Community Banks: Banking-as-a-Service and How Community Banks Can Make it Work

Jonah Crane, Partner, Klaros Group; Mitchell Lee, Chief Risk Officer, Synctera; Allan Rayson, Chief Innovation Officer I Chief Technology Officer, Encore Bank

Transcription:

William Pohl: (00:07)
So my name is William Pohl. I'm a account executive with back base. Who's sponsoring the event here. So back base is an engagement banking platform, which essentially can think of as a digital banking platform on steroids. So we are all about helping community banks compete with much larger financial institutions by giving them the same technology. So we work with banks as large as Royal bank of Canada, but also as small as vantage bank, Texas, who's about 3 billion. And our perspective is for community banks to stay relevant and compete over the next five to 10 years, you really need to own the customer experience and deliver hyper personalized, really tailored experiences that match the experience that you give them in person or in branch. So I'm here today to introduce our speakers for the banking of the service and how community banks can make it work session.

William Pohl: (00:59)
First up, we have Alan rayon. So Alan is the chief innovation officer and chief technology officer for Encore bank, Arkansas based boutique bank that couples innovative technology with talented, experienced bankers to offer unprecedented levels of service to clients, an accomplished banker and leader. Alan has a 20 year track record collaborating with and supporting large and small corporations, individual investors, founders, and entrepreneurs. Alan began his career in 2001 with COER bank in Dallas, where he spent the first five years of his career as an analyst and corporate banker Alan joined bank of Texas in 2005, working primarily in corporate banking and private wealth management, where he supported privately held business owners and their underlying middle market businesses. In 2013, Alan moved with his family to Austin to join the commercial banking team at BBVA Compass. And in 2017 joined region's bank to build a central Texas region market central Texas region as market executive, a position he held nearly three years before becoming an executive at Encore bank.

William Pohl: (02:07)
Additionally, Alan is the former CEO and co-founder of paida financial technology company launched in 2014, designed to support youth sports clubs across the U.S. Alan holds a bachelor degree in marketing and an MBA from Texas tech university. And he also earned a, certified private wealth advisor designation through the investment management consultants association, quite a mouthful and the university of Chicago's booth school of business. Alan enjoys spending time outdoors, running, cycling, boating, and listen to live music with his three sons Will, Alex and Sam. Alan and his family are also passionate about giving back to the community and working hard to support their homeless through mobile, loaves and fishes and Austin based nonprofit and freshies, an organization he and his family launched in 2014. It's quite the profile. Very impressive. Yeah.

Allan Rayson: (02:58)
Thank you. First thing I need to do is shorten

William Pohl: (02:59)
That. Yeah, no, that's you got a lot there. That's impressive. All right. Next up we have Mitchell Lee is the Chief Risk Officer at Synctera, a series a banking as a service startup focused on connecting fintechs with community banks. Prior to Synctera, Mitchell led the federal reserve bank of San Francisco's FinTech program where he oversaw supervision and policy related research on FinTech topics, advising policy makers and bank examiners on topics, including cryptocurrency/stablecoin, FinTech partnerships and neobanks. During this time, he also worked on FinTech lending research for the Fed's emergency lending programs during the COVID-19 pandemic. Mitchell has also led capital and stress testing programs at the fed to assess the country's largest bank and was a risk consultant at EY advising financial institutions on topics ranging from enterprise risk, capital management and banking regulation. Mitchell holds an MBA from the Wharton School at the university of Pennsylvania.

William Pohl: (04:01)
M.S. In accounting at the University of Virginia and B.S. In finance at the University of Florida. He is also an inactive CPA, inactive CPA in the state of California. Wonderful, thanks for joining us Mitchell. And lastly, we have Jonah Crane. Jonah Crane is an experienced advisor to financial technology companies with innovative products or business models, Jonah advises on business and product strategy, regulatory and compliance risk and regulatory engagement. He's helped neobanks infrastructure providers, crypto companies, and banks navigate complex regulatory frameworks. Jon has also helped financial regulators around the world develop policy frameworks to facilitate innovation and financial inclusion and led the drafting of the first comprehensive code of conduct for trading digital assets. Jonah served as a senior advisor and deputy assistant secretary in the U.S Treasury Department. And as advisor to U.S, Senator Chuck Schumer. Jonah was previously a mergers and acquisition lawyer at Millbank LP in New York city. Thanks for joining us, Jonah. All right,

