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Keeping Pace with Risk Mitigation and Regulatory Changes · Leaders in Lending

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You're listening to Leaders and Lending from Upstart, a podcast dedicated to helping consumer
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lenders grow their programs and improve their product offerings. Each week, here,
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decision makers in the finance industry offer insights into the future of the lending industry,
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best practices around digital transformation, and more. Let's get into the show
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well from the leaders in lending today. I am joined live and in person.
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Wonderful to do that with by Aaron Rikowski from West BANKO and Jen Rugierre.
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I got that right, M ANDT Bank from the CFPB Committee of the
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CBA. So there we go. So I guess we're gonna talk about,
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Yeah, should we do it? You guys? You guys have had your
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meeting with the committee, so I'm curious what are the topics for most top
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of mind for the committee these days? Like what's so like going on in
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the world of banking. Some of it is I think distracted from conversations around
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the CFPB, at least temporarily, but I know it's still top of mind
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for you guys. What are the topics of conversation when you guys get together?
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Pace of change, you know, and it seems like quickly monthly we're
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getting some new type of guide dale speed and unforced match in the supervisory life.
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I think of that nature about where the bureau is signaling to us,
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where they are looking, where they have priorities, and you know, it's
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coming fast and furious. How do we react to that and what are the
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actions right and where are they coming from? How are they letting us know?
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You know, we'll see something on the blog post that we'll see a
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supervisory highlights dock from, and then we'll see something that comes out at an
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advisory or a circular all of games non formal rules. Yep, it's something
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that we have to look at, evaluate and respond to. And just the
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pace posts come in, they don't have a fine timeline. You have to
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comment by this period. You have to have commines by this state. It's
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mandatory by this state. It's just almost the wild West from our regulatory perspective.
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It's coming fast, furious, and we're kinderous onto And does that feel
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demonstrablely different? Years have been in the industry for a while, does it
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feel demonstrably different than is that the common thing over the history of this If
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people here that a shift in how do you feel like information is flowing out
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in a more recent time period. I think the pace is more rapid than
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we've seen in the past. And forgetting they'd always need different tools available to
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that and be at enough couch. I do always sort of been able to
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read a t looks reached all its various and means in which they communicate,
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which is helpful. A lot of instances, you said, I lead,
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the piece is different, bamit to Biden, No, I agree. I
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think the paces are lot It is a lot faster. There's a lot more
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change that's being signaled through these different through these different pronouncements. And let's face
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it, the world writing process it takes time so well, a lot of
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times intentionally right exactly. I mean that there's a lot of comment. There's
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time to evaluate all the comments, it's looking at the proposals, it's looking
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at the final rules, implementation timelines. They're they've been very aggressive over the
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last several years, and I think they have a lot they would accomplish.
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And what best way for them to try to move that needle without going through
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that long du process is through advisories, through supervisory highlights, through since in
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orders or other other tools of band interested. Do you think there's an element
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of the political timeline. I mean there's elections coming up before long. The
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director is not permanent as permanent position, they can be fired it will.
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I mean like I think a little bit of like what can we sneak what
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can we get done at the time we have left before Maybe there's a changing
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of the guard. I don't know if that's driving some of the pace.
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I think each director has things they want to apoplish, right for sure,
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and you know defense about the same mission, right, what's right by our
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huston verse? Yeah, I'm so, you know up to that point though
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these front over roll make things and things tape alout for event one may have
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the positions, do you want to use the different tools available to drive their
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policy and what they was the right to do from a consumer protections get point.
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So I think it's to be expected, you know where that changes when
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you weren't the leadership changes. It does so though then potentially when they're not
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formal rules, right, we have to and okay, now what is this
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next? Leaders priorities and in some kind of sec and especially if there's a
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change in administration from one party the next it's more customary with this agency,
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the director steps down because they know that the new administration is going to help
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point their own director. So and Gen's absolutely right. I mean, everything
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that they're doing now can be easily undone by someone from the other side of
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the political spectrum. So as bankers, we have to look at that and
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evaluate how that's going to be, how that's going to change. Yeah in
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twenty twenty four. Yeah, there's some things they're doing the formal rulemaking process.
