FedNow: Is your bank ready? How to mitigate fraud risks

As your organization considers how to take advantage of instant payments to enable things like just-in-time payroll and bill pay, it's important to review your key systems for readiness.

Key Takeaways:
  • Best practices for implementing robust account opening process & strong authentication
  • Best practices for educating your customers
  • Best practices for classifying fraud involving payments
Transcript:

Chana Schoenberger (00:09):

So we are going to be talking about Fed Now, let me introduce my distinguished co-panelists here. We have Uma Wilson, who is the executive Vice President and Chief Information and Product Officer at UMB Bank and Jesse Honigberg, who is the EVP Product and Platforms at Customers Bank, which is a very confusing name because every time you talk about customers, you have to clarify if you mean the people or the institution. We at American Banker have been talking about Fed Now for a long time and we keep gliding over the now in the name because it is been fed later, fed eventually. But Fed Now is actually now it is really going to happen. And we are here to talk about the fraud risks of this payment system. So just to kick us off, how should bankers think about Fed now when it comes to fraud and what is different in the risk level for this system versus other payment systems that banks or consumers are already using? I, for instance, had to just shut off my Zelle. I had to delete my account because I got one of those fraud notifications that consumers get and I did not have time to reinstall it before I got here, so do not worry. I will download it again when I get home. I love Zelle. I can not live without it. Uma you want to start?

Uma Wilson (01:28):

Sure, absolutely. Good afternoon everyone. Thank you so much for having me as part of this session. So before we deep dive into Fed Now and the risk and fraud risk, it is just the discussion topics around instant payments. I am going to use that just for a second. Instant payments, either it is Fed Now or the clearinghouse realtime payments. It does not matter how you look at it. There is payments risk in every payments channel that we have been dealing with for many years. So the challenging part that we tend to as bankers, I will, I am going to use my financial institution and my team members, my operations and enterprise risk and fraud is when we look at channels as individually, we had fraud risk and fraud mitigation by channels, check fraud card, ACH or electronic, and the list goes on. Now, I think with the new payment type, it actually forcing us to have those tough discussions and decision to say perhaps we should really bring all the channels together and look at our fraud and payments fraud as a one cohesive opportunity rather than looking at an individual siloed. So that is kind of one area that we can keep focusing on. So I am going to pause until I do not want to steal all your thunder as well, so I am going to punt it over to him or maybe you have your own questions for him.

Jesse Honigberg (02:46):

Whatever you want. I can copy answer.

Chana Schoenberger (02:48):

Go ahead. Go ahead. You go first.

Jesse Honigberg (02:49):

So I think we met a great point in terms of payments or payments. I think that the thing that is changing its velocity. And so when we think about ACH, which a lot of our ops people are comfortable with, I get it, but there is a return process and it is great. There is a way that we can get it back. If something goes wrong, then you think about wire and you are like, well, we get it and our commercial clients need it. But then you have Zelle, which is its own little world, which kind of combines a little bit of both, and theoretically it is kind of settling with ACH, but a real time payment for the consumer. And the reality is now you are getting to this world of instant payments with Fed Now with the clearinghouses cleverly named RTP Rail. And that the real challenge is those are final irrevocable payments.

(03:49)

That money is gone, it is gone and it is now not just a commercial payment like a wire where you have commercial clients who are sending those payments and know what it is. It is really going to become more ubiquitous and it is going to be used across the board from both the consumer side, the retail side, SMB side, and then on the commercial side. And I think particularly it is going to be transformative in terms of all sorts of things, both fraud, but even liquidity risk is a whole different animal in a real-time payment world than it is, than we think about it today. And if you think that what happened a month and a half ago was fast, imagine how fast it would be if you could pull the money out over a weekend too.

Chana Schoenberger (04:34):

Wow, that is scary. It is really scary.

Jesse Honigberg (04:37):

Yeah, I am a good news person.

Chana Schoenberger (04:40):

Great. Yeah, no, it was an interesting day because overnight, of course, first Republic Bank got bought, which I encourage you to go to American Banker and check out the story that my people spent all weekend writing about that it is been quite the weekend. So what happens when people can withdraw their money from a bank instantaneously?

