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Navigating Fair Lending Challenges Through Collaboration and AI · Leaders in Lending

• 0:04
  Speaker 1: Hello.
• 0:04
  Speaker 2: This is Lynd Soderbiel and welcome to Leaders in Lending.
• 0:08
  Speaker 2: I'm joining you here from CBA live in Orlando, and
• 0:11
  Speaker 2: we have Lindsay Yusf and Nick Rustler from the Fair
• 0:15
  Speaker 2: and Responsible Banking Committee. Lindsay and Nick, can you introduce
• 0:18
  Speaker 2: yourself and tell us a little bit about your background.
• 0:21
  Speaker 1: Sure, I'm Lindsay yus If. I'm the executive Compliance Director
• 0:24
  Speaker 1: at ALI and also the fine or the Fair and
• 0:27
  Speaker 1: Responsible Banking Officer. In addition, I am the vice chair
• 0:31
  Speaker 1: of the Fair and Responsible Banking Committee for the CBA.
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  Speaker 1: So I have been in banking for about twenty four
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  Speaker 1: years now and have worked in all different areas, mostly
• 0:41
  Speaker 1: with CIRE Fair Lending and formerly as a chief compliance officer.
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  Speaker 3: Hi.
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  Speaker 4: Nick Raisler M and T Bank Fair and Responsible Banking
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  Speaker 4: Officer there and I've been in banking for a while
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  Speaker 4: as well, mostly in fair lending, UDAPT spaces as well
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  Speaker 4: as audit risk management. And I'm a former examiner with
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  Speaker 4: the Federal Reserve Bank as well as the chair of
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  Speaker 4: the CBA Fair Responsible Banking Committee.
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  Speaker 2: Awesome, well, great for joining Thank you for joining us again.
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  Speaker 2: We did this last year, so it's nice to have
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  Speaker 2: you back two years in a row, so I think
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  Speaker 2: interesting that being a former examiner as well, but both
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  Speaker 2: of you having extensive banking experience. The environment now, both
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  Speaker 2: the economic environment and kind of consumer regulatory environment is
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  Speaker 2: rapidly changing and uncertain in a lot of ways. What
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  Speaker 2: are some ways that you see banks and CBA members
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  Speaker 2: working with their external partners, like a fintech partner, to
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  Speaker 2: meet both regulatory expectations but also really drive innovation for
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  Speaker 2: their consumers.
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  Speaker 4: Well, one way I think, just in general, I think
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  Speaker 4: like partnerships right now, with a lot of uncertainty with expectations,
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  Speaker 4: is that can be a fair amount of benchmarkting that
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  Speaker 4: could be really helpful for a provider to kind of
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  Speaker 4: come in and say, Okay, what's the view of the
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  Speaker 4: industry here, and what sort of technologies might be emerging
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  Speaker 4: use cases and things like that to kind of consider
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  Speaker 4: and then kind of anyone's guess. It's anyone's guest in
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  Speaker 4: terms of like will.
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  Speaker 3: This meet future regulatory expectations.
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  Speaker 4: I think there's a lot of a lot of you know,
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  Speaker 4: sort of question marks there. But I think one thing
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  Speaker 4: that you want to do as an institution is is
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  Speaker 4: not be an outlier, right so I think it while
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  Speaker 4: it's there's a little bit of a safety's number, safety
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  Speaker 4: in numbers, but while that's not really the goal is
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  Speaker 4: to be like Okay, we want to be like everyone else.
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  Speaker 4: I think that's one kind of foundational area where I think,
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  Speaker 4: you know, a third party or you know, a fintech
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  Speaker 4: partner can come into play and.
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  Speaker 1: To adswer that. I think it also helps us with
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  Speaker 1: meeting the expectations of our consumers and customers they're looking.
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  Speaker 1: You know, with COVID, we really moved from more brick
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  Speaker 1: and mortar to being accessible through our technology and coming
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  Speaker 1: from a bank that is an online, all digital bank,
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  Speaker 1: we're always trying to find the ways to bring new
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  Speaker 1: products and services to our customers so that they can
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  Speaker 1: do the research beforehand at their desk to find out
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  Speaker 1: what are the differences in products or services or fees.
