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Banking’s Next Act: Regulatory Shifts Ahead · Leaders in Lending

• 0:04
  Speaker 1: Hi everyone, and welcome to Leaders in Lending. This is
• 0:08
  Speaker 1: Lynd Soderbiel. I'm happy to be joining you here today
• 0:10
  Speaker 1: from CBA Live, and I have Dave Palmeran and Billy
• 0:14
  Speaker 1: Riley joining me today, so thanks thanks for being here, gentlemen.
• 0:18
  Speaker 1: I would appreciate it if both of you could just
• 0:20
  Speaker 1: kind of introduce yourselves and what you do at CBA.
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  Speaker 2: Sure. Yeah, Hi everyone. David Palmer, I am a general
• 0:26
  Speaker 2: counsel and head of Regulatory Affairs at CBA, so I
• 0:30
  Speaker 2: deal a lot with the regulators in DC and of
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  Speaker 2: course with all the ongoing litigation around some of the
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  Speaker 2: former CFPB's rule bankings.
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  Speaker 3: And I'm Billy Riley, head of Public Affairs, so we
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  Speaker 3: handle messaging for the organization on behalf of our membership,
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  Speaker 3: work very closely with the regulatory and legislative teams in
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  Speaker 3: terms of policy communications, and also support broader corporate comms
• 0:52
  Speaker 3: and executive comms, including helping to set up this conference
• 0:56
  Speaker 3: and some of our other events like our Executive Banking School.
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  Speaker 1: Well great, thank you again, appreciate you taking the time
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  Speaker 1: to join us today. So i'd really just ask each
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  Speaker 1: of you to kind of give a brief overview obviously
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  Speaker 1: there's a lot of things changing in the market right
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  Speaker 1: now with the current regulatory and political environment, but just
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  Speaker 1: kind of a lay of the land, like where do
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  Speaker 1: you see things stand right now with the current environment
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  Speaker 1: out there, and how it's really impacting CBA members.
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  Speaker 2: Sure, yeah, I mean it's a very unique environment and
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  Speaker 2: it's changing by the minute. So any predictions we could
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  Speaker 2: give you probably are going to be wrong because they're
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  Speaker 2: going to change very rapidly right now. I mean, we're
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  Speaker 2: in this kind of limbo right where the new administram
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  Speaker 2: administration has come in a lot of executive orders, a
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  Speaker 2: lot of internal kind of rearranging of some of the agencies,
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  Speaker 2: and we're not quite sure where it's going to end
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  Speaker 2: up at this point. So we're working very diligently with
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  Speaker 2: the administration. We have new we have nominations for new director,
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  Speaker 2: we have nominations for a new comptroll or that are
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  Speaker 2: working their way through the Senate now, and so hopefully
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  Speaker 2: well once we get people in place in a permanent basis,
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  Speaker 2: there will be some think stability though that we can
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  Speaker 2: go and start talking to the individual agencies. We need
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  Speaker 2: the agencies to function, We need to know who we're
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  Speaker 2: dealing with right and the banks need to have certainty
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  Speaker 2: within the markets and the rules that they have to
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  Speaker 2: abide buying compliance issues. So there's a lot of question
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  Speaker 2: marks right now. There's a lot on people's minds, and
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  Speaker 2: so we're working through that and hopefully we'll again get
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  Speaker 2: to a better place in the near future.
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  Speaker 3: Yeah, I just add on that. I think the uncertainty
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  Speaker 3: is a big one, but it poses some we think positives,
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  Speaker 3: but also some potential headwinds. So obviously bankers know that
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  Speaker 3: the last four years in the prior administration in terms
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  Speaker 3: of some of the financial regulatory rules that came out,
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  Speaker 3: pos significant challenges for our members and kept us at
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  Speaker 3: CBA very busy. Obviously a lot of that is going away,
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  Speaker 3: or we think it is, and so in the sense
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  Speaker 3: and the positive sense, that may be a good thing.
