Does the calculation of the SPI threshold in relation to e-money issuance include the value of e-money that has already been spent? How do I compute the daily average value of the e-money?

In computing whether an entity holds a daily average e-money float that exceeds the threshold of $5 million, the value of the e-money that has been spent by the payment service user is excluded. The total annual value of the e-money float is to be divided by the total number of days in a calendar year, and not only for the days when there was e-money issuance.
This information is sourced from MAS
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