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  Speaker 1: And then also the other thing is, you know, we
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  Speaker 1: shouldn't forget that we also want to look at consultants
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  Speaker 1: in the field too.
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  Speaker 2: Sorry.
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  Speaker 1: With consultants, they also bring another viewpoint. They can come
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  Speaker 1: into an institution and help to make sure that you
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  Speaker 1: are having that consistency with your compliance programs and oversight.
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  Speaker 1: Like Nick said, you don't want to be an outlier,
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  Speaker 1: and that's where sometimes you having that third party to
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  Speaker 1: come in and tell you what they're seeing across the
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  Speaker 1: industry is helpful as well.
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  Speaker 2: Yeah, do you think you know, I was coming a
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  Speaker 2: conversation with somebody yesterday that given a little bit of
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  Speaker 2: the you know, swirl with the regulatory agencies, and of
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  Speaker 2: course you know, the exams from the credential regulators are
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  Speaker 2: still happening, but there is some uncertainty about what's next
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  Speaker 2: across the board, and they mentioned that maybe a good
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  Speaker 2: opportunity to do just that, like to kind of take
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  Speaker 2: another second look at your book, look at your practices,
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  Speaker 2: go through your whole CMS program, and evaluate if there's
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  Speaker 2: anything you want to do proactively yourself and to kind
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  Speaker 2: of shore up what you're doing. Are you seeing member
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  Speaker 2: banks doing that sort of thing, kind of saying hey,
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  Speaker 2: we're going to you know, take the opportunity to spend
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  Speaker 2: a little time looking inwardly.
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  Speaker 4: Yeah, And actually multiple sessions here at CBA Live discussed
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  Speaker 4: at very point. I think, you know the definition of
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  Speaker 4: proactive is basically doing something when there's not an urgent
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  Speaker 4: kind of requirement, right, So of being reactive and so
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  Speaker 4: in this time of a perceived lull, even if it's
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  Speaker 4: you know, whether it's real or not, I like, yeah,
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  Speaker 4: sort of taking a moment to breathe and go, okay,
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  Speaker 4: whether the things that I can do to strengthen my
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  Speaker 4: program or things that have been okay that I want
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  Speaker 4: to maybe spend a little bit more time.
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  Speaker 1: And that's one of the best parts about being part
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  Speaker 1: of CBA. We're having those conversations together to say, with
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  Speaker 1: what is all going on in the industry? And I
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  Speaker 1: like that you said swirl versus hurricane or SMORTNATO. We
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  Speaker 1: are able to talk about, you know, are we changing
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  Speaker 1: our programs now? Do we want to wait? When do
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  Speaker 1: we have that comfort level that the regulators are now
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  Speaker 1: settling on what the new CFPV is going to look like,
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  Speaker 1: what their expectations are, or are we going to have
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  Speaker 1: to again go back to really focusing in on what
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  Speaker 1: our crudential is expecting of us as institutions.
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  Speaker 2: Sure, well, you know, with that swirl, tsunami, hurricane, whichever
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  Speaker 2: natural disaster we want to call it, the you know,
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  Speaker 2: I think certainly the rules are changing. How do you,
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  Speaker 2: as going to CBA committee members think about helping your
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  Speaker 2: members or staying on top of what's happening in the news.
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  Speaker 2: I think the volume and velocity of news is almost
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  Speaker 2: impossible to stay on top of. But how do you
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  Speaker 2: how do you think about managing those risks and understanding
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  Speaker 2: them and helping kind of distill what's happening as it
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  Speaker 2: relates to fair and responsible making down to your members.
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  Speaker 4: CBA itself has a really strong team that keeps track
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  Speaker 4: of what's going on in DC and beyond, and so
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  Speaker 4: it really starts there, and I think they really provide
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  Speaker 4: a great backbone of updates that they can provide across committees.
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  Speaker 4: And so depending on the committee kind of subject matter,
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  Speaker 4: then the lean in on certain updates and so that's
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  Speaker 4: that's really I think having that foundation. While I think
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  Speaker 4: you know, all the committee members get news bye and
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  Speaker 4: you know, get a bunch of stuff via email or
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  Speaker 4: monitoring the industry, having that consolidated view and in some
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  Speaker 4: cases like a little bit of a behind the scenes
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  Speaker 4: or things that you might not see in the public
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  Speaker 4: about certain meetings or certain happenings is really valuable to
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  Speaker 4: kind of go okay, this, this gives me an idea
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  Speaker 4: of what might be coming next or in the next
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  Speaker 4: week or month or who knows.