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  Speaker 3: But we also have a political system right now with
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  Speaker 3: Republicans that may be a little bit more skeptical of
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  Speaker 3: large institutions, including large banks in particular with the rise
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  Speaker 3: of populism. So something else to keep an eye on,
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  Speaker 3: especially as it relates to Capitol Hill. But some of
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  Speaker 3: the proposals out there that maybe our banks won't be
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  Speaker 3: a supportive of.
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  Speaker 1: Sure, and I definitely hear you on the uncertainty. You know,
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  Speaker 1: we deal with We have over one hundred lenders of
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  Speaker 1: both banks and credit unions on our platform, and my
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  Speaker 1: team is actually supporting them through their regulatory exams and
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  Speaker 1: so that is a that and we deal with all
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  Speaker 1: of the regulators too, So certainty certainly helps us do
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  Speaker 1: a better job for our clients and helps our clients
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  Speaker 1: have a better understanding of what to expect. So, you know,
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  Speaker 1: with kind of the status of the CFPB right now,
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  Speaker 1: ongoing legislative debates, and and certainly states getting more active
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  Speaker 1: in the regulatory space, and potentially even more so if
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  Speaker 1: if the federal credential regulators kind of back off. You know,
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  Speaker 1: I think, how do you you know, how are banks
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  Speaker 1: adapting to these uncertainties and and what kind of advice
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  Speaker 1: are you giving your members on ways to stay kind
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  Speaker 1: of proactive and to at least navigate as smoothly as
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  Speaker 1: they can through this uncertainty.
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  Speaker 2: Yeah, I mean it's as Billy alluded to. I mean,
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  Speaker 2: a lot of the rules that they're currently gearing up
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  Speaker 2: for are you know, in limbo right now that could
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  Speaker 2: go away either through actions by Congress, actions by the
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  Speaker 2: agencies themselves or through litigation. Our banks are business as
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  Speaker 2: usual right now. I mean they're they're still beholden to
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  Speaker 2: the consumer protection laws and you know, and they're you know,
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  Speaker 2: complying with all of these things and regardless of whether
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  Speaker 2: or not the c FPB is and they're supervising them
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  Speaker 2: for any of these issues. Hopefully we'll get back to
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  Speaker 2: again a sense of stability on the supervisory side soon.
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  Speaker 2: The prudential banking regulators are supervisoring, supervising, holding, you know,
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  Speaker 2: examinations of those things, but a lot of the prep
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  Speaker 2: for things like ten seventy one small business data collection,
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  Speaker 2: this this is a huge poll for the industry, and
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  Speaker 2: they need to understand where that's going and what the
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  Speaker 2: bureau might do with it, what's going to be the
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  Speaker 2: outcome of the litigation, and so in large part, I think,
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  Speaker 2: you know, you have to plan for what we know now,
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  Speaker 2: and that's where they're going with this right now. But
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  Speaker 2: things could change on a dime and that cost compliance
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  Speaker 2: dollars obviously, which is not you know, ideal. But I mean,
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  Speaker 2: banks need to get back to what we're talking about,
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  Speaker 2: the certainty around some of the rule making, some of
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  Speaker 2: the compliance issues that they have right now in order
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  Speaker 2: to better function and quite honestly better serve the US public.
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  Speaker 1: Then sure, and I think you know we we certainly
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  Speaker 1: the clients that we work with are are many of
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  Speaker 1: them are not CB members. There are more, you know,
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  Speaker 1: regional community banks, and and the potential costs of uncertainty
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  Speaker 1: I think is hitting everyone hard, but certainly hitting them
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  Speaker 1: them hard as well. So I think one thing that
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  Speaker 1: that does stay in the spotlight, as you mentioned consumer
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  Speaker 1: protection and and how the you know, the banks are
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  Speaker 1: doing the things that they need to do to protect
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  Speaker 1: the consumer regardless of the rules, and the regulators are
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  Speaker 1: still doing their their regular exams, but late fees, overdraft
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  Speaker 1: fees certainly remain in the spotlight as well as SERIA
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  Speaker 1: modernization efforts and UH and lately some some UH I think,
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  Speaker 1: proposals to to get rid of CDFI as an organization.
