset value of the fund.
Tributary uses its discretionary authority to invest certain clients in Tributary Funds, which are advised by
our firm. A conflict of interest exists as we are incentivized to recommend the Tributary Funds to increase
assets for which we earn additional mutual fund fees separate from a client’s investment management fees.
To mitigate the potential conflict, we exclude the portion of the account attributed to the Tributary Funds in
the calculation of the client’s investment management fee.
Item 6: Performance-Based Fees & Side-by-Side Management
We do not have any performance-based fees at this time.
Item 7: Types of Clients
Description
We offer investment management services to institutional and individual clients and registered investment
companies. Our institutional clients include banking and thrift institutions, pension and profit-sharing plans,
charitable organizations, other investment advisers, corporations and other businesses. We also participate
in wrap-fee programs and provide model-based offerings.
Account Minimums
Our minimum account size varies depending on account type and investment strategy and ranges from
$100,000 to $5 million. We have sole discretion to waive minimum account balances.
Item 8: Methods of Analysis, Investment Strategies and Risk of
Loss
We are active portfolio managers grounded in strong fundamental research and adherence to risk
management. Investments in our client accounts may include but are not limited to, investments in common
stocks, investment companies, exchange-traded funds, corporate and municipal bonds and U.S.
Government and agency bonds.
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Our equity investment strategies include small cap, small/mid cap, multi cap, large cap, all cap, all cap plus
and equity income strategies. Our managers use rigorous stock research processes to identify businesses
believed to represent opportunities for long-term growth.
Our individually managed accounts invest in a client specific blend of assets customized to achieve stated
investment objectives.
Risk of Loss
There is a risk of loss when investing in any investment security, and clients should be prepared to bear
this loss.
• General Market Risk: All forms of securities may decline in value due to factors affecting securities
markets generally, such as real or perceived adverse economic, political, or regulatory conditions,
inflation, changes in interest or currency rates or adverse investor sentiment. Adverse market
conditions may be prolonged and may not have the same impact on all types of securities. The
values of securities may fall due to factors affecting a particular issuer, industry or the securities
market as a whole.
The material risks specific to our equity strategies include:
• Common Stock Risk. Companies that we invest in may not perform as anticipated. A downturn in
the stock market may lead to a lower market price for a stock even when company fundamentals
are strong. Factors such as U.S. economic growth and market conditions, interest rates and
political events affect the stock market.
•
Investment Strategy Risk. There is risk that a particular strategy, such as small cap equity, will be
out of favor and not perform as we predict. In addition, there is a risk that the stocks we select may
not reach what the portfolio manager believes to be their full value.
• Mid-Cap and Small-Cap Stock Risk: The prices of securities of mid-cap and small-cap companies
tend to fluctuate more widely and erratically than those of larger, more established companies.
Mid-cap and small-cap companies may have limited product lines, markets or financial resources
or may depend on the expertise of a few people and may be subject to more abrupt or erratic
market movements than securities of larger, more established companies or the market averages
in general. Securities of such issuers may lack sufficient market liquidity to effect sales at an
advantageous time or without a substantial drop in price.
The material risks specific to our individually managed accounts that include fixed income investments
include the items listed above as well as the following:
•
Interest Rate Risk: Changes in interest rates affect the value of the strategy’s fixed income
securities. When interest rates rise, the value of the strategy’s fixed income securities will decline.
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• Credit Risk: The strategy could lose money if the issuer of a fixed income security cannot meet its
financial obligations or goes bankrupt. The price of a security held by the strategy can be adversely
affected prior to actual default if its credit status deteriorates and the probability of default rises.
• Guarantee Risk: Mortgage and asset-backed securities involve the risk that private guarantors
may default. There can be no assurance that the private insurers or guarantors of fixed income
securities can meet their obligations under the insurance policies or guarantee arrangements.
• Mortgage-Related and Other Asset-Backed Securities Risk: The risks associated with mortgage-
backed securities include: (1) credit risk associated with the performance of the underlying
mortgage properties and of the borrowers owning these properties; (2) adverse changes in
economic conditions and circumstances, which are more likely to have an adverse impact on
mortgage-backed securities comprised of loans on certain types of commercial properties than on
those comprised of loans on residential properties; (3) prepayment and extension risks, which can
lead to significant fluctuations in the value of the mortgage-backed security; (4) loss of all or part
of the premium, if any, paid; and (5) decline in the market value of the security, whether resulting
from changes in interest rates or prepayments on the underlying mortgage collateral. Investments
in asset-backed securities are subject to risks similar to those associated with mortgage-related
securities, as well as additional risks associated with the nature of the assets and the servicing of
those assets.