Jonah Crane: (05:04)
Well, thank you, for the introductions, with intros, out of the way, why don't we just dive right into the conversation, although will you left out one thing about Alan, you failed to note that he's the cover boy for American banker magazine. So pick up your copy on the way out, Alan might even sign it for you, so let's dive right into the conversation. Maybe I'll tee it up really quick. I'm not gonna belabor any points on these slides, but just to sort of set the tone, there are lots of different kinds of bank and FinTech partnerships. I've used categories here, just as a helpful sort of way to structure, thinking around it, that the federal reserve use, in a recent white paper that they put out, and they range from sort of typical vendor relationships, sort of operational technologies, sort of back office type partnerships, to customer oriented applications, but where the technology or service provider is really in the background, sort of think white labeled or think, account, onboarding through something like mantle, to front end partnerships, which, I think what we typically talk about is banking as a service fits in this category, where the FinTech is out front customer facing, working with the bank on the back end.

Jonah Crane: (06:15)
So that, that's just a, sort of rough taxonomy, we're talking about banking as a service because lots of people want to talk about banking as a service. This is, a survey of banks and 85% of banks are at least thinking about, possibly getting into banking as a service, business. Why are they thinking about it? Because the returns are pretty high. The writing on this chart is a little bit low, but if you just look at where the crosshairs pass, the yellow lines are the average, return on assets and return on equity on the left and, growth, that's growth and net income on the right. And the yellow, crosshairs are the averages for the banking industry and the gray crosshairs, are the averages for, sort of partner banks or banking as a service banks.

Jonah Crane: (07:02)
And you can see in both cases they're up and to the right. So that's why we're here today. Alan, I wanna start with you, your bank has a number of different kinds of FinTech partnerships, and so you've seen, many different flavors of this, and I'd be curious from your perspective sort of, Hey, how do you think about that strategically? from the bank's perspective, what kind of value you're looking for in the partnerships and, really, I think what I'd love to get out of the first part of this conversation is understanding the key ingredients for a successful partnership.

Allan Rayson: (07:30)
Yeah, appreciate that. I love, that slide. So hopefully you'll maybe let me borrow at some point, just, to, it's maybe helpful to have a little bit of context on, on Encore and kind of the, in the environment that, I'm in, and how decision making gets made in inside of our organization. So Encore today, our claim to fame is that we're the fastest growing, bank in the country, our investment bankers KBW, went out and kind of stripped out, all of the banks that have grown through M and A, and just, just really kept it to organic. And, just, a fast growing, here in the United States, we skew commercial. So virtually, all of the decision making and, things that we do, we look through that, commercial lens.

Allan Rayson: (08:24)
So that's also helpful, kind of context to know, but, within our technology and, innovation thesis, we're trying to move three big rocks. We're trying to drive commercial loan volume, trying to source core deposits at the cheapest rate possible, and we're trying to drive non-interest revenue for, obvious reasons. So, as we think about, FinTech partnerships, ultimately we wanna be a great, and it's admittedly early days for us with respect to our banking as a service journey, but we want to be a great partner and a great sponsor to those primarily commercially oriented fintechs, but at the same time we want to select those partners based on, can we in, in some, or all part, help us, meet those corporate objectives, beyond commercial lending. Can we, the other side of the partnership, can it drive deposits for us? Can it, drive, non-interest revenue for us ultimately, as we try to, continue to build, on course. So I hope that's helpful.

Jonah Crane: (09:35)
Yeah, no, thank you. And Mitchell, why don't you, tell us, a little bit about what Sentara does and, your Sentara plays kind of a middleman role between banks and fintechs. And so I think you have a good perspective on what makes for, successful partnerships there.

Mitchell Lee: (09:49)
Yeah. So, I think Alan just covered off on kind of what are some of the business objectives of why you even want to do these partnerships? I think one of the things that's really important in these partnerships is understanding who's gonna do what in these relationships, so the roles and responsibilities being really clear, and so as an example, something as simple as customer support, if someone is calling the number on the back of a card that's being, issued through that FinTech, who's gonna answer the phone, is it the bank, the bank might have really good experience in this space. They may already have operations, but they don't necessarily know the Fintech's product or customer as well as the FinTech does, on the other hand, is that the FinTech who knows the product knows the customer, but might not be as well versed in disputes management or, understand compliance, right?