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  Speaker 1: But you know, kind of with all of the different
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  Speaker 1: things happening, you know, what are some of the areas
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  Speaker 1: you think that that banks and financial institutions should really
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  Speaker 1: be paying special attentions to as it relates to some
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  Speaker 1: of those I think, particularly the consumer focus items like
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  Speaker 1: late FEZ rate caps, overdraft.
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  Speaker 2: I mean, these are all important issues. Clearly, this was
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  Speaker 2: part of the previous administration's junk fee campaign quote unquote
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  Speaker 2: junk fee campaign. I think it's been painted in a large,
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  Speaker 2: large part as a populist issue, and actually the cost
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  Speaker 2: benefit analysis wasn't really completed when it's when they were
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  Speaker 2: looking about how these rules actually could impact the US consumer.
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  Speaker 2: You know, what should our banks be looking for. I mean,
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  Speaker 2: as you know, with late fees and with overdraft fees,
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  Speaker 2: there's litigation in both those fronts. The overdraft fee rule
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  Speaker 2: is subject to a Congressional Review Act resolution currently in
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  Speaker 2: front of Congress, so you know how they are navigating again,
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  Speaker 2: it's you know, hope we have answers soon. I hope
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  Speaker 2: that we get back to a place where we have
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  Speaker 2: a durable, credible agency within the cfp B that's going
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  Speaker 2: to do cost benefit analysis rule making where there is
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  Speaker 2: a market failure. Right now, we're really just kind of
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  Speaker 2: combating all these rules that were more political in nature
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  Speaker 2: than really addressing a market failure. Some of our member institutions,
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  Speaker 2: for instance, an overdraft, they're the leaders and putting together
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  Speaker 2: mitigating ways for consumers to actually avoid overdraft fees. With
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  Speaker 2: buffer amounts, twenty four hour grace periods, things of that nature.
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  Speaker 2: Where was the market failure that you know, precipitated this
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  Speaker 2: this need for this kind of outlandish rule and so
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  Speaker 2: you know, that's what we're dealing with now. I am
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  Speaker 2: very hopeful that over the next year or so, we
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  Speaker 2: can see a lot of this litigation go away, get
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  Speaker 2: back to really appropriate rule making that's done within the
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  Speaker 2: confines of authority and not for political reasons.
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  Speaker 3: And just to add to that, so obviously David mentioned
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  Speaker 3: the Lafey and overdraft fees driven largely by the prior administration,
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  Speaker 3: and you also mentioned ratecaps, And we recently saw a
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  Speaker 3: proposal introduced in the House as a companion to a
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  Speaker 3: previous legislative proposal in the Senate, both of which had
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  Speaker 3: bipartisan support, seeking to limit bank in credit card issuer's
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  Speaker 3: ability to charge interest rates above ten percent, which is
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  Speaker 3: concerning for a lot of different reasons. And so that's
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  Speaker 3: something we're keeping our eye on because of the bipartisan
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  Speaker 3: nature of it, and one of the many ways that
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  Speaker 3: we're trying to push back on that here at CBA,
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  Speaker 3: whether in the media or through some of our blogs
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  Speaker 3: and op eds, is trying to show through data and
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  Speaker 3: research the impact that that would have on consumers and
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  Speaker 3: especially consumers at the margin and their access to credit,
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  Speaker 3: because a lot of times these legislative proposals make for
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  Speaker 3: good political headlines, but they have real world implications on
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  Speaker 3: the people we're working to serve.