Item 9: Disciplinary Information
Tributary has no reportable disciplinary events to disclose that are material to a client’s or prospective
client’s evaluation of our advisory business or the integrity of our management. (Additional information as
provided in Part 1A of Form ADV is available upon request.)
Item 10: Other Financial Industry Activities and Affiliations
Our firm has agreements with FNBO (our parent organization) and FNA (an affiliated registered investment
adviser) to provide investment advisory services to certain FNBO and FNA clients. A conflict may arise if
these client accounts receive preferential treatment. To mitigate this potential conflict, we aggregate orders,
when possible, and execute them as a block trade; all participating clients receive the same average price.
Please refer to the Brokerage Practices section for more information regarding order aggregation.
We also serve as the investment advisor and co-administrator to the Tributary Funds. The Investment
Advisory and the Co-Administration Agreements between Tributary and the Tributary Funds are subject to
the supervision of the Board of Directors of the Tributary Funds. While the Chairman of the Board of the
Tributary Funds is an employee of our parent company, any potential conflict of interest is mitigated with a
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Board comprised of a majority of Independent Directors with the distinct ability to influence the Board’s
agenda and actions.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Our Code of Ethics emphasizes our fiduciary duty to place our clients’ interests first and outlines expected
high ethical standards of business conduct that we require of our employees, including compliance with
applicable federal securities laws. The Code of Ethics includes provisions relating to the need to protect
personal client information; a prohibition on insider trading, fraudulent or deceitful activities and spreading
false rumors about a company; restrictions and reporting requirements for the acceptance of significant gifts
or entertainment; and personal securities trading and reporting requirements, among other things. All
supervised persons acknowledge and accept the terms of the Code of Ethics upon employment and
annually thereafter.
To prevent conflicts of interest that may arise, all access persons must receive pre-approval of certain
personal securities transactions. Personal investing by our access persons in the same securities, outside
of the de minimis exemptions, held by our clients cannot occur within three business days of an intended
client trade or within three business days after the execution of a client trade. The Code also imposes a 60-
day holding period requirement to prevent short-term trading. In addition, access persons provide quarterly
reports of personal security transactions, annual holdings reports, and, when applicable, direct their brokers
to supply us with account activity reports. A copy of our Code of Ethics is available upon request to any
existing or prospective client by contacting Elizabeth Nelson at (877) 458-0021.
Item 12: Brokerage Practices
Selecting Brokerage Firms
For accounts in which we have discretionary authority, we will determine the type, amount and price of
securities or investments to be bought or sold on behalf of our clients, including the selection of and
commissions paid to broker-dealers. In executing portfolio transactions and selecting broker-dealers, we
seek the best overall terms available on behalf of our clients. In assessing the best overall terms available
for any transaction, we consider the full range and quality of broker-dealer services including execution
capability, trading expertise, commission rates, research, reputation and integrity, fairness in resolving
disputes, financial responsibility and responsiveness. Tributary's Management Committee is responsible for
monitoring our Firm's trading practices, gathering relevant information, periodically reviewing and evaluating
the services provided by broker-dealers, the quality of executions, research and commission rates, among
other things.
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Research and Soft Dollars
As provided by Section 28(e) of the Securities Exchange Act of 1934, we obtain economic and company-
specific research, reports on corporate conference calls and news, portfolio and data analytics, electronic
price feeds and other brokerage services through soft dollar commissions. These services augment our
own internal research and investment strategy capabilities. Client commissions paid to our broker-dealers
benefit our firm by allowing us to obtain research and other products and services that we do not have to
pay for or produce ourselves. As such, we may have an incentive to select broker-dealers based on our
interest in receiving research or other products or services rather than considering our client’s interest of
the most favorable execution. We may not use each brokerage or research service, however, in the
management of each client account. As a result, a client may pay brokerage commissions that are used, in
part, to purchase brokerage or research services that are not used to benefit that specific client. Broker-
dealers providing brokerage and research services, even on an unsolicited basis, may charge commissions
for executing transactions that are higher than the amount of commissions that other broker-dealers may
charge for effecting the same transactions. We will execute portfolio transactions through these broker-
dealers only if it has been determined that such broker-dealers provide best execution. We do not make
formal or contractual commitments for soft dollar obligations.