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The many that are they're a little less, the little less, so
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it's a little little. The other one of the other copics of conversation I
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know you guys have was around the clarity of expectations being conveyed. Talk to
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me about it. How that kind of clarity or lack of clarity on exactly
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what are the expectations are impacts the way you think about responding you're dealing with
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those things as a bank I think depending on the topic, we do get
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a lot of mixed signals, and I think you know, with the Bureau
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may sit in one of the other layers of complexity. The Bureau may signal
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one position on a particular topic, while our predential regulators who still have some
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compliance oversight of our resurtans even though we're larger. They we have another take
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on it. So we're evaluating what's the best strategy, Which master do we
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serve, you know, which which interpretation trumps And there isn't a lot of
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clarity. Sometimes we see we'll see pivoting back and forth or different messaging even
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from the bureau related to the same topics. You know, overdraft has always
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been one where they'll say one thing and then they'll see something a little bit
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different there next pronouncement. Then they'll go back to the friar when the next
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on this release information on that topic. But it's really hard for us to
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nail down exactly what they want us to do. At some points, you
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know that they want us to take this new interpretation and roll it forward.
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There's been times where they tell us, okay, we have a new interpretation,
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now you need to look back and retroactively apply that. That's very difficult
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for us, and if they do that for five years, they don't there's
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no clear standard on this, and we're as compliance officers. We've always been
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to the historically very good that you tell us a rule whether if we like
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it or not. You tell us a rule, would you tell us the
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standard, You tell us the timeline, we'll put it, replace them,
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We'll do it. But this mixed messaging and in consistent messaging is harder for
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us as bankers to deal with as compliance officers to explain relations things pre ban
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Sorry, it really is, um. You know if his errand said,
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we want to do the right thing by our customers first and foregops, for
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sure, we want to follows right, we want to do what is expected
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of us, and so U sometiops lack a clarity rate prevents us with no,
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it weren't debt is in other people's mind self? Um, you know,
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it makes it hard for us to always desirable solution that will last respond
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to what's being How do you think about building out a compliance organization or internal
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policies processes that deal with that kind of environment? I mean it feels like
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interesting question for you, not just from the CFP committee point of view,
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but from like your internal roles and compliance you know, in risk or compliancy,
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how do we actually think about operationalizing or building a team and building an
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approach that allows us to adapt to what seems to be somewhat changing environments,
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like how do you deal with that personally? Within the organizations? It just
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feels like an interesting challenge, a little bit different than the way traditionally compliance
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roles have operated with a little bit more set rules and expectations. Let you
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take this one course, very different scale organizations, So this might be a
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questing. You know, all is keeping in my between always keeping aligne.
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Let's do the right thing. Let's do the right thing by the customer.
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What's the first way to leverage data? We obviously have a lot more an
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ability to leverage data and identified risks so on. I would say one if
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it things though, you know now the directions or the luship. But one
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of the things that I find challenging, and I think a lot of the
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folks in many kind challenging is the impact on the tios and the human capital
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element of it leaving uh. You know, our heavy folks constantly pivot to
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the next thing, and they're always be potentially the last fire drow to deal
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with, you know, katol up at latins until keeping focused on all them
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good we're doing for the consumer, for the bank, you know, the
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value we're adding and keeping that pop front of mind. And you know,
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we can't solve every problem at what's so let's tackle all thet we go out,
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let's make it impact, Let's do the right thing. And so keeping
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that message and keeping that teen positive and focused is also really important, you
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know, regulatory divider mat that is I am yea and I think from my
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same bord too, is ingesting it as a compliance organizage and keeping our team,
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you know, engage and keeping them from getting all this burnt out,
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with all the with the pace of change. And for me, it's not
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only that, it's how do we disseminate this information to the right leaders as
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the organization. Yeah, how do we take this information? We can do
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and if we want with it our clients organization, we can afford it.
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We can tell our board management, Hey, this is this is what's common.