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  Speaker 1: Yeah. Absolutely, and I think you both called it out
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  Speaker 1: that you know, doing a true data driven cost benefit analysis,
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  Speaker 1: what really will happen if you impact if you make
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  Speaker 1: changes like that, And the answer is that a lot
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  Speaker 1: of lenders simply won't be able to lend to, especially
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  Speaker 1: UH consumers. That I think when when we originally started
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  Speaker 1: our company, we're looking to expand access to credit and
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  Speaker 1: maybe identify what we saw as those hidden primes or
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  Speaker 1: near primes that the banks weren't reaching. And those folks
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  Speaker 1: are are easy to get kind of put out on
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  Speaker 1: the edges of the banking industry. Again, So what do
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  Speaker 1: you you know as you as you think about maybe
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  Speaker 1: the federal regulators being weakened a little bit, or being
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  Speaker 1: defunded or having less staff. Potentially, do you see a
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  Speaker 1: potential for individual states to create more kind of a
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  Speaker 1: patchwork of regulation that it makes it even harder for
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  Speaker 1: the Bank.
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  Speaker 2: It's a great point. Yeah, and we need a strong
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  Speaker 2: federal regulator to set you know, the kind of the
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  Speaker 2: path here. It's it's difficult for our member institutions to
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  Speaker 2: kind of piecemeal regulation and enforcement through different state actions.
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  Speaker 2: We're seeing a little bit of that now. I would
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  Speaker 2: imagine that you'll see more ramp up with the AGS,
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  Speaker 2: especially in blue states where if we don't have you know,
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  Speaker 2: proper supervision from the Bureau or from from the Prudentials. Again,
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  Speaker 2: we're really hopeful that the Bureau will start that process
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  Speaker 2: again and that we'll get back to a good place.
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  Speaker 2: There's also the private right of action for a lot
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  Speaker 2: of the enumerated statutes within Dodd Frank. So we are
• 11:35
  Speaker 2: somewhat concerned that you could see an uptaken you know,
• 11:38
  Speaker 2: lawsuits from the plane offs bar. But you know, that
• 11:42
  Speaker 2: wouldn't be anything new. The planet bar is going to
• 11:44
  Speaker 2: take advantage when it can take advantage of something. But
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  Speaker 2: I do think that we'll we'll probably get more action
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  Speaker 2: from the states as we move, you know, into the
• 11:52
  Speaker 2: near future. But again, I don't think that was anything
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  Speaker 2: particularly new. We saw that ramp up even with the
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  Speaker 2: Biden administration. Yeah, so I think that we'll see a
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  Speaker 2: little bit more of it down.
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  Speaker 1: Yeah, and that's definitely something you know, we certainly track
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  Speaker 1: a lot with like the legislation in Colorado and different
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  Speaker 1: and did MACA opt outs as are of challenging to
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  Speaker 1: manage when you're a company that works across the across
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  Speaker 1: the country. So you know, as you think though about
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  Speaker 1: protecting consumers insurance competition, do you see any tension between
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  Speaker 1: kind of those two things, like how are your banks
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  Speaker 1: on bank members staying competitive and with each other when
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  Speaker 1: there's certainly a lot of I think in a regulator
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  Speaker 1: d certainty and they also have to think about consumer protection.
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  Speaker 3: I can start with them, and I mean we always
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  Speaker 3: talk about how the banking industry in America is among
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  Speaker 3: the most highly regulated, most competitive in the world. Right,
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  Speaker 3: and so that really does benefit consumers in the sense
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  Speaker 3: that because of the regulatory apparatus, they can have confidence
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  Speaker 3: that they are being protected, that their money is safe
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  Speaker 3: and secure. But also with that many banks and credit
• 13:02
  Speaker 3: unions and also with the rise of fintech and tech
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  Speaker 3: companies that are increasingly offering financial services, consumers have amazing
• 13:10
  Speaker 3: ability to choose financial products and tools that meet their
• 13:13
  Speaker 3: unique needs, right and so I feel pretty confident, Dave.