Uma Wilson (05:04):

So bankers, we tend to provide this security that makes our customers feel like, hey, we are going to safeguard your accounts and funding. I am not saying we do not do a good job, we do a great job, but I think one of the challenge and opportunities we have is we have been very comfortable around the batch process. There is always that tomorrow the checks, you can wait until the next day by two o'clock or whatever timeline you can return that wires. I get it, right? It is more of a relationship. If there was a wire that went out of the bank and the customer did not intend to send it or it was a business email compromise, that is an hour long session in itself. Based on where we are these days, customers still take instructions over the phone or email and sending transactions. We have built those relationship we can call another financial institution, explain the situation, and they will do their best effort.

(06:00)

But as we think about what this means to security and fraud, it is as things are evolving. Okay, we need to make sure, I know everything comes back to education, and I know it is very hard and I am very confident everyone in this room probably rolling their eyes in their own ways to say, my gosh, we have heard this session before, right? Education. How many folks over here, even if you really self-reflect upon your own financial institution, how many bankers that you even think clearly understands the difference between real-time payments or instant payments or Fed Now and ACH? Have you guys, like a show of hands, curiosity, everyone in your sales folks have a thorough understanding of what is going on in the payments world?

(06:44)

No, because I cannot answer that. I can assure you that it is an evolution. I mean, it is what, 40 years since we have had ACH, we are still educating ACH. It is not ache anymore, it is ACH or automated clearing, how it is kind of the process. It took us a long time. It is not always about our customers, it is also about us. That is one of the biggest opportunity and challenges. There is a mindset out there. Even if you look at this group payments, folks go to payments forums, no other folks go to any other forums. So we just become an expert when it comes to payments, but we expect our customers to know every single payment channels and the risk associated with that. It is a very daunting task. So the long way of me saying is the security side of the equation should be based on how well we onboard our customers and how we educate them, the opportunities of pros and cons and the risk associated with that.

Chana Schoenberger (07:37):

I have always been struck by the wires, the scaffolding around wires. So if I do a wire as a consumer, I can email the instructions to my banker and then someone will call me from the office, they know me, they know my account, they will call me and they will authenticate me. They will ask me my security questions and it is like, well, I just sent you the email, but I am totally cool with it because I understand they are keeping my money safe. And I also understand that once that money is gone, I can never get it back. So I really want to make sure that they are ticking me seriously. Yeah, that that is not real time. There is no way to do that in real time.

Jesse Honigberg (08:15):

Sure. I mean there always is. I think that it is the challenge for a lot of us is that we have these big core vendor dependencies and we have not, many of us kind of control our own tech stack and our own innovation stack. And so when you think about a real time payment, you do not have the luxury that you have with the wire on accepting it or not. It does not sit in your BSA queues or whatever it is going to do that you have five seconds to say, I am going to take it or I am not going to take it. So you run a cascade of rules and if you accept it, you have accepted it. Same thing about when you have accepted it to go out. At a certain point, once you say, yes, I am going to dissent this, you have an SLA that you have to adhere to on both the Clearing House and on Fed Now.

(09:05)

And your ability to build systems that interact that way is tough. And I think that the biggest thing in terms of education that I still found really funny in a way, I guess it is not funny, but is no one really understands the request for pay in terms of I would be on calls with partners who were sophisticated payments platforms and they are like, no, we love this. We want to implement request for pay because it is like a faster permanent ACH. I was like, no, it is not. And they are like, well, it is okay. We will figure it out. I was like, you do realize it is dependent on the person you are debiting positively confirming it and you can not set up a persistent auth. And they are like, oh. And I think that that is really, it is a very different mindset shift that forces a lot of us to think about how are these things going to play into our narratives?

(10:02)

But it is also a great opportunity when you go out and visit clients to be a real subject matter expert and to talk them about how you can be transformative to their business. If you think about Kennedy, something that I probably should worry everybody in this room fraud, but it is something else as well that if you have a certain amount of non-interest income that is dependent on wire fees and Fed Now is now priced at four and a half cents publicly, and probably banks are going to charge maybe a dollar for it, who knows? But is someone going to come out to your large commercial relationships who are giving you tons of money and wire fees or you have on analysis and you are getting really good spread on it and say, all right, I am going to move you all to Fed Now, and it has the exact same commercial enforceability as a wire, so there's no UCC concerns about it. It is good to go, but what just happened to all of your non-interest income that you get from wire transactions? And so I think there is going to be a fundamental shift in the price economics of payments as well. That is going to really affect a lot of us and candidly put a lot of our sales teams on the heels where you will have someone coming in and really undercutting you in a fundamental way, not just on process because the real-time payment is faster or more reliable, but on overall cost.