Tributary may also use commission sharing arrangements (CSAs) to obtain soft dollar benefits. In CSAs,
Tributary may effect transactions, subject to best execution, through a broker-dealer and request that the
broker-dealer allocate a portion of the commission or commission credits to a segregated “research pool”
maintained by the broker-dealer. Tributary may then direct such broker-dealer to pay for eligible products
and services. Participating in commission sharing arrangements may enable Tributary to:
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strengthen its key brokerage relationships;
•
consolidate payments for eligible products and services; and
•
continue to receive a variety of high-quality eligible products and services while facilitating best
execution in the trading process.
Tributary will only acquire research and brokerage products and services with soft dollars if they qualify as
eligible products and services under the safe harbor of Section 28(e) of the Securities Exchange Act of
1934.
Directed Brokerage
Sometimes a client may wish to restrict trade execution to a particular broker or dealer; this is referred to as
directed brokerage. Our firm may accept directed brokerage instructions for specific client accounts. When
a client for whom we have discretionary investment authority instructs us in writing to direct a portion of their
securities transactions to a specific broker-dealer, we will treat the client’s direction as a decision by the
client to retain, to the extent of the direction, the discretion we would otherwise have in selecting brokers-
dealers to effect transactions and in negotiating commissions. Although we will attempt to effect such
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transactions in a manner consistent with policy, there may be occasions when we will be unable to do so.
The client, therefore, should consider whether commissions, execution, clearance and settlement
capabilities and fees of directed broker-dealers are comparable to those otherwise obtainable by our firm.
A client making such a designation may be forgoing the potential advantages from the aggregation of
transactions such as achieving the most favorable execution or price and reduced execution costs. The
client that directs transactions to a particular broker-dealer may receive less efficient clearing and settlement
on some transactions at least in part because the directed broker may provide less efficient service.
Trade Placement
Trades in which Tributary has the discretion to select the broker-dealer are blocked together and traded
first, using brokers selected by Tributary. In these instances, clients participating in any blocked transactions
will receive an average share price and transaction costs will be shared equally and on a pro-rata basis.
Block trading may allow us to execute equity trades in a timelier, more equitable manner. Trades for directed
brokerage accounts, in which the client has given Tributary full discretion to select the securities to purchase
and sell but requested us to use a specific broker or group of brokers are placed next in a rotational order.
Then, client accounts where Tributary provides changes to a model portfolio are communicated to the model
managers in a rotational order.
The more client assets we manage and directed brokerage relationships we accommodate, the greater the
potential market impact cost will be to client portfolios. Tributary attempts to manage the liquidity profile of
the order and minimize its impact on the market. Depending on the market capitalization, or market
availability of certain securities, these trades may take multiple days to complete.
Tributary may give advice and take action for clients which differs from advice given to, or the timing or
nature of action taken for, other clients, meaning Tributary may be buying and selling the same security at
the same time. For example, Tributary may be reducing a security position in a strategy while purchasing
the same security for a client account that has made a new or additional investment in that same strategy.
Specific asset allocations within client accounts may differ from those in other accounts managed by
Tributary due to various factors, including but not limited to, the availability of certain investments, market
conditions, client deposits and withdrawals or the amount of client funds available for investment or
reinvestment.
To address these potential conflicts, Tributary maintains policies and procedures to disclose, mitigate and
where possible eliminate any perceived conflicts of interest when it buys or sells securities on behalf of more
than one of its clients’ accounts. In addition, Tributary believes its core responsibility in managing all
accounts is to ensure that all benefits arising from its management of a client’s account belong to the client.
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Cross Trades
At its discretion, Tributary may, but is not required to, engage in “cross trades”, whereby Tributary causes
one of its clients to sell a security and another of its clients to purchase the same security at or about the
same time, provided such transaction is in the best interests of both accounts and is consistent with
Tributary’s best execution obligations. Cross trades may be used in an effort to obtain best execution
because cross trades can potentially reduce transaction costs and increase execution efficiency. Cross
trades present potential conflicts of interest. For example, there is a risk that the price of a security bought
or sold in a cross trade may not be as favorable as it might have been had the trade been executed in the
open market. Additionally, there is a potential conflict of interest when a cross trade involves a client account
on one side of the transaction and an account in which Tributary has substantial ownership or a controlling
interest or an account in which Tributary receives a higher management fee on the other side of the
transaction.