Mitchell Lee: (10:41)
So those are the types of things that, Sentara we are really focused on, which is how do we take these relationships? So we're first and foremost, a tech platform. So we really are connecting banks with fintechs through a ledger system through, anti-money laundering and fraud transactions, monitoring, as well as things like, being able to basically have visibility into, KYC customers, being onboarded, all the transactions that are flowing through that FinTech. So we provide those services as a tech platform, but then what we're really trying to do is simplify all these other decisions that have to be made when you're standing up these partnerships, from, the launch all the way to, to the Goli of that FinTech, and so customer support is one component of a whole bunch of different decisions that have to be made. And that's what we're really trying to make as easy and simple as possible.

Allan Rayson: (11:32)
And just maybe one, one thing to, add onto that. I mean, yes, it is about the business outcomes that, that we're trying to achieve, whether it's driving core deposits or driving non-interest revenue, but, the other really, really important part of, a partnership, is the compliance audit risk ops, inside of a fast growing FI there, there are a number of different ways to get sideways with, with respect to those topics. So I think, maybe some balance, between accomplishing the business objectives, but from, the jump being, focused on the, compliance risk audits, Ops aspects of, those partnerships and as everybody gonna win from, that perspective?

Jonah Crane: (12:26)
Yeah, I think it's an important point. Maybe we can jump right into risk and compliance. I did a panel in this room yesterday on bank and FinTech partnerships, and that was a big focus of our discussion, just getting that right. And, we, know through the grapevine and our contacts that the regulators are tightening the screws on banks involved in FinTech partnerships, and really just trying to make sure that the bank understands, these programs are being run through a bank and ultimately they're therefore their bank accounts and the bank is responsible, at the end of the day. And so, they wanna make sure that the bank really understands what's going on in these accounts, and is overseeing them really closely. So that's a clear trend Mitchell. And you touched on this a little bit just in terms of roles and responsibilities, and some of the things you guys try to bring to bear with the sync terror platform and some of your partners, but maybe you can put your, old San Francisco fed hat back on for a minute.

Jonah Crane: (13:15)
And talk to us a little bit about how regulators see some of those risks. So I, mentioned a couple areas that we're seeing, inquiries now, but if you could expand on that a little bit and, give us a, bit of a picture from the regulator perspective.

Mitchell Lee: (13:28)
Yeah, absolutely. And, I do have to be careful about putting on the regular hat because, the last time I was at one of these conferences, I was at the fed and nobody wanted to talk to me. So, yeah, I think taking a step back, all the conversations I had when I was at the fed, or at least on the policy side was centered around this idea of are fintechs somehow getting away with, not abiding by banking regulations through these partnerships, right. Is there some sort of arbitrage that they're doing here, and is the bank doing a good enough job of ensuring that, through these partnerships, these fintechs are still following these rules and regulations. so a lot of the activity that we're seeing on the regulatory front is through third party risk management. That seems to be the way that regulators are saying, okay, we can't supervise the FinTech, but we can certainly supervise the bank and how they kind of manage that relationship.

Mitchell Lee: (14:23)
So even in the community bank space last year or two years ago, now there's been some guidance that, the fed worked with a couple other agencies worked on in terms of due diligence of community bank, FinTech partnerships, if you haven't checked that out, definitely advised reading that, but the biggest challenge in that space is really, rethinking what third party risk management really is, I think classically, we think of it as service provider, vendor management, right. And there's a huge checklist and there's all sorts of things that you've gotta do, and I think in these relationships, it's not really that service provider. It goes a little bit beyond that, you're sharing in some of the upside you're sharing in some of the downside, and so the things that you're looking at has to go well beyond a checklist.

Mitchell Lee: (15:07)
And I, joke that, with my wife just actually a few days ago, she was saying, before I decided to marry you, I saw that you had good credit score. Right. That was on my checklist of things that I care about, but I certainly felt like, Hey, there better be other things that, you, liked about me, right. For this to work out. And I think that's, in lots of ways, the same type of thing you gotta think about in these partnerships is that it is going well beyond a checklist, and then I think educating then the regulators on why you're making those decisions, what processes, what governance you have in place, and as a regulator, look, they're gonna be a couple steps behind, right. They're getting information on a lagged basis, as I mentioned earlier, people didn't want to really talk to me when I said, I was a bank examiner. Right. Um, and so I think part of it is gonna be educating them on how these relationships work and what are the controls in place that, the bank has. And especially on the technology side where there's all sorts of new innovation around, risk and compliance tools. These are things that a lot of regulators are just frankly, not yet fully familiar with. And so I think that's gonna be a lot of the process that's gonna happen this evolution of educating and getting them familiar with, what's going on in this space.