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This is how they're interbreting things. But unless we get it down into
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the leadership of our business lines that are dealing with our consumers and making product
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decisions of work lef, it's on implementing these changes, you know, it
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really doesn't matter. So having a strategy to get that information across the organization
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into the right people's hands in a way that is going to be meaningful for
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them, that they can understand it and to the best of our ability clarify
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what base new or change regulatory expect emitions are. It's absolutely critical to navigating
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this pace of change, in this style of change. Really, I would
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also add understooding the business, really understanding how they out how they serve our
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customers, and having risk people to really a deep understanding of that to help
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them solve. But you really parked there with those business folks and helping we
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beat the regulatory expectations but help our customers and also stay within the business live
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intel of that level of integration, that level of product knowledge is become more
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and more import from a risk perspective. But maybe ten years ago when you
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know, knowing the rules and yeah, not beating as good. Granted it
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was there out way business house. Yeah. The other thing that occursed me
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And it's interesting, it was a learning for me coming from the technology space
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into the banking you know space, Like I kind of expected there to be
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easy, just rules like is this a lot? Yes, No, you
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realize it's more like if I do ask how much of a risk am I
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taking? There's someone that's like no risk, and there's someone like, well,
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you're likely to go to jail if you do that. But the vast
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majority falls somewhere in the middle where it's like, well, it's not like
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a black and white there's a lot of areas that are a little bit gray.
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And I think that figuring out how to work with business owners across the
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organization and help them understand where in the shades of gray they can be and
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how that lines up with business priorities or other expectations, and where are we
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comfortable taking a little more risk and where we comfortable taking a little less risk.
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That's interesting because I think so often the lines of business just want like
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can I do this? They want to, They want to yes, no,
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And the answer is like maybe, well that's risk probably okay if you
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do these other things as well. And I think I'm curious how you think
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about managing that grayness across the organization, that kind of if not a clear
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yes or no, there's like, this is a risk, here's some mitigation
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strategies you could take. How big a risk? Well, I gotta find
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some way to quantify or help you understand it. It's like it's very different
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than it just yes, good, no bad, simple answer, And I
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think it has to go down the line of business to be well executed.
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Right, how do I think about making trade offs between business, between risks
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and the compliance side, between mitigation strategies I could take, how do you
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think about integrating it and like kind of pushing that all through the through organizations.
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I feel like that's just such a critical thing these days and very different
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to your point than maybe Weston or fifteen years ago. I would say,
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you know, and the wents starting there, our business leaders from the top
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twelve um are really sending the right messages around risk and risk management. And
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I would say more than ever, the business books are as educated on risk
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as anyone else. Right, So it's out there's most management, and here
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here's product folks. Right, those product folks are really as educated as risks.
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So the discussions I find to be pretty easy. As a business.
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Here's what the rule is, let's collectively make these decisions. You know are
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usually and you know, a group of belides, the defense at the table,
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the business partners, and really when we talk to things, it's rare
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and I reaching experience that there's disagreement on what the red tap is so um
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it's been i'd say, such a level of education and you know the message
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from the top of the house or managements, you know is important and it's
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one of our strategic comparatives. So I think that is at the key.
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Yeah, and I think looking at where the where the change is coming in
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the regulatory landscape, but where it has been coming, there is a lot
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that is black and white. You look at most traditional regulations, you look
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at look at trip right when that came out, Thou shalt calculate this way
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and thou shalt disclose this way, either doing it right or not. Ye.
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I mean there's there's not much gray area in the rules like that,
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or when you're collecting home to data or when ten seventy one drops later.
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This we collect, this is how we have to This is what we have
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to collect, and this is what we need to do. The gray area
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comes into the responsible bank in a fair landing, in TVWDAPP and where a
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lot of the Bureau's current current focus is. That's where I think our risks.
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Our business high leaders to gents BLAF, I really think they are starting
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to understand more than ever what those risks are and how things that we're doing
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could be perceived. And you know, in twenty plus years, I've never
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sat in a room where people are trying to figure out what's the most we
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can get out of a consumer. It's always what is the best us for
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our consumer? How can they understand this, what's the right trade off for
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this? How can we make this product better for them to make them want
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to come back with us, and having them understand the perception of what we're
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doing. It's in an all time high from what I'm experiencing as well.