To address these potential conflicts, Tributary maintains policies and procedures, which require that all cross
trades are made at an independent current market price and are consistent with Section 206 of the Advisers
Act. In addition, if one of the parties to the cross trade is a registered investment company; the transaction
must comply with procedures adopted under Rule 17a-7 under the 1940 Act. Tributary does not execute
principal trades or permit cross trades with accounts subject to ERISA.
Trade Errors
Our firm has systems in place to prevent trade errors; however, errors may occur as a result of system
malfunctions, trader or broker error or other circumstances. If a trade error does occur, prompt action is
taken without disadvantaging the client. All trade errors are reported to the Tributary Management
Committee.
Order Aggregation
Our policy is to aggregate client transactions (also known as block trades) where possible and when
advantageous to our clients. In these instances, clients participating in any aggregated transactions will
receive an average share price and transaction costs will be shared equally and on a pro-rata basis. Block
trading may allow us to execute equity trades in a timelier, more equitable manner. When we purchase initial
security positions or liquidate entire security positions, discretionary trades are aggregated or blocked
together when possible. If two or more accounts are purchasing or selling the same security, these trades
will be aggregated if the orders are placed simultaneously. For all other trades, we will aggregate trades
when we believe that aggregation will lead to best execution. Our firm does not engage in principal trades.
A full description of our trading, execution, allocation and soft dollar practices is available upon request by
contacting Elizabeth Nelson at (877) 458-0021.
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Item 13: Review of Accounts
For equity investment strategies, as articulated in our firm literature, portfolio managers and the firm’s
operations team utilize various reports to continuously monitor investment accounts for adherence to the
relevant model portfolio. Individual security weightings and cash/money market weightings in an account
are compared to model weightings to identify potential deviations from the model. If a deviation exists, and
is deemed material, appropriate trades are made to bring the account back in line with the model.
For individually managed accounts that do not follow an equity investment strategy model, the portfolio
manager regularly evaluates each account utilizing our portfolio management system. Asset allocation,
positions in individual securities, suitability of each holding relative to the account’s objectives and any
unique requirements are among the factors considered. Additionally, the firm’s operations team regularly
runs automated reports to assist the portfolio manager in identifying any issues that may require attention.
These reports may include information such as cash levels, position sizes, and asset allocation, as well as
other factors, and are automatically generated and provided to the portfolio manager.
Investment objectives are updated as needed through communication with the account holder or their
intermediary, and accounts are adjusted accordingly.
Item 14: Client Referrals and Other Compensation
Our firm does not compensate any party for client referrals, nor do we receive compensation from anyone
who is not a client for providing investment advisory services to our clients.
Item 15: Custody
Tributary does not take custody of clients’ funds or securities, or have a related person serving as custodian.
Item 16: Investment Discretion
Tributary can receive discretionary authority from clients through the Advisory Agreement that establishes
the advisory relationship. For clients that grant us discretionary investment authority, we select the amount
and type of securities to be bought and sold without first obtaining their specific consent. When selecting
securities and determining amounts to be bought and sold, our portfolio managers follow the investment
guidelines stated in the applicable agreement for the equity investment strategy selected by the client. For
individually managed portfolios, they also consider the client's specific investment policy and any limitations
and/or restrictions placed upon the account. For our proprietary mutual funds, Tributary’s authority to trade
securities may also be limited by certain federal securities and tax laws that require diversification of
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investments and favor the holdings of investments once made.
Item 17: Voting Client Securities
Unless otherwise directed, Tributary votes proxies on the client’s behalf. In order to meet this fiduciary
responsibility and to avoid conflicts of interest, Tributary hired an independent, third-party service provider
to develop our written proxy voting policy. Tributary has adopted procedures to implement the firm's policy
and reviews to monitor and ensure the firm's policy is observed, implemented properly and amended or
updated, as appropriate, which include the following:
• The holdings of each client account are linked to Tributary’s Proxy Edge ID. Tributary monitors
Proxy Edge for upcoming proxy votes. All votes are populated by Glass Lewis. Portfolio managers
review each vote and if they wish to deviate from the Glass Lewis recommendation, the vote is
manually updated. All proxy votes are completed in a timely and appropriate manner.
•
If the client’s custodian is unable to send the holdings to Proxy Edge, the Director of Operations
will receive and vote these proxies manually according to Glass Lewis policy unless otherwise
directed by the portfolio manager.
Our entire proxy voting policies and procedures as well as our historical voting record are available by
contacting Elizabeth Nelson at (877) 458-0021.
Item 18: Financial Information
We believe our financial condition allows us to meet our contractual commitments to our clients.
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