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  Speaker 3: So I think it starts there.
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  Speaker 4: Then that's really a platform to spur discussion about okay,
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  Speaker 4: well what does this mean at across the institutions, and
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  Speaker 4: maybe some have already thought about taking action or kind
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  Speaker 4: of preparing.
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  Speaker 1: Absolutely, and then behind the scenes sometimes we do benchmarking.
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  Speaker 1: And so Nick knows for many years I've called him
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  Speaker 1: throughout the year and said, hey, what do you think
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  Speaker 1: about this?
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  Speaker 4: What are you doing?
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  Speaker 1: What have you seen or her from other colleagues, And
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  Speaker 1: so it's a good way for us to within the
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  Speaker 1: committee and also behind the scenes to really benchmark with
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  Speaker 1: each other.
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  Speaker 2: Yeah. Absolutely, So I think that like partnership is key,
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  Speaker 2: especially today, and you know, I think you both know,
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  Speaker 2: like you know, folks move around in the industry too,
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  Speaker 2: between different organizations, So that's great that you have that
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  Speaker 2: network out there. You know, as you think about like
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  Speaker 2: technology innovation AI, whether it's you know, the type of
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  Speaker 2: AI we use to do our underwriting and risk assessments
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  Speaker 2: or things like generative AI, the role of a fair
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  Speaker 2: lending officer or a fair responsible banking officer is getting
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  Speaker 2: more complex, you really, you know, it was already a
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  Speaker 2: very complex area, but now taking those rules and kind
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  Speaker 2: of applying them to rapidly changing new technology, Like how
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  Speaker 2: do you think about staying on top of technology developments
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  Speaker 2: and taking kind of the crux of the regulation which
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  Speaker 2: hasn't changed, and then measuring with new technologies like AI.
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  Speaker 2: That's a big, light, lightweight question.
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  Speaker 1: I mean it really is, and especially coming from an
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  Speaker 1: online bank where we do everything digitally to start with you,
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  Speaker 1: really we are becoming more and more involved in the
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  Speaker 1: process of AI machine learning in our institutions than ever before.
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  Speaker 1: And it's really based on the expectation of the regulators.
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  Speaker 1: They want us to make sure we're aware of what
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  Speaker 1: are in our models, What are the variables in there?
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  Speaker 1: Is there any potential risk of discrimination and if so,
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  Speaker 1: how are you controlling for it? Are you changing the
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  Speaker 1: variables that are in there? Are you requiring different standards
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  Speaker 1: around it? So we're keeping in touch with our models
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  Speaker 1: across our our across our organization as well as across
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  Speaker 1: the industry. And that's where again having a platform like
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  Speaker 1: CBA where we can come together and talk about my
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  Speaker 1: regulators looking for this within examinations or how we're looking
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  Speaker 1: for oversight versus a different crudential regulator that might have
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  Speaker 1: a different focus. We know last year there was the
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  Speaker 1: CFPEB sent out a questionnaire to multiple organizations to gather
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  Speaker 1: more information on what are they doing for models and
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  Speaker 1: oversight internally. So as we're trying to figure it out,
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  Speaker 1: the regulators are trying to figure it out as well.
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  Speaker 4: Yeah, and I would add that sort of the tools
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  Speaker 4: and techniques continue to evolve. I think the principles of
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  Speaker 4: the challenges with AI, with the black box nature and
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  Speaker 4: then now with jen ai sort of being very widespread,
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  Speaker 4: and I think, you know, I think everyone probably has
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  Speaker 4: a version of chat GPT or claud or something like that.
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  Speaker 3: On their phones, and so it's very accessible.