Chana Schoenberger (11:26):

That is so interesting, especially since I heard there was a question from somebody at the CFPB this morning, but of course the regulators have really gone after what they are calling junk fees, but no one has ever suggested that wire fees are junk fees. Those are fees that everybody pretty much agrees are legitimate fees. So you are saying they are going to go away.

Jesse Honigberg (11:48):

Not going to go away. They are going to reduce.

Chana Schoenberger (11:49):

Your compete it away!

Uma Wilson (11:51):

But at the same time, with any payments, confidence in any payments, rail drives the value. I am not saying with Fed Now or real time payments, there is no confidence. It is still relatively new. Not everyone has had the luxury to send the transactions yet everyone wants to send it. No one wants to receive it. So I think that itself, it is a battle because everybody including ourself, we won't send it to others. We are not ready to receive it. So that is our next phase. We are working through it. I mean, we are very large wires originator. By no means I am saying our wire transactions revenue is not going to shift. I 100% agree with that statement, but it is not going to happen overnight.

Jesse Honigberg (12:31):

Okay. And it is also the shift, right? Yes. In terms of the dollar amounts. And so if you think about it, you probably make most of your wire income on your sub $250,000 wires because there is just a lot more of them versus your 10 million wire. And so it is just something to think about as you kind of talk to your executive teams and you say, all right, well this is why we need to do it. It is not just about, oh, we want to be faster. You also need to think about it. It really needs to be a defensive strategy because it is going to be something that is probably going to affect you materially and probably 18 months.

Uma Wilson (13:05):

So the approach that we are taking when it comes to transactions revenue, of course we are, I mean we are a financial institution. We are publicly traded, so we have a commitment to revenue and bottom line. So we all know how things work. The best approach we would say is you cannot train your sales arm like another payments channel and say, when the customer asks for it, here you go, give a brochure and they should be able to do it. No, it has to be something that is oriented with kind of a payments taxonomy kind of an approach. Hey, let us actually take an opportunity to look at all the payments you originate today. If it is checks, ACH, wires, same day, whatever option it is, you have to look at it holistically and you need to start divvying up that payments. I am pretty sure many of you have heard the term best cost routing or the best preferred payments we are asking and training our sales books.

(13:53)

We have been doing this for six months. I am not going to claim victory by any means. Rather retraining their mind and attitude to start asking questions, not about ACH or anything. How many checks you write now, how many transaction payments do you send that needs to receive your recipient within 24 hours? How many payments do you have that it could be four to five days. So we are trying to ask those kind of qualifying questions that automatically provides them the option to say this is the right payment option for the customer and walk them through it. Because you put, if you enroll a customer into the right product type, they are going to be happy and they do not have to worry about onboarding issues, de enrollment and on enrollment. So I think that is big for us is, and also reinforcing payments are not any more just isolated to the treasury management sales folks are operationss okay. Payments is actually a revenue generator for everyone. Everyone needs to understand, they do not have to know everything. Details of SCC codes and violation and exception policy, but everyone, including lending officers and relationship officers must know the details around their payments instrument that they're transacting on.

Chana Schoenberger (15:05):

So it is like payments versus the world. Yes. So one thing that is interesting, and this sort of mirrors larger trends in the consumer economy is what happens when instantaneous payments are available, but especially a small business customer just does not have the money to pay right now. They needed that five days or they needed that net 30 days to come up with the money. It is a different business challenge.

Uma Wilson (15:32):

It is a very different business challenge. And also you have made a comment about CFPB. There are some strong opinions from CFPB about allowing customers overdraw their accounts. Many of many financial institution went through the concept around reg regulation, e-opt in, opt out. That was a chore in itself many, many years ago. Now we all are unpacking those things and trying to move away from those kind of attributes. This also allows folks to sit there and think about line of credit. So when you enroll in customers, it is not anymore like, oh, you want a $10,000 line of credit? We will just extend it to you. It is not just that anymore. It is, we have always had the obligation of knowing our customers. There is no doubt. I am not trying to shy away from that. We have alphabet soup of know your customer, CIP, there is your own internal 10,000 booklets policies we all have written, but truly, I strongly believe payments like Fed Now forces that a little bit more further.