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They really do grasp and are starting to grasp what potential could be unfair or
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what an agency could say is deceptive. And when they're building and designing the
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products, they're being very thoughtful of you making sure consumers are getting a good
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value for any fees or for the services we're provided. Yeah, I'll on
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that point because it's one of the things that's come up. One of the
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themes there that's called with a lot of my conversations is having the compliance and
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risk conversation early in the product. But it's like, don't don't finish the
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project and then center it over for the stamp of approval with the like yes,
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no, do we do it right? Like how that be an ongoing
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dialogue either with aligned business owner that's that's savvy about the risk involved, but
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also with the compliance seems risk as you're developing a product rejected strategy of marketing,
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missus, that's not like finish the whole thing and then toss over the
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fence and hope it comes back stamped. Yeah, let's let's iterate on this
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and build it together, because then we can get to a probably a better
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place. So just like the kind of like separate houses. Uh, it
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not non iterative like just waterfall thing. I know, you guys. It
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also mentioned the topic of fair banking and credit reporting is a topic that came
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talking about what's uh, what is the copic of discussion there? What's going
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on in that space? A lot what Aaron mentioned right, there's a lot
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of focus there. So those are the places we're seeing a lot of guidance
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um paths. It's a commistry. Credit reporting is very of course and uh
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you know it is extremely complex. So that's streetway data driven and so just
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a focus said and that you know from a consumer stampoint and making sure you
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know, I think euros a regulator stamp point that you know, there's matt
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negative impacts to consumers and following and it's chime otis. Yeah. I always
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feel like just that there's the consumer protection side of rulemaking, and then there's
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a like when an institution actually internalizes that, what happens to the availability of
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pricing of credit because of that? Because the first thing you do is why
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I get I got to restrict access to credit because I mean, my risk
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has increased or my revenues decreased. And so I do think understanding those impacts
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is really important because it changes the nature of what the real impact of regulations,
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what rulemaking can be, and cutter reportings. Ever since the bureau has
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been around, has always been a hot topic and it's always a hot hot
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topic with consumers. That's one of the leading if not looked at it in
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a while, but if not, the leading source of complaints in the CFPB
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conplaint well is credit reporting. And it's something that as banks were furnishers,
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so we have in its simplest term, one responsibility and obligation or FCR report
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accurately. That's it. We don't ever have to report, but if we
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do, it's going to be accurate, But once that data leaves us,
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it has absolutely bureaus. It goes into their black box, and consumers don't
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understand the impact that something that is going on with one of the major credit
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bureaus has on their scores, whether it's untilization rate, whether it's an inquiry,
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whether it's something that happens completely unrelated to us, or something that we've
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dealt with with some of our customers. Why did one of my scores go
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down but the other two didn't And we don't have an answer to that.
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We report the same thing to all bureros, but that's still a pain point
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for a customer. Well, even their scores are different among the bureaus,
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go why, Well, it's just not a great answer, and you don't
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have any insight into that. No, we don't know. We can't tell
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them why their score was eight hundred for a car loan and seven fifty six
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for a mortgage. You're depending on what products they get, their score could
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be different with the same beer, say yeah, for sure. Is there
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any discussion of the some of the newer products I think BNPL here in particular,
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that are not currently furnishing, and yet I would argue in many cases
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represent a substantial enough payment obligation on behalf the consumer that when you're thinking about
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pulling credit as a credit underwriting group, you're going, I would like to
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know that these obligations are on this like that were alone, I would know
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that there was a two hundred alarm unt payment that was due, that it
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would impact my my assessment of credit worthy despability to repay. And yet those
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things are being reported often to the bureaus. It was that sept in a
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topic of conversation, not so much, I get I'll have to call the
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credit people and see if they're they're talking about that. That could help us
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make more informed decisions when we're looking at it, for sure, and they
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could also help consumers. You're talking about there's a lot of people that are,
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you know, blind your credit line. They're not. They're credit invisible
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because they're financing thrilled by now pay later, And if they don't pay their
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by now pay later place, I bet that they won't hesitate to file a
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judgment and that will negatively impact their credit. Ye. So if they have
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the ability to negatively impact credit, as you should have to be able,
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they should positive report possibly. Yeah, there's certainly a movement I see underfoot
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for more of the large payment obligations to be listen. I mean, like
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your cell phone bill, let's off not credit your rent utilities which you can
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aren't credit, but they're like consistently paying those is a good indication. And
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something that like is on is it superly valuable information from people making credit because
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rent is I own a house, my mortgage payments get reported. If I
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don't own a house, my rent payments, which are basically the same thing,
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don't get reported. And that just seems and there's ways obviously there are
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bureaus of reports US, but it's not commonly available right that. It's a
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topic I know on the underwriting side, because well, it's would help me
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get access to consumers that don't have thick files. And young consumers now are
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like very likely to stick with debit cards instead of credit cards. And I
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talked to some of them. They go, why I don't want to give
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myself the trouble to the credit card, Draff. I know, but you
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realize if you don't put anything on credit when you want to buy a car,
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you're gonna have no credit history. Here I can have a credit score
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that qualifies you for a loan, and they're like, I didn't know better.