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  Speaker 3: I think you would agree as well that this system
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  Speaker 3: really does provide so much flexibility and choice and access,
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  Speaker 3: and I think nowhere has that been more evident over
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  Speaker 3: the last decade than in overdraft. And you've seen so
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  Speaker 3: many of our members innovate on that product, offering financial
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  Speaker 3: flexibility and next day grace periods because you know, banks
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  Speaker 3: really want to meet consumers where they're at number one,
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  Speaker 3: but number two. The market is getting more competitive with
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  Speaker 3: other FinTechs and such that are offering are offering low
• 13:52
  Speaker 3: or no cost overdraft services, and so that competition, I
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  Speaker 3: think is benefiting consumers, and consumers can have that comp
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  Speaker 3: finance when they meet their needs within the well regulated
• 14:02
  Speaker 3: banking system, that they're also being protected.
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  Speaker 2: Yeah, I agree with all that, and I would add
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  Speaker 2: though that, you know, with the fintech industry or banking
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  Speaker 2: as a service as a model now becoming more and
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  Speaker 2: more popular, it's it's vital that our our member institutions,
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  Speaker 2: large regionals or national banks have the ability to innovate,
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  Speaker 2: aren't confined by the rules that are being written solely
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  Speaker 2: for them, right without having an equal playing you know,
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  Speaker 2: or a level playing field, for those those fintech companies
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  Speaker 2: and for you know innovators in that space. I mean,
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  Speaker 2: we're all for the innovation on either side, but we
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  Speaker 2: have to we have to be able to have the
• 14:43
  Speaker 2: flexibility to do that as well. And I'll i add
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  Speaker 2: too though, this is another reason the CPP is very
• 14:47
  Speaker 2: important because they have a supervisory theory over the non
• 14:51
  Speaker 2: banks and that is going to be vitally important going
• 14:56
  Speaker 2: into the next few years where we're having I think
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  Speaker 2: a larger up uptick in you know, banking as a
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  Speaker 2: service and FinTechs entering that space and partnerships.
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  Speaker 1: Sure, there's a there's a great story from the early
• 15:08
  Speaker 1: days of Upstart, where you know, I was founded by
• 15:11
  Speaker 1: ex Google executives primarily and people who had not worked
• 15:14
  Speaker 1: in banking, and in their exuberants to be part of
• 15:19
  Speaker 1: the industry and to be you know, friendly to regulators
• 15:23
  Speaker 1: and to get in front of them, showed up at
• 15:26
  Speaker 1: the OCC Office of Information in San Francisco and said, hey,
• 15:28
  Speaker 1: we want to tell you about what we're doing, very excited,
• 15:31
  Speaker 1: which was maybe the first time that that had happened
• 15:34
  Speaker 1: at an OCC office. And so we do work very
• 15:36
  Speaker 1: closely with the regulators, like we why we don't get examined,
• 15:39
  Speaker 1: our clients do, uh, And so we spend a lot
• 15:42
  Speaker 1: of time with the OCC and helping them understand and
• 15:45
  Speaker 1: and the FDAC and helping them understand how we use
• 15:47
  Speaker 1: AI and how we think about AI and how we
• 15:50
  Speaker 1: work with our bank partners. You know, I think is
• 15:54
  Speaker 1: that a space that you're particularly seeing probably more uncertainty
• 15:57
  Speaker 1: and maybe less of an even playing field where the
• 16:00
  Speaker 1: banks may be getting challenged harder on use of AI
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  Speaker 1: versus FinTechs and banking as as service providers can can
• 16:07
  Speaker 1: move a little bit faster.
