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Surviving the CFPB’s Transitional Era · Leaders in Lending

• 0:04
  Speaker 1: Hi, Welcome to Leaders and Lending. This is Lynd Souderbil.
• 0:08
  Speaker 1: We're joining you today from CBA live in Orlando, and
• 0:11
  Speaker 1: I have Aaron Rakowski and Mike Reynolds here joining us
• 0:15
  Speaker 1: on the panel. So Aaron, Mike, would you take a
• 0:18
  Speaker 1: minute to introduce yourselves and tell our listeners what you do?
• 0:22
  Speaker 4: Sure?
• 0:23
  Speaker 2: Hi, I'm Eron Kkowsky. I'm the Chief Compliance Officer for
• 0:25
  Speaker 2: West Banco, headquart in Wheeling, West Virginia. We're about a
• 0:29
  Speaker 2: twenty eight billion asset bank at the current time, with
• 0:33
  Speaker 2: offices in nine different states, and I'm responsible for all
• 0:37
  Speaker 2: of our regulatory compliance programs.
• 0:39
  Speaker 3: You, Mike you Reynolds, I'm Director of Compliance for Science
• 0:41
  Speaker 3: Bank Corporation. We're based in Salt Lake City, Utah, and
• 0:44
  Speaker 3: we're almost about one hundred billion in assets.
• 0:47
  Speaker 4: And Aaron and I realized leading up to this that
• 0:50
  Speaker 4: we live probably a couple hours apart in Ohio and
• 0:52
  Speaker 4: have met each other for the first time in Orlando, Florida,
• 0:55
  Speaker 4: which is always fine. And both of you are on
• 0:57
  Speaker 4: this CFPB committee for Sumer Bankers Association.
• 1:02
  Speaker 1: So can you kind provide our listeners with kind.
• 1:05
  Speaker 4: Of an overview and of how CBA and then its
• 1:08
  Speaker 4: members engaged with the CFPV.
• 1:09
  Speaker 2: Well, this was a lot clearer answer a couple of
• 1:12
  Speaker 2: months ago. Right now the jury's out. We really don't
• 1:17
  Speaker 2: know how we're engaging with the CFPV at present, you know,
• 1:19
  Speaker 2: given some of the some of the goings on in Washington.
• 1:22
  Speaker 2: But you know, ways that we have in the past
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  Speaker 2: is by having dialogue between the membership of CBA and
• 1:29
  Speaker 2: the CFPB, you know, interacting with that agency. And it's
• 1:32
  Speaker 2: really unique that we have a committee that is dedicated
• 1:35
  Speaker 2: to relationships between the banking industry and a particular regulator.
• 1:39
  Speaker 2: And I think that's what makes this committee unique. You
• 1:41
  Speaker 2: know this, the regulator has direct supervision authority over banks
• 1:46
  Speaker 2: with ten billion assets and larger and has it's a
• 1:49
  Speaker 2: unique structure. So having a committee that is able to
• 1:53
  Speaker 2: take the concerns of the association's memberships and have that
• 1:57
  Speaker 2: dialogue at times directly with the agency, see to provide thoughts, feedbacks, concerns,
• 2:02
  Speaker 2: you know, where we think that you know, some of
• 2:04
  Speaker 2: their their rulemaking or some of their their activities can
• 2:08
  Speaker 2: help benefit consumers and benefit our customers, and you know,
• 2:11
  Speaker 2: the membership and communities at largely, I think that that's
• 2:14
  Speaker 2: one of the ways we really try to engage, and
• 2:17
  Speaker 2: you know, we'd also get feedback from our membership to
• 2:20
  Speaker 2: provide input to the Consumer Bankers Association that they use
• 2:25
  Speaker 2: when they draft comment letters or when they have discussions
• 2:28
  Speaker 2: directly with the regulators as well. So in normal circumstances,
• 2:31
  Speaker 2: that's really how we have historically engaged. Right now, Jerry's.