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Good get that credit card. It is paid off. Let's pay it
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off everyone. Are there changes? Or when you look at this landscape,
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what are the things you advice you would give to banks about how I prepare
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what's coming ahead? How do I lay the foundation for being adopted? Like,
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what's the advice you would give to bankers in the space we're trying to
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be ready for, you know, the world that's coming ahead of us the
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next couple of years. I would say, just simply breathe. There is
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change coming. But we can't breathe. We can't seod advice. Okay,
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well, we can't control the pace yep, control what we can control and
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understanding. We can't boil the ocean. We can't get all of it done
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at once. So the pace is going to come. Change is going to
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come. We don't necessarily know land. I mean up with the exception of
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things like the small business room, chance having you're tired if you took the
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things free get hardy out there. But those are following the formal, formal
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rulemaking process. For those other things, we know they're going to come when
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they come. Breathe read it, and we heard something earlier today and it
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was actually the one of our forum sessions. Look through the tone, looks
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through the rhetoric that the press release has in it, and get to the
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underlying substantive issue and how that impacts your institution, not just the tone that's
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coming from DC, whether it's the CFPB, fd C, OCC, whomever's
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putting out the release. Really focus in on what they're trying to get at.
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Evaluate your product and service based on that, not on the they're just
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piling onto the industry part of it. We get that, look the underlying
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issue. It's funny you said breede. When I my original version of my
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notes, it doesn't say it here. Breathed was what I wrote out too.
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So that's and the other thing I would say is had staff now stay
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staffed up. Um, you know the paces that of a change for a
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while and you know so and be mindful of your genes and you know,
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make sure that they're breathing and that they're now thriving in this environment and invest
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in their well being. Um and um. You know the other thing weak
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or to Babe that I would say, it's continuing to focus on complete data.
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We've treed that from almost every average speaker and every four I wait by
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then, you know that is such a key to unlocking risks, and you
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know, you know the bureaus, we know agencies use it. So you
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know, continue to really mind that. And as more data becomes available,
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is more technologies, tools become available, leverage them to mind data because that
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is what you know. I think we'll be the key to getting in from
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out, Um, patricious, I get two things to fall up on both
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of your as We'll start with yours, which is Um, you talked about
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the underlying issues versus the tone. I noticed this recently and I'm curious that
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you have other examples of it. But like in there were losses brought by
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that the New York State, the appass and Attorney General against various auto automobile
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lenders, right, I remember reading the tone of the press release was like
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angry expensive loans and then I like, what what are they getting sued for?
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Oh, they didn't disclose fees. What's that's different than unafforded? There
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was like this kind of like message of we're unhappy, and certainly I told
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my team, like I know we're not doing the things that are wrong.
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But you should be looking at the tone too, because they are worried about
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putting people on affordable loans. But it was interesting to notice the difference and
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focus on what the press release might have said, what the statements were that
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we were unhappy about, and then you go, what were the actual findings
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of things that was done wrong? Yo, it was really lack of disclosures,
23:26
lack of clarity on that's a very different thing than unaffordable loans or ability
23:30
to repay. Even if that's some of the rhetoric that's that's coming out of
23:33
the top of that, it's interesting to see that those are not always aligned.
23:36
And how do you think about the value of what they're saying, which
23:38
tells you a little bit about where they're coming from, and the value of
23:41
what they're actually making an enforcement action about or giving advice about, which is
23:45
like it was a different thing sometimes than what's being said at the top of
23:48
them. Yeah, really absolutely, the words the tone go down to about
23:52
the third or fourth paragraph. Yeah, and you get two underlying issues.