(16:31)

You have to know your customers. Yeah, it is not just you. Oh, do I know you? No, it is not that I need to know you, how you make your payments, how do you get your payment instructions? Because if we can get that much of a detail we can avoid, I mean this whole concept around this panel is about fraud and risk, fraud and risk. As bankers, we can talk about it all day long. We can build different fraud engines and tools and channel and AI's and machine learning with all the different trending technologies on top of it. But if we do not ask a question, how do you get payment instructions? How do you actually authorize transactions internally? If we do not nail that concept down, the confidence in this payments rail will quickly derail because if more fraud comes into it is like Zelle, you made a comment.

(17:17)

If you lose a confidence, the first thing you would do is you re-enroll in the payments business and what is going on as an individual. If they see a fraud and they are having struggles with getting the money back, that is when the confidence will go. But going back to your question about small business, yes, a challenging of liquidity side is it is a thing, it is key. So which means if you do not have funding option, if you do not have line of credit, that payments may not go through the timeline you want to though, but at the same time it is also receiving.

Jesse Honigberg (17:46):

But I think that the opportunity in it is that right now, if you are accepting your merchant acquiring that you're settling T plus one, T plus two, that the opportunity is that if you are getting your customer payments instantly, then you really cut down that cash cycle. And so right now there is a lot of businesses that make a lot of money on charging SMBs, whether it is an MCA or whatever else in terms of getting access to funds that are actually theirs. I think the real interesting thing is going to be what happens to merchant acquiring? What is the card in your wallet going to do? How is that transaction going to be authorized at the point of sale? It presents all sorts of new fraud consequences. But also I think that there is really great opportunity in it, especially for SMBs, and that if we can get small businesses access to their money, the second that payment is swiped, it presents a huge opportunity for them to think about how they pay their people now that same day, right?

(18:55)

Because they are really on these same cycles and they need to pay their employees. And often there is cash flow issues there. And so you have solutions even in daily pay and everybody else that have popped up that do those disappear because now the money is there for the merchant and they can really pay it and it is not as big a deal and they can use a realtime rail to pay that. So I think that right now we accept a lot of compromise in the way we deliver solutions. And a lot of fintechs that probably a lot of us work with have really come about as a way to solve bad process that has really accommodated our payment rails, that the opportunity as we think about whether it is Fed Now or RTP or anything else, is how do we UNMs it up and implement it the right way and do so thoughtfully, and then think about all of our legacy technology vendors that all of us have to deal with and get them to come along for the ride. Because no matter what, as much as you have the grandest ideas, if you can not implement them, it does not really matter.

Chana Schoenberger (20:02):

Good point. Yeah. So you guys mentioned business email compromise, which brings up the fraud part of the hacking the cybersecurity challenge. There are many consumers, and of course many businesses that do not have a good handle on identity management. How do banks deal with all that? Because it is your job to know your customers.

Uma Wilson (20:26):

Yes, indeed we do. I wish I could sit here and say that we do not have any business email compromise. And the frustrating part, I think many of you guys have been in the same shoes as we are. It is that same customer over and over. We educate them and they do the same mistake a month from now. So to be very upfront with you, I do not have a secret sauce, right?

Chana Schoenberger (20:50):

Fire the customer.

Uma Wilson (20:50):

So I mean, I!

Jesse Honigberg (20:54):

De-risk! 

Uma Wilson (20:54):

Yes, right

Chana Schoenberger (20:56):

That customer right out of your institution.

Uma Wilson (20:58):

And I would say that as bankers, there is not a dollar that we do not like sometimes as well. We do not want to let a client go because we believe we can help them and we can be that security blanket as well for them. So the challenging part that we have is going back to the initial term as far as we need to start asking questions of our customers when we onboard them. How do you make payment transactions? And we talked about the value of wires versus a value charge associated with Fed Now, right? Based on the customer and how they get payment instructions. One of the discussions we have had internally is maybe we should charge customers based on the risk we are taking with them as well. Yes.