• 2:37
  Speaker 3: Out, I would say for us, I mean there's still
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  Speaker 3: that ongoing or up until maybe two months ago, you know,
• 2:42
  Speaker 3: the touch points that we would have with the CPP.
• 2:44
  Speaker 3: I'm kind of focusing on what Aaron said to coming
• 2:47
  Speaker 3: together in our committee to then you know, discuss kind
• 2:49
  Speaker 3: of current trends, things that are going on with exams,
• 2:51
  Speaker 3: you know, or hotspots up until about two months ago.
• 2:54
  Speaker 3: But still you know, trying to abide by the law
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  Speaker 3: for what it is right now.
• 2:58
  Speaker 4: Sure, and I think you know, we a lot of
• 3:00
  Speaker 4: us have talked about that recently, just the uncertainty and
• 3:04
  Speaker 4: it's much more straightforward and easy to build a compliance
• 3:08
  Speaker 4: organization and a period of clear roles and clear oversight.
• 3:12
  Speaker 4: But you know, given the changes in the administration, uh,
• 3:17
  Speaker 4: this is probably it's a hard one to forecast. But
• 3:19
  Speaker 4: you know, if you had to say what you know,
• 3:21
  Speaker 4: what do you think is going to happen, And with
• 3:25
  Speaker 4: CFPB regulations in the year ahead, how do you think
• 3:28
  Speaker 4: that those may change and ways that impact the CBA members.
• 3:32
  Speaker 2: I think a lot of that depends on the time
• 3:35
  Speaker 2: frame and confirmation of a new director. So you know,
• 3:38
  Speaker 2: obviously there's an arum director and now there's been a
• 3:40
  Speaker 2: couple of them since the new administration has taken office.
• 3:45
  Speaker 2: But you're really understanding the thought process and priorities of
• 3:51
  Speaker 2: the administration and the new director and what that's going
• 3:54
  Speaker 2: to look like. So right now it's hard to forecast.
• 3:57
  Speaker 2: I know the current nominee for the director has experience
• 4:05
  Speaker 2: on the FDIC board, so he knows what it's like
• 4:08
  Speaker 2: to be a bank regulator, to be part of an agency,
• 4:12
  Speaker 2: to lead an agency, to manage through that. So what
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  Speaker 2: we're hoping for as members is we kind of get
• 4:17
  Speaker 2: back into common sense regulation. You know, enforcement. I believe
• 4:21
  Speaker 2: in enforcement, I believe in supervision. But enforce the regulations
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  Speaker 2: as they are as they're written, examine based on the
• 4:28
  Speaker 2: exam manuals as they are and as they're written, and
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  Speaker 2: have that transparent dialogue with your banks when you're in there.
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  Speaker 2: You know, part of my background, I'm an next examiner.
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  Speaker 2: I was an FDIC examiner years ago, and that was
• 4:39
  Speaker 2: always the mentality that I took. You know, here's the
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  Speaker 2: exam manual, here's the rule. How are you complying with this?
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  Speaker 2: So when we're talking about supervision regulation, you know, I
• 4:47
  Speaker 2: would look for and expect the agency to adhere to
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  Speaker 2: the rules as they're written and follow their exam manuels.
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  Speaker 2: At least that would be the whole Yeah.
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  Speaker 3: That's squat point. I mean, we still have to apply
• 5:00
  Speaker 3: with rules that are codified you know currently, and all
• 5:02
  Speaker 3: of these pending rules that are still under the Congressional
• 5:05
  Speaker 3: Review Act, you know, and we have some time still
• 5:07
  Speaker 3: to go for some of those. I mean, it's still
• 5:09
  Speaker 3: status quo for us. It's nothing normal. And I would
• 5:11
  Speaker 3: say even since twenty twenty when COVID hit and we
• 5:14
  Speaker 3: had a bunch of regulatory reform because of consumer harm
• 5:17
  Speaker 3: and whatnot, you know, I mean, it's just, you know,
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  Speaker 3: business is usual for us right now.