Jonah Crane: (16:25)
Yeah, that sounds right to me. I've been with my wife for 23 years, so I'm glad she didn't look up my credit score probably wasn't very good. 23 years ago, well, Alan, you mentioned that, you have as a core objective of the partnerships facilitating both sort of core deposit growth and, growth on the assets side. And, in my experience, one of the things that banks often sort of leave out of the risk, equation is thinking about sort of asset liability management with these partnerships, right? If, if one of these partnerships takes off, all of a sudden you could have, if it's a deposit program, you could have a ton of deposits. Now you gotta figure out what to do with them. Or if it's a lending program, all of a sudden your assets are growing, and it presents, a bit of a risk management conundrum, right?, you can, be too successful as well as not successful enough in these programs. So I'm curious how you guys think about that in terms of, just sort of making sure that you're well matched on the asset liability side and managing that proactively.

Allan Rayson: (17:14)
That's a great question. I mean, somebody, put it to me the other day, it was a bit of a paradigm shift for, I mean, they explained that, you need to understand your downside risks, but you also need to understand your upside risks as well. And, certainly, I am seeing instances of, big upside risks, for example, with banks, we're, we're only about, 2.3 billion in assets, so well under the 10 billion threshold, but certainly seeing banks that, are struggling, are, bumping up against those up against those thresholds and trying to manage that, that upside risk, specifically on the, on the deposit side. But, I think for us, we are entrepreneurial, we, we move at a pretty significant pace with respect to growth, trying to do it in a in a controlled environment, trying to be very much in lockstep with our, we're more regulated by the St. Louis fed

Allan Rayson: (18:22)
And by the, state banking regulators and in Arkansas in our case. But, really trying to be in sync with, our partners on the, on the regulatory side, but bit of a go slow mentality, in some ways as it relates to the evolution of the business on the banking as a service side, so that we can account for, it's a good problem to have, I guess, but, so that we can account for those, upside risks, should things just go swimmingly, for us in that journey.

Jonah Crane: (19:00)
Yeah, no right. Good problems to have. Right, Mitchell, maybe we can start with you on this and, then I certainly want your perspective too, but, I mean, one of the things that, comes up in the context of thinking about bank and FinTech partnerships is a concern on the bank side that we might get disintermediated, we might, lose the direct customer relationship, and you guys probably have to think about, you're adding even another layer into the relationship right. At St. Terra. So I'm curious how you guys think about that Mitchell and obviously Alan, I'm curious how you guys at the bank think about that, with all the partnerships you have now, and as you approach the, the best space. Yeah.

Mitchell Lee: (19:40)
Yeah. So I'll start, so this is a topic I thought a lot about when I was at the fed and I will say probably looking back on it probably a hundred percent wrong about my sort of assumption, which is yeah. That banks potentially are getting commodified. And, I think there's a, some articles years ago about whether banks are gonna become quote unquote dumb pipes, in these relationships, and I think what we're really seeing is, especially in, my role working with we've got about nine different banks on our platform is sort of the opposite of that, and I think there's a few reasons for that, one, I, when I take a step back, I think of banks, what they're good at is ultimately connecting people who have money with people who need money, right.

Mitchell Lee: (20:26)
Or wanna borrow money. And that turns out to be a very complex exercise, if anyone's following the crypto space right now, there's a company called Celsius that has billions of dollars in crypto, assets. I have some money in there and they're experiencing the equivalent of a bank run right now, so it turns out this thing about inter remediating money is very hard, I don't think that fintechs, regardless of, whether they have access to getting a bank charter are gonna be able to just do that on the fly, so that kind of value that a bank is bringing is still gonna be around, the other thing I think about from the community bank standpoint is that community banks are by definition smaller than their mega bank peers. And I think there's actually a huge advantage to that because you can be a little bit more nimble.

Mitchell Lee: (21:13)
You can make decisions faster, I was in a conversation just a couple days ago around setting certain limits or reserves for a FinTech partner. And that bank was able to say, give the policies and the documentation from that FinTech, let me look at the data that they have currently, and they're able to come back with a decision within a week, and I think something like that, which, fintechs love the ability to move with speed, cuz they want to get to market, is not something that I could envision, at a really large bank, right, where there's tons of approvals and committees and lots of stakeholders involved, so I think that's one area where community banks are gonna be able to separate themselves, but the other piece is also community banks differing amongst each other. And so in our platform, we've got a bank that really understands wealth management and working with financial advisors.

