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As discussed in Chapter V, unlike the previous FCA schemes, FE 25 does not provide Rupees liquidity to mobilizing banks. The hard currency mobilized between July 1998 and July 1999, was placed abroad directly by the commercial banks, while the FE 13 Circular announced in June 1999, effectively compelled banks to place fresh deposits with SBP. Two issues need to be noted: (1) discretionary placement abroad by banks became a source of concern in terms of the risk characteristics of the assets, and (2) the thrust of FE 13 was to encourage mobilizing banks to lend the hard currency in Pakistan with a fallback option of placing the funds with SBP. However, as banks were unable (or unwilling) to lend locally, all fresh FCAs were placed with SBP.