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  Speaker 4: And so I think having that discussion on you know,
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  Speaker 4: some some banks may be leaning in more historically to
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  Speaker 4: using AI models in more kind of high stakes scenarios
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  Speaker 4: like lending, and then others aren't. So I think having
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  Speaker 4: a committee to discuss those and sort of learn from
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  Speaker 4: the collective group is very valuable. And so then if
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  Speaker 4: you know, if your institution is like, Okay, we're kind
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  Speaker 4: of ramping up in this area, then what does that
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  Speaker 4: mean from a fair lending perspective, what sort of reviews
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  Speaker 4: might be conducted, and I think that's also a pretty
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  Speaker 4: big sliding scale.
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  Speaker 3: I think you know, we've.
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  Speaker 4: We've heard some from regulatory feedback or some it's a
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  Speaker 4: limited public documents from prudentials and CFPB on the topic.
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  Speaker 4: But there's still a lot of different, I think, ways
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  Speaker 4: in which you could implement fair lending controls and risk management.
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  Speaker 4: So having again have that dialogue and committee to talk
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  Speaker 4: about those things is helpful.
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  Speaker 1: And then also to add to it, the CBA is
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  Speaker 1: great and other industry trades as well where they advocate
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  Speaker 1: for the banks on Capitol Hill to say the banks
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  Speaker 1: want more direction, they want to have that guidance of
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  Speaker 1: what your expectations are so they can implement it within
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  Speaker 1: their institutions.
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  Speaker 2: Yeah, and I think that's definitely something you know, and
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  Speaker 2: you think you both are aware that you know, we
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  Speaker 2: work with more than one hundred banking institutions, whether it's
• 11:29
  Speaker 2: a bank or a credit union or more of a
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  Speaker 2: banking as a service type bank provider, and so we
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  Speaker 2: see and help support them through many exams with all
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  Speaker 2: of their prudential regulators. And I think that that inconsistency
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  Speaker 2: with what the different field examiners may know and what
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  Speaker 2: they're comfortable with and you know they are really trying
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  Speaker 2: to learn and you know, we've done a lot of work,
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  Speaker 2: you know, going into the different agencies and kind of
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  Speaker 2: trying to open up our doors as much as possible,
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  Speaker 2: to be very transparent and to help educate and to
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  Speaker 2: drive forward the understanding of AI. And we spend a
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  Speaker 2: lot of time I think, as you've been thinking about
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  Speaker 2: fair lending and have a deep team that's that's working
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  Speaker 2: on fairness across you know, I think with the you know,
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  Speaker 2: one of the themes that I've heard this week is
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  Speaker 2: with a lot of the kind of political uncertainty and
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  Speaker 2: the regulatory swirl, experienced examiners potentially leaving and the risk
• 12:24
  Speaker 2: that that can can bring. You know, can you talk
• 12:27
  Speaker 2: to me about maybe what what you're thinking, particularly in
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  Speaker 2: an area like fair and responsible banking, where I think
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  Speaker 2: the subject matter expertise has to be very deep to
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  Speaker 2: be very effective at it and not just and really
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  Speaker 2: sort out the signal from the noise of data. What
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  Speaker 2: what do you see that having an impact on the
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  Speaker 2: examinations If there's a kind of mass departures from the agencies.
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  Speaker 3: Yeah, I even think just.
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  Speaker 4: Even mass departure aside sort of filtering in and out
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  Speaker 4: of examiners, patients, things like that, sometimes you may lose
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  Speaker 4: institutional knowledge, you know, regardless of kind of fair lending expertise.
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  Speaker 4: And then I think too, you think about like the
• 13:10
  Speaker 4: scope of fair learning exam, so it's not just an
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  Speaker 4: underwriting mortgage underwriting fair learning exam every single time across
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  Speaker 4: the country. It's it could be many different focal points.
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  Speaker 4: So even even sort of like current state, there's a
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  Speaker 4: bit of a sometimes a learning curve. And but yeah,
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  Speaker 4: I do think that's important. I think relationships with examiners,
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  Speaker 4: I of course, being being one in.
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  Speaker 3: The past, I have a soft spot there.
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  Speaker 4: And and it really is a situation where when everyone's
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  Speaker 4: working together, no one likes surprises.
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  Speaker 3: It's really going to yield the best result.