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  Speaker 2: Well, it definite can move faster. I mean there's a
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  Speaker 2: lot about it. Banks have to be very measured in
• 16:12
  Speaker 2: their approach to any new technology, especially AI. I mean,
• 16:15
  Speaker 2: it's it's highly scrutinized, right, I mean, it's a little scary,
• 16:18
  Speaker 2: I mean to be honest with you, right, you know,
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  Speaker 2: and we do good regulation and sound law around the
• 16:24
  Speaker 2: use of AI, or it could go it could run amok, right,
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  Speaker 2: And so but you have the FinTechs that are able
• 16:30
  Speaker 2: to move a little faster, and that's not bad for
• 16:32
  Speaker 2: the banking industry as a whole, you know, as long
• 16:36
  Speaker 2: as we can partner and work with these these organizations.
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  Speaker 2: There's also third party risk management issues that you know
• 16:41
  Speaker 2: are abundantly you know, our banks are abundantly you know,
• 16:45
  Speaker 2: supervised and examined for and we encourage that innovation and
• 16:49
  Speaker 2: we but we have to be able to implement and
• 16:52
  Speaker 2: you know, partner or build that to be able to
• 16:55
  Speaker 2: do that ourselves as well. In order to make sure
• 16:58
  Speaker 2: that we're able to do that, we need to be
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  Speaker 2: very very measured in our approach to regulation. That only
• 17:04
  Speaker 2: affects you know, the banking industry and depository industries federally
• 17:09
  Speaker 2: ensured you know, FDIC positive industries, but the fintech industry
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  Speaker 2: plays a very important role in getting us to the
• 17:18
  Speaker 2: next level. And so we not saying that they shouldn't
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  Speaker 2: be able to do that. We just need to have
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  Speaker 2: far absolutely.
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  Speaker 1: Yeah, and I think fair lending particularly is an area
• 17:26
  Speaker 1: that comes up frequently that in a traditional underwriting model
• 17:29
  Speaker 1: is logistic regression whatever your you know, even table driven models,
• 17:33
  Speaker 1: or it is easier to explain or at least it's
• 17:37
  Speaker 1: already documented with the regulators. How do you examine a
• 17:40
  Speaker 1: bank that is using a model like this? How do
• 17:42
  Speaker 1: you examine a bank that is partnering with the fintech
• 17:45
  Speaker 1: that uses AI and their underwriting much less clear and
• 17:48
  Speaker 1: kind of gets back to your certainty, like the rules
• 17:51
  Speaker 1: of the road aren't as clear. I think there's certainly
• 17:54
  Speaker 1: a challenge with individual examiners not necessarily having the know
• 17:58
  Speaker 1: how to do it, and I think there's an education
• 18:01
  Speaker 1: challenge there that we're trying to This is a.
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  Speaker 2: Challenge in the current environment now too. I mean, you're
• 18:06
  Speaker 2: seeing a lot of the regulators leave the agencies. A
• 18:09
  Speaker 2: lot of the folks that were embedded within some of
• 18:12
  Speaker 2: these financial institutions knew them how to historical context of
• 18:15
  Speaker 2: the of the institution, and now we're seeing fewer and fewer,
• 18:19
  Speaker 2: you know, team staff at the regulatory agencies. The examiner,
• 18:25
  Speaker 2: the examiners are half of what they used to be.
• 18:28
  Speaker 2: They have to be brought up to speed, and so
• 18:30
  Speaker 2: it's important to have a really well educated, very informed
• 18:33
  Speaker 2: regulatory exam staff in order to make sure that banks
• 18:37
  Speaker 2: and FinTechs can get to these places and that they're
• 18:40
  Speaker 2: not being halted on something that's misunderstood just because the
• 18:44
  Speaker 2: regulator might not understand the process or the institution that's implementing.
• 18:49
  Speaker 1: Absolutely, So, how do you know, as you think about
• 18:52
  Speaker 1: your member banks, how do you advise kind of the
• 18:55
  Speaker 1: business teams, the lending teams, the heads of innovation, the
• 18:57
  Speaker 1: different different functional areas to work closely with their kind
• 19:01
  Speaker 1: of legal and public affairs team to navigate what's happening
• 19:04
  Speaker 1: right now in the market.