23:56
Yes, right, so you can almost look at the release, Okay,
23:57
this is a company, this is how word salad word salad, word salad.
24:03
Here's what the real issue meets potatoes, the rights really no one,
24:04
Let's let's skip the appetizers, right and let's focus. Let's focus on the
24:08
main course. What is the what is the crux of the issue, and
24:12
how do we need to evaluate our processes, not the rhetoric. It's the
24:18
key issue, the key issues in the processes. I think the other thing
24:22
the Pamela Is said today was when you get to that meeting Potano's issue,
24:26
don't think of it a silo. Whenever you know, in your example it
24:29
was related to Ottoman, think about that across your portfolio and what they're really
24:33
saying there and look at your practice is against Yeah, it could be precursor
24:38
to what's some other access coming in maybe same day. They didn't disclose fees
24:42
correctly for a student loan or we don't have student loans. That doesn't apply
24:45
to us, No, we have loans. Stead of thing I wanted to
24:49
build on that you had mentioned, Jem was this um technology because the idea
24:56
that like I look at ten seventy one, I look at ten thirty three,
24:59
and there's a lot of this. It's like, it's not just process
25:00
change or rule change is like, Hey, we're going to need a technology
25:03
infrastructure that enables us to actually support new use cases, new requirements moving forward.
25:10
How do you think about the investments that you can be making today from
25:14
a data layering capabilities and technology abilities, say, this is what we're going
25:18
to need, whether it's evaluating complaints as you talked about today, or whether
25:22
it's getting ready for consumer access to financial records in the future, or collecting
25:27
ten seventy one small business data, Like, how do you think about making
25:32
sure the institution is prioritizing investing in the technology that enables you to do these
25:36
things that you're going to need to do, maybe not today, but before
25:40
too long, and you don't want to wait till the last minute. Start
25:41
that investment right and get off in front of that absolutely putinit Bree Moore and
25:48
one of the other things, you know, focusing ere ape, buyans and
25:51
risk you know, as you're going from those projects and partnering with folks not
25:55
only on the technicals rules and what doy do we have to submit, but
25:59
help we leverage that data to help identify other risks. So where can that
26:03
data be lanveraged throughout the organization to bring together monitoring opportunities and other things that
26:08
bad nature and you know, thinking about how powerful data can be and the
26:11
more of what we have I can bring into a riskless compliance or graps,
26:17
the better off will be. And staying you know, in the same lane
26:22
and admit the same speed as other folks. Is that a skill set you're
26:26
hiring for more in the risk in compliance areas like data analytics. I feel
26:29
like it's there's this h there's so much data now and it's so powerful,
26:33
but you have to have people who know how to interrogate it, understand it,
26:36
ask the right questions of it. It's usually not so simple as just
26:40
like there's a data it tells us something. It's like you gotta actually understand
26:41
how to like kind of ask the right questions of the data to find out
26:45
the insight you're looking for. And I'm curious, that's something you're putting in
26:48
house the on the compliance teams, so you have like a risk teams,
26:51
you have the ability to look at that directly, not relying on some data
26:53
analysts from a product or wherever. Yeah, we are, we are definitely
26:57
looking for folks as some folks on our team now who can sort of design
27:00
those queries and think about the data that's available and we or might that help
27:06
plus find risk for you know, even the good back to the basics was
27:10
another one on the concepts today. We're make sure you're doing the basics well,
27:14
so how can we leverage our data? Make sure we're doing that.
27:17
And we spend a lot of time with our data anthemetics teams as well,
27:19
and really have built great partnerships there too. They helpless chelge, you know,
27:25
we can sort of think of how to get at the data and then
27:26
they will help us build that and it's been a really fruitful partnership that we've
27:32
started to leverage in the compliance base. And we're not hiring directly for that
27:37
in our compliance organization, but we're hiring more for that in our organization as
27:41
a whole. And partnering with that group with our data analytics seems like this
27:45
is what we're looking for, This is what we're trying to get at.
27:48
These are the risks we're trying to vitigate. What do we have available?