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  Speaker 4: So sure, sure, yeah, And we you know, we work
• 5:24
  Speaker 4: within a number of banks and credit unions on our platform,
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  Speaker 4: some banking as a service providers, some traditional banks that
• 5:30
  Speaker 4: originate and retain as well as credit unions. And so
• 5:34
  Speaker 4: while we're not directly regulated by the prudential regulators, you know,
• 5:38
  Speaker 4: we do get state examines examinations, and we support a
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  Speaker 4: variety of examinations, and we you know, had a partnership
• 5:44
  Speaker 4: with the CFPP for a period of time. And I
• 5:48
  Speaker 4: think that's the one thing I was talking to some
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  Speaker 4: other folks earlier, that the banks don't want to do
• 5:53
  Speaker 4: consumer harm, right, like you can't harm your customer, you
• 5:57
  Speaker 4: still need will do those things even in the absence
• 5:59
  Speaker 4: of CFPV may be coming in. So, you know, if
• 6:03
  Speaker 4: the CFPP, if some of the trends towards defunding and
• 6:07
  Speaker 4: decreasing the size of the CFPB and even some of
• 6:10
  Speaker 4: the other regulatory agencies continue or accelerate, even anything that
• 6:15
  Speaker 4: you can see on like broader implications for what that
• 6:17
  Speaker 4: means for the banking industry as a whole.
• 6:19
  Speaker 2: Well, if they see kind of a shrinking of the
• 6:22
  Speaker 2: exam workforce, I think that that'll depending on how they
• 6:26
  Speaker 2: go about that. I think you could see a lot
• 6:28
  Speaker 2: of broad implications. They're both for consumers and consumer protection regulation,
• 6:33
  Speaker 2: but also safety and soundness of risk management examinations. You know,
• 6:36
  Speaker 2: the way Typically these things happen is they look at
• 6:39
  Speaker 2: seasoned examiners at the top of the pay scale and
• 6:41
  Speaker 2: offer them, you know, early retirement options, or you look
• 6:44
  Speaker 2: at people that are coming up through the ranks and
• 6:46
  Speaker 2: maybe going through various schools and training and onboarding that
• 6:50
  Speaker 2: have not earned their commission yet to write exams, and
• 6:53
  Speaker 2: they maybe let go. They may be probationary employees or
• 6:55
  Speaker 2: ones that have not fully gone through the education and
• 6:58
  Speaker 2: onboarding process, so the exams have to happen, right, you know.
• 7:02
  Speaker 2: From the credential regulatory side, you know there's rules that
• 7:06
  Speaker 2: you have to come in every so often to look
• 7:09
  Speaker 2: at consumer compliance, to look at community reinvestment, to look
• 7:12
  Speaker 2: at fair lended compunts with fair lending laws. And you know,
• 7:15
  Speaker 2: a reduced examination workforce is going to leave less resources
• 7:18
  Speaker 2: to examine banks, but you also lose that relationship that
• 7:24
  Speaker 2: you've built with your regulators. You know, the end goal
• 7:28
  Speaker 2: is a safe and sound banking system, a safe and
• 7:31
  Speaker 2: sound bank, and nobody wants to do harmon consumers. You
• 7:34
  Speaker 2: have been in banking over twenty years and never once
• 7:36
  Speaker 2: have I been in a room where somebody said, well,
• 7:37
  Speaker 2: let's how much in fees can we get on this
• 7:39
  Speaker 2: or how can we really you know, do something other
• 7:42
  Speaker 2: than what's in the best interest of our customers. But
• 7:47
  Speaker 2: you know, you still have you know, the regulatory side,
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  Speaker 2: and people need to come in, and a lack of
• 7:54
  Speaker 2: experienced examiners that don't have the institutional knowledge, that don't
• 7:58
  Speaker 2: have that relationship with management, can't have those sometimes hard
• 8:02
  Speaker 2: conversations how did you think this through? Why are you
• 8:04
  Speaker 2: doing this this way? It could lead to things that
• 8:09
  Speaker 2: don't get caught, or it could lead to questions that
• 8:12
  Speaker 2: don't get asked or issues that don't get resolved. So
• 8:15
  Speaker 2: you know, when I would look at this, like you know,
• 8:17
  Speaker 2: anybody would listen to me anyway, But I would say,
• 8:19
  Speaker 2: you know, just kind of proceed with caution when you
• 8:21
  Speaker 2: look at right sizing, if that's the right term, an
• 8:24
  Speaker 2: examination workforce, to make sure you still have the right
• 8:27
  Speaker 2: people looking at the right things on the right frequency.