Mitchell Lee: (22:01)
And they've kind of taken that as an area of expertise and said, Hey, let's work with FinTech whose customers are actually financial advisors or RIAs. And so they understand, the needs, the complexity in that space. And they understand also what to do from a compliance standpoint, we've got another bank that is focused on cannabis banking, they've already been doing that as part of their business. So they understand, the sorrows filings that are required, the licensing that you've gotta check on cannabis dispensaries, again, really knowledgeable at that space. And they have a really good relationship with their regulators. And so they're able to service fintechs that are kind of operating in that space, so that's the other way area where I feel like if community banks have certain built in expertise based on the geography and the communities, the communities that they're already serving, they can really double down on that to operate in the FinTech space and work with fintechs that, are trying to, serve that market.

Allan Rayson: (22:58)
Yeah. This is a fascinating aspect of the, of the banking as a service conversation. And there, we could probably spend the entire session talking about just the dis intermediation topic alone. But, I think the way that I'm thinking about it is yes, I'm acknowledging that there is dis intermediation taking place. I'm seeing it day in and day out, I'm getting two to three calls a week from FinTech, that are looking for looking for sponsor banks. So the demand is out there, the disintermediation on some level is happening. I'm gonna acknowledge that. And, ultimately not like turn a blind eye to it, because I'm scared of it or something like that. But, I think there's another piece of, the conversation and you alluded to it in your slide, which I wanna borrow at some point.

Allan Rayson: (23:47)
And that's the valuation aspect of, the community banking space. And, for us, I mean not to oversimplify banking as a service, but in my mind, it's just the automated delivery of products that banks are already delivering to the market. Anyway. I mean, we're talking about loans and deposits. It's a relatively straightforward business, but, with a great banking as service, platform you've designed your tech stack the right way. You're partnering with the, right people. And ultimately you are, deriving the benefits of, in a lot of cases, a lot of deposits, a lot of new non-interest revenue that you weren't, able to capture prior to, know, prior to the development of that banking as a service program. So for us, the best data that's been shared with me is that, today we have, we've done an outstanding job of going out and, raising capital whole other conversation, but we're talking about several hundred million of, capital that has been raised. So, from a valuation perspective with banking as a service, there's an additional 60 to 70 maybe 80 basis points of, value. And when you're talking about several hundred million of capital, from a valuation perspective in the M and A market, it's something that we pay attention to recognizing that at the same time, there is just an mediation taking place between, us and our consumer client and, or our commercial client.

Jonah Crane: (25:26)
Yeah. And we talked to banks who were thinking about getting into the bass business. It's really, helping them think about it from the perspective of fueling our turbo, charging their core strategy, to begin with finding the right partners that can push that strategy ahead. And again, opening up access to customers who they're not gonna otherwise actually have as customers. Right. So from that perspective, it's additive, it's not disintermediating, and I think actually the regulators are coming around. I was in a meeting last week, with a large group from the fed and actually to hear somebody from the fed say, we think that for community banks, you gotta innovate, to survive was definitely a change in mindset from the regulatory side, at least from, from my perspective.

Mitchell Lee: (26:09)
Yeah. And I would add to that too, because what's really interesting from our angles that we're starting to see fintechs that are saying, I want to because, we're sitting in the middle of these transactions, but, so some banks are saying, Hey, well, I don't wanna be dis intermediate from that relationship, even with the FinTech. Right. And what we're seeing is, well, FinTech will come to us and say, I actually wanna know who's the bank on the back end of this thing. Right, what's their regulatory situation, have they, had, cease and desist or something like that, what's their capital position, right? Are they able to service us in a way that isn't gonna put us at a risk of potentially having the switch banks?

Jonah Crane: (26:47)
Right. No, it's a big deal. I mean, we're, we're talking to multiple fintechs right now who are either having their programs sort of throttled cuz their bank is coming under pressure. Maybe they mismanaged their balance sheet aspect or maybe there's a, balance sheet risk or maybe they have regulators breathing down their neck, but, FinTech who are having, having issues and seeking secondary or tertiary partner banks, because just from a, either a capacity or a resilience perspective, they find that, they gotta manage that risk on that side too. So definitely, something we've been seeing recently, I'm cognizant that there are two minutes left and I wanna make sure that if there are questions in the audience, you have a chance to ask them. Got one in the middle there.

Audience Member 1: (27:28)
So an on for how are you managing? How are you managing adherence to your BSA and AML policies with the FinTech partners that you have? Like, what are some of the tactical steps? Are you going out and visiting or are you, are they kind of check a box? Yep. We're hitting the policies.