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  Speaker 4: And and so I think I think telling, you know,
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  Speaker 4: sort of being a being proactive with with regulators, telling
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  Speaker 4: your story about your program, telling about what you've already
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  Speaker 4: thought about and how you're controlling for things connectually be
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  Speaker 4: a way to sort of go, hey, if I've got
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  Speaker 4: my program really well laid out, that's going to be
• 14:06
  Speaker 4: easy for someone who's maybe you know, new or green,
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  Speaker 4: to say, okay, now I kind of understand how to
• 14:13
  Speaker 4: take the regulation and how it's actually being done, and
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  Speaker 4: I can kind of use that as a springboard.
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  Speaker 1: I agree. I think the relationship part is so important
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  Speaker 1: with our regulators, and part of that is going to
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  Speaker 1: be having to reteach them what your organization does, why
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  Speaker 1: you do things a certain way, and also a little
• 14:31
  Speaker 1: bit of that history so that they understand. But I
• 14:34
  Speaker 1: think it will be it will be hard. We also
• 14:38
  Speaker 1: to remember it's a lot on the examiner to walk
• 14:39
  Speaker 1: into institutions and have to relearn completely different focuses, sizes,
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  Speaker 1: and complexity, So we have to also remember that it's
• 14:47
  Speaker 1: going to take a little bit of time for our
• 14:49
  Speaker 1: regulators to get caught up. It does concern me a
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  Speaker 1: little bit though, with the large influx of those that
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  Speaker 1: are leaving at this time. As you say, fair lenning
• 14:58
  Speaker 1: is very complex, and so even internally in institutions, a
• 15:02
  Speaker 1: lot of times I'll have, if I have an open position,
• 15:05
  Speaker 1: someone who's very new to compliance wants to start unfair lending.
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  Speaker 1: And I always think this is kind of where you
• 15:10
  Speaker 1: end or where you're in your mid at least your
• 15:12
  Speaker 1: midpoint of your journey for your career, because it is
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  Speaker 1: very complex and you need to understand a lot of
• 15:18
  Speaker 1: other regulations in order to be able to apply fair
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  Speaker 1: lending accurately.
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  Speaker 2: Sure, And I remember actually last year, I think we
• 15:24
  Speaker 2: talked about a little bit the challenges of hiring and
• 15:28
  Speaker 2: bringing in new employees into the fair lending space. This
• 15:34
  Speaker 2: could be an opportunity to hire some ex examiners, and
• 15:36
  Speaker 2: so there may be some senior people that landed at
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  Speaker 2: many of the banks I think particularly we've seen, you know,
• 15:42
  Speaker 2: we work with a lot of more kind of regional
• 15:44
  Speaker 2: and community banks as well and smaller credit unions, and
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  Speaker 2: I think that may be a good hiring opportunity for
• 15:50
  Speaker 2: them to snatch up some of those ex examiners.
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  Speaker 4: Yeah, absolutely, thinking that, I think that's sort of the
• 15:55
  Speaker 4: flip side and a positive because yeah, there's a lot
• 15:58
  Speaker 4: of really good talent across agencies and and you know,
• 16:04
  Speaker 4: and even just folks kind of looking for a different
• 16:07
  Speaker 4: opportunity to be like, hey, I've been kind of in
• 16:10
  Speaker 4: examination supervision for twenty years and kind of what's next. Okay,
• 16:15
  Speaker 4: well get on the bank side, you know.
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  Speaker 1: And Nick is a great example of how we can
• 16:21
  Speaker 1: transition into working in a bank and having a really
• 16:24
  Speaker 1: great career.
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  Speaker 2: Absolutely and there's so many as you mentioned, like consulting agencies.
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  Speaker 2: There's a ton of firms that are out there as consultants,
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  Speaker 2: particularly in the fairness space, to bring that expertise into
• 16:35
  Speaker 2: organizations that maybe can't build and hire a full team internally.
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  Speaker 2: And we certainly see more of those and are engaging
• 16:42
  Speaker 2: with them too.
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  Speaker 1: In our work.
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  Speaker 2: All Right, So, I know you've both talked a lot
• 16:46
  Speaker 2: about the benefits of the CBA and the benefits have
• 16:49
  Speaker 2: done just relationships across the industry too. But you know,
• 16:52
  Speaker 2: what would you if you had to say what's the
• 16:54
  Speaker 2: biggest challenge in the past year and how being a
• 16:56
  Speaker 2: member of CBI and on the committee at the CBI
• 16:59
  Speaker 2: has helped navigate that? Like where do you know? What
• 17:03
  Speaker 2: would you say is the biggest benefit that you've seen
• 17:06
  Speaker 2: in helping over the past year.