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  Speaker 3: And I would say that even though there's a roll
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  Speaker 3: right now, you know, from that perspective, I mean, we're
• 8:34
  Speaker 3: still gearing up for potential state regulation then to kind
• 8:37
  Speaker 3: of come in and swing. We've got you know, the
• 8:40
  Speaker 3: midterms coming up. I would say in about a year
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  Speaker 3: and a half and so that may be another pendulum
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  Speaker 3: swing that we have to then prepare for, or a
• 8:46
  Speaker 3: moot house where you know, there's a lot to be
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  Speaker 3: unexpected I think right now.
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  Speaker 4: So yeah, and I think that the impact of a
• 8:55
  Speaker 4: patchwork of state regulations that may be very strong would
• 8:58
  Speaker 4: be very difficult to deal with. You know, even for
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  Speaker 4: a fintech like ours that lends nationally or works with
• 9:03
  Speaker 4: banks to lend nationally, those state regulations can be very
• 9:07
  Speaker 4: difficult for us to manage our business and understand volume
• 9:09
  Speaker 4: and and ensure that we're we're applying them, like the
• 9:12
  Speaker 4: Colorado UH law, if we had to put that into effects,
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  Speaker 4: you know, and spending time and money and and certainly
• 9:18
  Speaker 4: a time and money expends on banks for for especially
• 9:22
  Speaker 4: with uncertainty and less clear I really liked it you said, though, Aaron,
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  Speaker 4: about less experienced examiners and kind of the team where
• 9:30
  Speaker 4: you know, they really maybe knew the bank partnership and
• 9:33
  Speaker 4: and had insight there, particularly as it relates to say,
• 9:37
  Speaker 4: you know, use of AI partnerships with FinTechs UH or
• 9:41
  Speaker 4: or new technologies.
• 9:43
  Speaker 1: You know, what would.
• 9:44
  Speaker 4: You you know, one with some of the changes in
• 9:48
  Speaker 4: the regulatory bodies right now, like what do you think
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  Speaker 4: the risks are there in their ability to oversee those?
• 9:55
  Speaker 4: And I guess I would say too, like, you know,
• 9:57
  Speaker 4: how how can the cb I members think about working
• 10:03
  Speaker 4: with them to maybe help educate them on the new
• 10:05
  Speaker 4: technologies or partnerships that they have.