• 19:05
  Speaker 2: We provide no advice to anyone. No, I mean, I
• 19:09
  Speaker 2: mean quite clearly, I mean we're not. We're you know,
• 19:12
  Speaker 2: we try to shape the policy that best suits our
• 19:14
  Speaker 2: industry right and so, and we work very closely with
• 19:17
  Speaker 2: the policy folks within our member institutions, the legal teams.
• 19:20
  Speaker 2: You know, as a lawyer, I can say the lawyers
• 19:22
  Speaker 2: probably you know, hold up most of these things for
• 19:26
  Speaker 2: very when they shouldn't be. But you know that's what
• 19:29
  Speaker 2: lawyers do, and that's what we pay them to be careful.
• 19:31
  Speaker 2: But we you know, obviously it takes it takes a village,
• 19:36
  Speaker 2: you know, to kind of push you know, an organization forward.
• 19:39
  Speaker 2: And I think that you know, working closely with the
• 19:42
  Speaker 2: policy especially the folks in d C and now more
• 19:45
  Speaker 2: importantly you know, the state you know, policy folks and
• 19:49
  Speaker 2: the legal teams is vital to the survival of some
• 19:53
  Speaker 2: of these institutions and.
• 19:55
  Speaker 3: Just to add to that, I think over the last
• 19:57
  Speaker 3: four years, as difficult as some of the rules and
• 19:59
  Speaker 3: regulartions coming out of the prior administration were for the industry,
• 20:03
  Speaker 3: for especially the largest institutions, when the business lines really
• 20:08
  Speaker 3: got a sense of the financial impact that one specific
• 20:12
  Speaker 3: regulation among many would have on their ability to provide
• 20:16
  Speaker 3: that product and innovate on that product at the level
• 20:19
  Speaker 3: that their consumers expect, I think really heightened the pressure
• 20:23
  Speaker 3: that corporate executives across the industry put on DC. And
• 20:27
  Speaker 3: so you saw that Obviously government affairs and traditional lobbying
• 20:31
  Speaker 3: was always a priority, but that really expanded to the
• 20:34
  Speaker 3: public affairs ecosystem, and so you saw really historic levels
• 20:39
  Speaker 3: of investment with digital advertising, grassroots coalitions, grasstops, which really
• 20:45
  Speaker 3: means more paid stakeholder engagement. So identifying those small business
• 20:52
  Speaker 3: owners or some of those think tanks that can speak
• 20:55
  Speaker 3: on behalf of the industry. That really all revved up
• 20:59
  Speaker 3: over the last four year years, and I think there's
• 21:01
  Speaker 3: a perception that in many cases it was at least
• 21:04
  Speaker 3: somewhat successful. And so I think that kind of atmosphere
• 21:07
  Speaker 3: of the intersection between the business priorities outside of Washington,
• 21:11
  Speaker 3: and the teams on the ground in terms of public
• 21:14
  Speaker 3: affairs and government relations will continue regardless of who's in
• 21:18
  Speaker 3: the White House.
• 21:18
  Speaker 1: Great. Yeah, And I think we've certainly seen it on
• 21:20
  Speaker 1: the fintech side of the world too. The American Fintech Council,
• 21:23
  Speaker 1: which we're a founding member of we used to be
• 21:25
  Speaker 1: the Marketplace Lenders Association, were actively engaged there. I know
• 21:29
  Speaker 1: We've got a lot of some similar organizations that are
• 21:34
  Speaker 1: doing similar work and partnering up on various initiatives. So
• 21:39
  Speaker 1: I think it's it's definitely been a very very active
• 21:42
  Speaker 1: few years and doesn't look like things are slowing down
• 21:45
  Speaker 1: at all. So kind of last last thoughts are last
• 21:48
  Speaker 1: question for the both of you. You know, any kind
• 21:51
  Speaker 1: of bold or bold predictions, emerging issues, things that might
• 21:55
  Speaker 1: surprise us for the year ahead, that that banks should
• 21:57
  Speaker 1: be really preparing for, could both political and regulatory standpoint, like,
• 22:03
  Speaker 1: is there you know, with the uncertainty, what could they
• 22:05
  Speaker 1: prepare for to be ready for twenty twenty five?