• 17:08
  Speaker 1: I'm going to go with my two regulations, and I'll
• 17:11
  Speaker 1: say CIRA and ten seventy one. Even though CIRI is
• 17:14
  Speaker 1: outside of our scope, it's still very close with what
• 17:16
  Speaker 1: we do in fair and Responsible banking. That regulation in
• 17:20
  Speaker 1: ten seventy one we have final rules and then organizations
• 17:24
  Speaker 1: are starting to implement those rig change management and then
• 17:28
  Speaker 1: it's on pause because of lawsuits or other changes right
• 17:31
  Speaker 1: now with the administration, when do we start, when do
• 17:34
  Speaker 1: we stop? And working with CBA, they've really been able
• 17:37
  Speaker 1: to bring us together. There are forums for ten seventy
• 17:40
  Speaker 1: one where anyone can pop in each week ask questions
• 17:44
  Speaker 1: about I'm trying to implement this field. It does not
• 17:47
  Speaker 1: make sense. How do I train my commercial lenders on
• 17:51
  Speaker 1: what this field means, when to collect data, when not
• 17:54
  Speaker 1: to collect data. So it's really been great because they
• 17:56
  Speaker 1: keep us all aligned better and give us that forum
• 17:59
  Speaker 1: to really work together and find out what concerns our
• 18:03
  Speaker 1: other banks having so we can try to prevent it
• 18:05
  Speaker 1: within our own institution.
• 18:08
  Speaker 3: Yeah, that's a great one ten seventy one.
• 18:09
  Speaker 4: And not only just like implementation, but just the dates,
• 18:12
  Speaker 4: like so what is the compliance state? So that's moved
• 18:14
  Speaker 4: many times and with court cases and whatnot.
• 18:17
  Speaker 3: So that's again a strength of the CBA in keeping really.
• 18:23
  Speaker 4: Finger on the pulse of all of those court cases
• 18:26
  Speaker 4: and kind of current current statuses. And so I think
• 18:30
  Speaker 4: there's a number of rules too that go beyond fair
• 18:33
  Speaker 4: and multiple banking, but the same kind of thing of
• 18:35
  Speaker 4: like okay, well this rule survive or will it permutate
• 18:38
  Speaker 4: in something else, And so that's that's really good and
• 18:42
  Speaker 4: really good source of information. I think every bank probably
• 18:44
  Speaker 4: talks about that in their own institutions as well, but
• 18:48
  Speaker 4: to have you know, more perspectives on that. And then
• 18:52
  Speaker 4: I think most recently with a bunch of executive orders,
• 18:56
  Speaker 4: and I think the question is like, okay, even though
• 18:58
  Speaker 4: maybe most of these do not apply to banking directly,
• 19:02
  Speaker 4: what's the indirect impact? And I think there's the reputation
• 19:06
  Speaker 4: risk that comes into play of like okay, well, what
• 19:09
  Speaker 4: are people doing? How are we interpreting this as an industry?
• 19:14
  Speaker 4: So that's you know, very front and center these days.
• 19:17
  Speaker 1: It's a great example. I think of DEI as one
• 19:19
  Speaker 1: of it. It works, it aligns very closely to what
• 19:22
  Speaker 1: we do in very responsible banking, who we protect, which
• 19:26
  Speaker 1: customers as prohibited basis groups, and so it does have
• 19:29
  Speaker 1: also that reputational risk. How are organizations going to adjust
• 19:33
  Speaker 1: based on what we're seeing from executive orders?
• 19:35
  Speaker 2: That's interesting, So that's maybe a good one to kind
• 19:39
  Speaker 2: of end on. Then, like you know, any I guess
• 19:42
  Speaker 2: bold predictions of what may change in your space throughout
• 19:46
  Speaker 2: twenty twenty five.
• 19:47
  Speaker 3: I think there's going to be a change with ten
• 19:49
  Speaker 3: seventy one. I could see some of the I guess
• 19:54
  Speaker 3: so called.