• 10:07
  Speaker 2: It's a very broad question. So I think here AI
• 10:11
  Speaker 2: is becoming more prevalent. General of AI is becoming more prevalent,
• 10:14
  Speaker 2: and I think that banks and through that through just
• 10:19
  Speaker 2: using it directly, developing it directly, or partnering with FinTechs
• 10:22
  Speaker 2: offering it directly. You know, they're looking to find ways
• 10:25
  Speaker 2: to go to market and work with their customers in
• 10:28
  Speaker 2: the most efficient way possible, and this is kind of
• 10:30
  Speaker 2: a way to do that. Really, looking at the risks
• 10:33
  Speaker 2: of AI, it's to me, you know, starting with your
• 10:37
  Speaker 2: third party management or risk management program and being sure
• 10:40
  Speaker 2: you understand what the what the service is, what the
• 10:44
  Speaker 2: AI can do, what the variables are, because again, the
• 10:48
  Speaker 2: the compliance risk is always there and it's still there,
• 10:51
  Speaker 2: ends Mikey mentioned earlier, the codified rules and regulations are
• 10:53
  Speaker 2: still there. We still have an you know, upstarting the
• 10:56
  Speaker 2: lending space and looking at AI and Algareth algorithms used
• 11:01
  Speaker 2: in lending for automated decision and approval. You still have
• 11:05
  Speaker 2: to ensure that those models that you're using, the AI
• 11:08
  Speaker 2: you're using is operating fairly. You know those rules and
• 11:13
  Speaker 2: those laws. Equal credit opportunity does not go away. You
• 11:16
  Speaker 2: know you're still going to be examined for it. You
• 11:18
  Speaker 2: still have your prudential regulators that can look at fair
• 11:21
  Speaker 2: housing if you're in the mortgage space and using some
• 11:23
  Speaker 2: AI to help with your decision making. So you know,
• 11:26
  Speaker 2: the basic blocking and tackling of your compliance program does
• 11:29
  Speaker 2: not change regardless of you know, the political environment or
• 11:33
  Speaker 2: the regulatory environment. And just be honest, because things ebb
• 11:37
  Speaker 2: and flow. You know, we've seen a lot of ebb
• 11:39
  Speaker 2: and flow over the last ten years as far as
• 11:42
  Speaker 2: which administration is currently sitting in the White House or
• 11:44
  Speaker 2: which administration or which party is currently controlling Congress. You
• 11:49
  Speaker 2: see swings back and forth. So the rules are still
• 11:52
  Speaker 2: the same. And making sure that you're doing your own
• 11:56
  Speaker 2: due diligence and understanding how these things are working. It's
• 12:00
  Speaker 2: central to what we're trying to do from a compliance
• 12:02
  Speaker 2: perspective in how we govern the use of AI in
• 12:06
  Speaker 2: our banks and in our shops.
• 12:07
  Speaker 3: That's a great point. I mean it's specifically talking about
• 12:09
  Speaker 3: AI and you know, focusing on operational effectiveness kind of
• 12:13
  Speaker 3: in this lull from a regulatory perspective that we're in.
• 12:15
  Speaker 3: I mean, you still think that, you know, these fraudsters
• 12:18
  Speaker 3: out there are using fourth generation bots as we move
• 12:20
  Speaker 3: into fifth generation technology and things like that where they're
• 12:23
  Speaker 3: starting to dart smell or outsmart the banks. As Aaron mentioned,
• 12:27
  Speaker 3: you know, we have to be very up on these
• 12:28
  Speaker 3: different models or things that you know, then AI is
• 12:31
  Speaker 3: coming out with and then being able to kind of
• 12:33
  Speaker 3: defraud the fraudsters. So also focusing on you know that
• 12:36
  Speaker 3: operational effectiveness and reducing operational or you know, losses.
• 12:41
  Speaker 4: And I certainly think with the technology, you know, becoming
• 12:44
  Speaker 4: more sophisticated in the growth of and use of AI
• 12:47
  Speaker 4: in various forms, whether it's the way that we use
• 12:50
  Speaker 4: it or generative AI. Getting field examiners up to speed
• 12:55
  Speaker 4: and trained, or people at the regulatory bodies, especially if
• 12:58
  Speaker 4: they're they're shrinking and and and more experienced examinators are
• 13:03
  Speaker 4: rolling off IS is only going to be more of
• 13:05
  Speaker 4: a challenge.
• 13:07
  Speaker 2: Absolutely, you know, when we're having these discussions and what
• 13:09
  Speaker 2: we've been having for the last several years with our regulators.
• 13:12
  Speaker 2: Is our use of AI and is how our governance
• 13:14
  Speaker 2: processes work? And what does our oversight look like? And
• 13:17
  Speaker 2: how does that integrate? You know, like Mike you mentioned
• 13:19
  Speaker 2: you have to outfraud the fraudsters. You know, the fraudsters
• 13:22
  Speaker 2: are out there, they're using AI to counter our AI.