• 22:08
  Speaker 3: You want to start to sure, I'll take you.
• 22:13
  Speaker 2: I'll take the Obviously, banks need to be able to
• 22:16
  Speaker 2: our member institutions need to be able to pivot quickly,
• 22:20
  Speaker 2: and I think us providing them with a little bit
• 22:23
  Speaker 2: of the kind of signals of where things are going
• 22:24
  Speaker 2: with some of the rulemakings and other things will be
• 22:27
  Speaker 2: helpful for them. But it's going it's it's just kind
• 22:30
  Speaker 2: of a new era. We're very dedicated to stopping that
• 22:35
  Speaker 2: pendulum swing between administrations. I think that we're going to
• 22:38
  Speaker 2: see a pretty big pendulum swing for the next two
• 22:40
  Speaker 2: years at least because Congress. They have majorities in Congress
• 22:43
  Speaker 2: and that might change in two years, and so they're
• 22:46
  Speaker 2: going to have a pretty healthy agenda going forward. So
• 22:49
  Speaker 2: it will be an interesting couple of years. I think
• 22:52
  Speaker 2: banks will enjoy some deregulation of in some wind back,
• 22:58
  Speaker 2: wind down of some of these more egregious rules that
• 23:00
  Speaker 2: we're quite honestly outside the authority of the regulators to
• 23:03
  Speaker 2: even promagate. But it's going to be We're going to
• 23:08
  Speaker 2: have to be very nimble right and be flexible about
• 23:12
  Speaker 2: our approach to how we're working with our regulars. But
• 23:14
  Speaker 2: I think we also need to advocate for what we
• 23:16
  Speaker 2: need the regulators for, and that is for to make
• 23:19
  Speaker 2: sure that the system is working, that we have level
• 23:21
  Speaker 2: playing fields, and that you know, quite honestly that you know,
• 23:25
  Speaker 2: we're proud of being the most regulated, are heavily regulated,
• 23:29
  Speaker 2: heavily supervised industry because you know, we were there for
• 23:32
  Speaker 2: the American public. It needs to be well regulated, well supervised,
• 23:36
  Speaker 2: and so hopefully we'll get back to some of that.
• 23:38
  Speaker 3: Yeah, just to add to what Dave said, I think
• 23:40
  Speaker 3: a lot of institutions right now in the financial services
• 23:43
  Speaker 3: space are, especially for reputational risks, trying to stay a
• 23:47
  Speaker 3: little bit more in the background, which is obviously an
• 23:49
  Speaker 3: intentional choice. We'll see if they're able to continue to
• 23:52
  Speaker 3: do that, and a lot of that depends on the
• 23:54
  Speaker 3: political environment. From a policy perspective, I think banks and
• 23:58
  Speaker 3: credit unions and FinTechs need to be prepared for what
• 24:03
  Speaker 3: seems to be more likely instance or a more likely
• 24:07
  Speaker 3: instance of legal framework being put around crypto and stable coins. Peers.
• 24:13
  Speaker 3: There's bipartisan consensus in the House and Senate to advance that,
• 24:16
  Speaker 3: and obviously you saw in the President's campaign huge coalition
• 24:21
  Speaker 3: of crypto and stable coin influencers and leaders, and that
• 24:26
  Speaker 3: seems to be something that is going to make progress
• 24:31
  Speaker 3: in the months to come.
• 24:31
  Speaker 1: Awesome. Well, thank you, thanks Dave, Thanks Billy, appreciate you
• 24:34
  Speaker 1: being on the podcast Today US