• 19:56
  Speaker 4: Non mandatory fields maybe getting pulled back, some of the
• 20:00
  Speaker 4: requirements within for monitoring of kind of no responses for
• 20:06
  Speaker 4: collecting information for demographics or I don't want to provide that,
• 20:10
  Speaker 4: so that that's kind of a new thing. And then
• 20:13
  Speaker 4: I think too, I think, you know, date's already been
• 20:15
  Speaker 4: pushed back. I think there's I don't even know what
• 20:17
  Speaker 4: the official they would be, so I think it's always
• 20:21
  Speaker 4: been odd with ten seventy one, like a mid year implementation.
• 20:24
  Speaker 4: I'm not a fan of that personally, but so I
• 20:28
  Speaker 4: could see that, you know, kind of getting delayed and
• 20:33
  Speaker 4: being changed a bit, some of it rolled back, so
• 20:35
  Speaker 4: that that will cause you know.
• 20:39
  Speaker 3: A lot of I don't know, I don't know the
• 20:43
  Speaker 3: right word is, but in some.
• 20:45
  Speaker 2: Maybe expense and resourcing that may not actually be implemented.
• 20:50
  Speaker 4: Then yeah, I think banks will have a choice of like, hey,
• 20:53
  Speaker 4: we've already coded all this stuff, so then like well,
• 20:56
  Speaker 4: if it's if it's optional and we can still do it, fine,
• 20:59
  Speaker 4: maybe that's that Maybe that's cheaper and better to kind
• 21:02
  Speaker 4: of have those but maybe not report them. Or if
• 21:05
  Speaker 4: it's even permissible, right, because so for a test everyone
• 21:08
  Speaker 4: maybe the fields it would be legal to collect them now,
• 21:11
  Speaker 4: so there's a lot of complexity there.
• 21:13
  Speaker 3: So maybe that's not really a bold prediction.
• 21:14
  Speaker 4: I think it's maybe somewhat logical, but I think in
• 21:17
  Speaker 4: this environment, I think logic might be out the window,
• 21:21
  Speaker 4: you know, So, so i'd say sort of be prepared
• 21:24
  Speaker 4: to be surprised.
• 21:26
  Speaker 3: I love the movie Dan in real life, so that's
• 21:27
  Speaker 3: one of my favorite quotes.
• 21:30
  Speaker 1: I agree. I think we as compliance officers are used
• 21:34
  Speaker 1: to a lot of change, and so we're just going
• 21:36
  Speaker 1: to have to be prepared for even more change over
• 21:38
  Speaker 1: the next couple of years. But again we're here to
• 21:41
  Speaker 1: serve our customers to do the right thing by them,
• 21:44
  Speaker 1: and also serve our institutions, so with it, we will
• 21:48
  Speaker 1: make sure that we do work with the ebbs and
• 21:50
  Speaker 1: flows and make sure everything goes well. I think the
• 21:53
  Speaker 1: biggest predictions I have is again going to Siri, because
• 21:58
  Speaker 1: it works so closely with us, I think is going
• 22:00
  Speaker 1: to be vastly different once it goes through the lawsuit
• 22:04
  Speaker 1: and it's looked at again. And I believe you DApp
• 22:07
  Speaker 1: will probably have I don't know if it'll be better
• 22:09
  Speaker 1: to find, but I think it's going to be slightly
• 22:12
  Speaker 1: less regulated over the next couple years, and I expect
• 22:16
  Speaker 1: to see through our midterm election that it could change
• 22:20
  Speaker 1: then instead of waiting until the next four years for
• 22:23
  Speaker 1: a new administration. So we'll see what happens with you, DAP, CIRA,
• 22:28
  Speaker 1: and I think we're going to have a slightly different,
• 22:32
  Speaker 1: much smaller CFPB. I keep saying it's going to have
• 22:35
  Speaker 1: a facelift. It's going to be here somehow, but it's
• 22:38
  Speaker 1: going to look slightly different.
• 22:40
  Speaker 2: Great, well, thank you. Definitely appreciate Lindsay Nick both of
• 22:43
  Speaker 2: you rejoining us on the podcast.
• 22:45
  Speaker 1: Thank you for having us