• 13:25
  Speaker 2: So how do those interplay? And you know, our examiners
• 13:28
  Speaker 2: have been with us as we've gone down this journey
• 13:31
  Speaker 2: understanding how we're making these decisions. We're making the due diligence,
• 13:36
  Speaker 2: we're doing the testing, we're doing the evaluation of the results,
• 13:40
  Speaker 2: and you know, the loss of that experience and the
• 13:43
  Speaker 2: loss of the folks that have gone on that journey
• 13:45
  Speaker 2: with us, I think that would be a blow for
• 13:47
  Speaker 2: us and how we serve our customers and how we
• 13:52
  Speaker 2: protect our customers because you know a lot of AI too.
• 13:54
  Speaker 2: It's not just granting loans and giving credit. We use
• 13:58
  Speaker 2: a lot of AI on the back end to monitor
• 14:00
  Speaker 2: for fraud and different different things there. So you know,
• 14:04
  Speaker 2: the examiners that have kind of grown up with us
• 14:06
  Speaker 2: in this space, them not being there could really be
• 14:09
  Speaker 2: detrimental with some of our efforts and having to bring
• 14:12
  Speaker 2: newer ones up to speed on what we're doing. It
• 14:15
  Speaker 2: could be time consuming and really put a damp on
• 14:19
  Speaker 2: some of our efforts.
• 14:20
  Speaker 4: Yeah, you know, we've certainly spent you know, despite not
• 14:23
  Speaker 4: being a bank or having a bank as part of
• 14:26
  Speaker 4: our organization, We've spent a lot of time with the
• 14:28
  Speaker 4: regulators over the years, and I've met with the FDAC,
• 14:32
  Speaker 4: along with our head of government Affairs and our chief
• 14:34
  Speaker 4: risk officer and the OCC and so we've taken the
• 14:37
  Speaker 4: stands as a fintech to be very proactive in our
• 14:40
  Speaker 4: regulatory outreach and to kind of open our doors and
• 14:43
  Speaker 4: try to help drive that education forward. And knowing that
• 14:47
  Speaker 4: then we're working with all of our bank and credit
• 14:48
  Speaker 4: union partners to support their exams. And it is a
• 14:52
  Speaker 4: it is a constant. There's the I think volume and
• 14:55
  Speaker 4: velocity of information right now and changes is very high
• 15:00
  Speaker 4: compared to, uh, you know where it may have been
• 15:03
  Speaker 4: several years ago. How do you think about on your
• 15:08
  Speaker 4: committee through the CBA, staying up to speed with what's
• 15:12
  Speaker 4: happening with the CFPB and then using that to help
• 15:16
  Speaker 4: put of educate your members or drive your agendas internally.
• 15:20
  Speaker 3: Yeah, I can go for it. First, I would say specifically.
• 15:23
  Speaker 3: I mean as we even share these secrets, you know,
• 15:25
  Speaker 3: across the committee members and whatnot, we try to focus
• 15:28
  Speaker 3: more on sharing what I think are best practices and
• 15:31
  Speaker 3: still building up maybe are our CSA you know, cosa
• 15:34
  Speaker 3: framework CMS, you know, frameworks and things like that. To
• 15:37
  Speaker 3: then better be able to attack these types of things.
• 15:39
  Speaker 3: You know, you have to have a skilled staff. And
• 15:41
  Speaker 3: as we talk about, you know, potentially you know, lead
• 15:44
  Speaker 3: examiners that have many years of service and many years
• 15:46
  Speaker 3: of experience kind of going off. I mean, we have
• 15:48
  Speaker 3: a new generation I think that will eventually come in
• 15:51
  Speaker 3: where they have a little bit more of these heightened
• 15:53
  Speaker 3: skill sets too.