Allan Rayson: (27:42)
Yeah. The first, I would, I would comment on a couple different things, but the first and most important step for us is, very early on in our journey. And we're only about, three years in. So it's, still, early days for us, but we took the time to be thoughtful about the right team, that we wanted working on, on all projects, this one, this one specifically. So we created, lack of a better phrase kind of multidisciplinary teams, that we leverage a lot internally. So, those teams cover, audit, risk compliance to your point, BSA, ops tech, innovation, we have those people at the table and that's really the starting point for virtually everything we do so that, I'm not out doing something, on my own and then trying to catch the rest of my folks up to the program, we're getting the right people at the table from the get, to make sure that we understand where the risks are and that we've, kind of properly mitigated those from from day one.

Jonah Crane: (28:59)
Yeah. I mean, I think Mitchell, your first response to the first question, I think, got it. An important piece of this, which is making sure you're clear on roles and responsibilities, right? Cause if you have the customer facing FinTech, they're gonna have a role to play right. And collecting the right information, making sure they go through the right C.I.P, steps and then sharing information back with the bank, if that's how the bank wants to run it or, so there's at some point a handoff from the FinTech to the bank and sort of how that all plays out has to be dealt with, has to be worked out. And every partnership, people like St. Terra trying to sort of standardize that, but every bank is gonna have a slightly different view about how they want to, handle that. And it's, it's definitely a compliance issue. Number one, two and three, I think, I get a little bit discouraged, cuz that seems to be the only thing people want to talk about in compliance in these partnerships is say, okay, oh, we got KYC done. Okay. We're good on compliance. Like, well there's a lot else to talk about, but it still is complex and you really gotta work through, who's gonna do what here, at the end of the day. And it's, it's definitely an exposure area for banks.

Mitchell Lee: (30:00)
Yeah. Spot on, if you talk to any FinTech, they will know KYC, they'll be dangerous about KYC and that's because that's affecting their onboarding process and their customer acquisition. Right, but once you get into some of the other topics, maybe not so much, I always advise our banks to think of the whole relationship as the FinTech is sort of your first line of defense, they own the product, they own the customer relationship. They should actually have a role in playing, risk management, but the bank is the second line in lots of ways, right? You're, you're instituting the policies or enforcing them. You're doing the checks, the audits you're doing the SARS filings on the side, so there's certain rules that the bank has to make sure that, these fintechs are follow the rules and regulations.

Jonah Crane: (30:45)
Well, I see we're at of time. I was gonna close with a big final question for YouTube. Maybe we'll do sort of a very brief version of the question, lots of banks as, one of the slides before indicated, were seeking to get into the banking as a service base. One of the reasons they were doing so is for, non-interest income, but, with net interest margin coming back, I wonder if, the vast majority of, of banks, will end up deciding to go forward with a vast program or not. And on the FinTech side, in terms of the, sort of demand for banking as a service, obviously the FinTech markets have been quite choppy and we'll have to see who makes it through. So I think on both the demand and the supply side, banking as a service, may not follow the same trajectory. It looked like it was gonna follow say a year ago. So I guess my, short version of the question is, have we seen peak bass? Yes or no?

Allan Rayson: (31:37)
In my opinion, no. I mean it, the market will continue to evolve that the demand is so high and, to the credit of the FinTech community, often times they're, delivering products that historically are better than, what banks have delivered. So when you're, when that's a fundamental part of your business model that you're delivering a product that's better than what's been delivered historically, there's probably always gonna be a spot for you. So

Jonah Crane: (32:05)
Sounds right. Mitchell, you're really biased in this question.

Mitchell Lee: (32:10)
Yeah, no, I agree, I think that, look, the funding numbers don't look as great for FinTech this year versus last year. But if you look at last year's numbers, it's, it's pretty staggering. And so I think that there's tons of building that's going on right now. And, for sure, like, you're gonna have some thin techs that might be struggling from a funding standpoint, but there's gonna also be a lot that are flushed with cash right now and just need to put their heads down and actually build stuff, but I think the opportunity itself, the technology has not changed despite the macro environment, right. It's, it's only gonna get better and easier, and there's a whole, we could do a whole session on embedded finance and all the other companies out there that actually already have cash flows and will probably be fine, but they just want to add banking products to their solutions. So, yeah, the market, I think is gonna long term, just continue to expand.

Allan Rayson: (33:03)
All right. We have not seen peak bass. So say our panelists, well, join me in thanking our panelists and, appreciate our sponsors and have a good afternoon.