27:51
How can we design that? And then we're focusing on taking those numbers and
27:53
trying to draw some conclusions and using our risk at risk experts for that.
27:57
And you know that getting back to base the mentor that use the phrase blocking
28:02
and tackling, you know, you can't do anything unless you block and back
28:06
when you get those base elements of your program, base elements of your data
28:08
sets and understanding what you have, and we'll really have a big focus on
28:14
that organizationally and getting those analytics teams up. Yeah. I love what you
28:18
said too about like getting in front of like here's what we're looking for and
28:22
why, because one of the things I've experienced is I've often sat like at
28:25
the interface of like the technical or data people in the business, but it's
28:27
like that's gonna want my career there, And so often I get a red
28:30
question from the business team to goes, I need X, and I go,
28:34
well, help me understand why. And then once I get to why,
28:38
I go, actually, you don't need X at all. That won't
28:41
answer the question you've got. You need why, and why is going to
28:45
get to the thing that you really need. But if you have an organization
28:48
or approach where you like to say, I neither set of data. Can
28:51
you give me a CSB with the stuff or graph this form and you go
28:53
sure, and they get post it back and it's like that may not actually
28:57
like the skill of saying hey can I and you'd understand what I'm trying to
29:00
understand what I'm trying to get at, so you can help me understand where
29:03
to look in my data and find that is so critical versus saying, hey,
29:07
can you give me a chart of this? I go sure, and
29:08
then you get the chart that actually didn't give you the insights you were looking
29:11
for. But you didn't use the people with the deep knowledge of the data
29:14
to help you find the best answer to the underlying question. You ask,
29:18
what's the right data set? What's the right source for the information? You
29:21
could have somebody working for weeks on a query out of your yeah, loan
29:25
servicing system, when an Excel sort of your humbler might give you exactly what
29:27
you needed. Right, Yeah, it's stop in five minutes. You understand
29:30
of what you're trying to get at is just as critical as that itself.
29:34
Yeah. Absolutely, any last thoughts before we before we break here on things
29:38
for the committee or key things on top of your mind for the next year.
29:42
I just think, buckle up, it's going to be a ride.
29:45
I mean man, everybody, everybody that's coming through this podcast is saying that
29:48
right now, it's a crazy year, you think, and I think we've
29:52
both been around for quite some time, and I can remember the biggest thing
29:56
you've unprephanded and sometime was ladd Frank rules and tread the servicing rules. Those
30:02
were massive, massive undertakings that were creating processes and practices that previously did not
30:10
exist, especially in services space. Yeah, there were no rules prior to
30:15
that, no formal regulatory, guidance, regulations, anything else. And that's
30:18
where we're heading in the ten seventy one right There is no rule right now
30:22
that is anything close to similar to this. I looked at in the PAP
30:26
that's folks on commercial ending. So it's not just okay, we can take
30:30
some dat amount and collected and report it. You have to build the infrastructure
30:34
first to get it, train people to ask for it. And it's going
30:37
to be at eighteen to thirty six month thing rodeo of getting our hands around
30:45
the data, getting our hands aut processes, the people, training systems,
30:48
the whole deal. And I think this is going to be one of the
30:51
most complicated things that we've had to implement maybe in our careers, and coupled
30:56
that with Mutters modernizing the commedia user rule that this will likely play into,
31:02
and we could have three separate data reporting rules going on at once if they
31:07
don't time this corrected between Honda, CIRA, and small business bumbas. So
31:11
it's going to be very complex just in those areas. Buckle up, all
31:15
right, I'll love with that. Then, I can't think of anything better
31:21
to say. Absolutely, buckle up. You have. You know what I
31:25
will add, Stay in touch with your colleagues are committee. I can now
31:30
talking through a lot of these more complex issues with your peers and even just
31:33
yaring there freezing the same challenges I think is helpful until really you know,
31:38
filter us networks and stay in touch with every model you know. It's piece
31:44
of advice i'd have. There is no competition and compliance. I like that
31:48
as a game. We enjed. That's a grade one liner to end one
31:51
nice shot man, there's no competition and compliance. Use your network. We're
31:55
all trying to get the same good things out there. Well, Jen Aaron,
31:57
thank you guys both for joining me. I really appreciated this was great.
32:00
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