• 15:54
  Speaker 2: So yeah, and I think you're engaging with through our committee.
• 15:57
  Speaker 2: You know, obviously there's some things we can talk about,
• 15:59
  Speaker 2: there's some things we can can't talk about. But what
• 16:01
  Speaker 2: I think is unique about the compliance and risk community
• 16:04
  Speaker 2: is there's no competition in compliance, right. You know, everybody
• 16:08
  Speaker 2: has to comply with the rules they apply across the
• 16:11
  Speaker 2: board to all of us. And you know, when you
• 16:13
  Speaker 2: look at the discussions we have, what is working, what
• 16:16
  Speaker 2: is not working? How do we risk assess certain practices?
• 16:19
  Speaker 2: What are the things you consider in your risk assessment?
• 16:22
  Speaker 2: That I might not consider in mind and vice versa.
• 16:24
  Speaker 2: So you know, these are things where we're talking about
• 16:27
  Speaker 2: the framework of our compliance management programs and getting best
• 16:33
  Speaker 2: practices from each other and how we navigate through you know,
• 16:37
  Speaker 2: anytime really, but really through uncertain times like this. What
• 16:41
  Speaker 2: this is the time you might use term law. I
• 16:43
  Speaker 2: think it's that you know, right now, we're not hearing
• 16:45
  Speaker 2: as much from our regulators, so it's a time to pause,
• 16:50
  Speaker 2: breathe after what we've seen the past several years with
• 16:53
  Speaker 2: the volume and pace of change, and shore up our
• 16:58
  Speaker 2: compliance programs, not that they were you know, substantids to
• 17:02
  Speaker 2: start with, but take the take the time to you
• 17:05
  Speaker 2: kind of go through and you know, button up things
• 17:09
  Speaker 2: that you know may not have gotten as much attention
• 17:12
  Speaker 2: because we're focusing on other issues, or better document some
• 17:16
  Speaker 2: of our processes and some of our methodologies and different things.
• 17:19
  Speaker 2: So this is a good time for us to collaborate
• 17:22
  Speaker 2: and kind of talk through what we're what we're seeing,
• 17:25
  Speaker 2: and where we want to go from here.
• 17:26
  Speaker 3: I would even say that it's still you know, an
• 17:27
  Speaker 3: emphasis for us to focus on our other regulatory bodies
• 17:30
  Speaker 3: that really aren't having a lot of fluctuation right now
• 17:32
  Speaker 3: many of us are larger institutions that are regulated by
• 17:34
  Speaker 3: the OCC the FDIC, so there's still that oversight lunction there.
• 17:39
  Speaker 4: True. True, it's we're kind of focused on the c
• 17:42
  Speaker 4: FPB in this conversation that there's certainly the rest and
• 17:46
  Speaker 4: then all the states as well. I really like that
• 17:49
  Speaker 4: that idea of like that's you know, if you if
• 17:51
  Speaker 4: you are having a little bit of a lull or
• 17:53
  Speaker 4: a little bit of quietness, like taking the time to
• 17:56
  Speaker 4: you know, kind of revisit your you know, make sure
• 17:58
  Speaker 4: your house is in order to make sure you're doing
• 18:00
  Speaker 4: anything else. I guess any maybe kind of bold predictions
• 18:05
  Speaker 4: for you know, what you expect to see from the
• 18:07
  Speaker 4: CFPB over the next I'll just say a few months
• 18:11
  Speaker 4: or even quarter. We'll make it short, because I think
• 18:13
  Speaker 4: even trying to do a year is probably unreasonable at
• 18:16
  Speaker 4: this point.
• 18:17
  Speaker 2: I think it's really hard to tell. I mean, I
• 18:19
  Speaker 2: think that we're my personal prediction. I think, you know,
• 18:23
  Speaker 2: there's the rules that they've put out. You know, some
• 18:26
  Speaker 2: of the final rules they're subjects of congressional review, but
• 18:28
  Speaker 2: some of them aren't right, So maybe we focus on
• 18:30
  Speaker 2: the known at this point. So I think the ten
• 18:33
  Speaker 2: seventy one small business rule that's out there. There's litigation
• 18:37
  Speaker 2: around that, but I think the CFPB has to finalize that.
• 18:41
  Speaker 2: You know, it's something that there is a consent order,
• 18:44
  Speaker 2: and I think a lot of people forget, well maybe
• 18:45
  Speaker 2: they can just go away. No they can't. I mean
• 18:48
  Speaker 2: court is forcing them. You have to do this. But
• 18:51
  Speaker 2: I think a prediction from me on that side might
• 18:54
  Speaker 2: be we see a new proposal that subsequently changes what
• 18:59
  Speaker 2: the requirement are going to be, because I think that's
• 19:01
  Speaker 2: been where the industry and the Bureau have but heads
• 19:04
  Speaker 2: a little bit. Is Dodd Frank says thou shalt collect
• 19:07
  Speaker 2: this cefpb's rules, So thou shalt collect this plus all
• 19:11
  Speaker 2: of these other things as well. So I think that
• 19:13
  Speaker 2: we may see a proposal that shifts more towards what's
• 19:16
  Speaker 2: in the Dodd Frank Act itself there, and I do
• 19:19
  Speaker 2: think we'll see continued movement on ten thirty three. You know,
• 19:23
  Speaker 2: the open banking rule. I don't think that's going to
• 19:25
  Speaker 2: go anywhere, because I think that that's something where it's
• 19:28
  Speaker 2: going to open up information flow between between banks, between
• 19:31
  Speaker 2: banks and FinTechs, between FinTechs and fintexts. And that aggregators
• 19:34
  Speaker 2: and different things. So that has the potential to really
• 19:37
  Speaker 2: change how we do business. And I think that that's
• 19:41
  Speaker 2: not something that this administration will likely touch. So I
• 19:45
  Speaker 2: think that that's going to be, you know, something that
• 19:48
  Speaker 2: is going to move on status quo. So I think
• 19:50
  Speaker 2: that's going to stay status quo. But I think we'll
• 19:52
  Speaker 2: see a new proposal. In ten seventy one.
• 19:54
  Speaker 3: Aaron hilarious or hilariously pulled out a magic eight ball
• 19:57
  Speaker 3: in one of the sessions that he moderated earlier in them,
• 19:59
  Speaker 3: and I would say that that's exactly.
• 20:00
  Speaker 1: An actual magic eb all.
• 20:01
  Speaker 2: Again in liter I brought a literal magic that's great.
• 20:04
  Speaker 3: Yeah, And I mean that really is kind of the
• 20:06
  Speaker 3: environment that we're in. And I'll just emphasize maybe on
• 20:08
  Speaker 3: what Aaron said is that, you know, ten thirty three,
• 20:10
  Speaker 3: I think that's one of the bigger ones that we're
• 20:12
  Speaker 3: still going to see an emphasis and focus on. And
• 20:14
  Speaker 3: it's more about the potential for future acquisitions of customers.
• 20:19
  Speaker 3: You know, it's not just about you know, creating less
• 20:21
  Speaker 3: barriers for customers to be able to then see their
• 20:23
  Speaker 3: data across multiple institutions. It's also to then be able
• 20:26
  Speaker 3: to create, you know, some competition within the market and
• 20:29
  Speaker 3: then kind of start to you know, really pull into
• 20:32
  Speaker 3: folks the fact that you want to increase your volumes
• 20:34
  Speaker 3: for both deposits, loans, et cetera, you know, within your institution.
• 20:37
  Speaker 4: So well, thank you, Aaron, Mike. Appreciate you joining us
• 20:40
  Speaker 4: today and taking the time out of your schedules to
• 20:42
  Speaker 4: chat with this a leader's blending.
• 20:44
  Speaker 2: It's been a pleasure.
• 20:45
  Speaker 3: Thank you.