Chana Schoenberger (21:40):

It is sort of like the Swiss search and rescue. If you go off into the mountains when they tell you not to and they have to rescue you with a helicopter, they are going to send you a bill.

Uma Wilson (21:50):

I am going to send you a bill after that kind of stuff. So yes, even if you were to charge $20 for a real, I am sorry, fed Now transactions, and if the transaction is 500,000, it does not mean I am going to get the loss back. It is not that. It is about knowing the customer and asking, not just because there is a new payment rail, it does not mean that it is going to be an best option for the customer. Like the commentary you made, maybe you could fire the customer. We may not fire the customer, but we may choose not to end enroll you into the Fed Now transaction types until you can show us that you have good controls in place that can help you and protect the network and also safeguard the financial institution. So that is the best way I would answer. I am not going to sit here and say, we are going to get rid of business email compromise until the Federal Reserve builds a directory.

Jesse Honigberg (22:38):

Well, I mean the interesting thing on Fed Now is there is the blacklist option in there where banks can blacklist an account and now all of a sudden any money coming to that will get rejected. And that is a really interesting first step. What I worry is that could really get potentially compromised the wrong way. You know, really want to screw up a bank, have a rogue employee blacklist every account. Wow. And so I think there is lots of things that, there is lots of opportunity to improve process, but it is always people process technology. And so it always starts with your people. It starts with the way that you get them to understand what is the opportunity and the responsibility in the payment. I do not think many of our customers, even though our name is customers are primarily a commercial bank, even really think about real time payments. It is not in their mindset.

(23:37)

They do not think about it. They think in terms of brands. So they are thinking about in terms of Zelle, right? But we do not have anyone at our door who is saying, oh, like give me a Fed Now payment tomorrow. It is more about how do we go and understand that business and figure out how it becomes a competitive differentiation for us, and then how do we tie it to their liquidity concerns? How do we make sure that we use it to capture low-cost deposits? Because if you think about it, you really can not pay anything on the money that is going over a real time payment that needs to be fully liquid. And so if your customer is saying, I am going to send a million dollars a day in real time payments better, a, you better not lend out a million dollars in that relationship, or you better keep it very short duration.

(24:24)

And so there is all sorts of interesting conversations and enables us to have with our customers around the value trade. And so we are creating a lot of value for you because we are creating this instant payment rail for you. We are opening up tons of opportunity. They are in terms of paying vendors faster, accessing inbound funds quicker, but what is the responsibility that comes along with getting that? And that we need to think about how we educate them in that term and say, what is the value trade? And when you have, especially your larger clients, think about it that way. It is just a relatively easy conversation. It is an opportunity to deepen the relationship and get them to think about what you can do for them in a very different way. One of the old roles I was in, we were actually contemplating building an internal consulting group to just work on how do we work with our large clients and get them to really understand it and partner with one of the big three, big four accounting advisory firms and get them to understand what we can do and how we can be transformational. But it is not just about saying, oh, I can do this. It is not going to the Cheesecake Factory and figuring out what you want off the menu. It is figuring out how do you take the ingredients and make something that they will really remember.

Chana Schoenberger (25:48):

Avocado egg rolls, who needs to make a choice. Okay, last question I am going to ask and then I am going to open it up to the audience. I have lots more questions, but get yours ready. Is this an area where banks can use AI or machine learning? Is there a way that those technologies can help solve some of these problems for you?

Uma Wilson (26:05):

100%. And this is also the challenging part about the technology and tools we leverage in banking environment and operations. It is more, perhaps it is just our bank. I would say we do buy best of breed technology, then we tend to have what we call the exception queue that has to be reviewed by every single human in this world validated that requires another person to make sure that whatever she did or he did is right. And I think those kind of make you feel processes are not sustainable in this faster payments rack. When you buy a tool, you have to believe in them and you have to back test them and you have to deploy that. But we all have that customer, the top 20 customers list. But as the top 20 is not just the top 20 at the bank level, but top 20 at individual relationship level, which means every client is an important client.

(26:56)

So when you reject the transactions or something happens, that always flares up and creates concerns and the satisfaction within your operations team and everything. So it is not always about you using the latest or greatest. Rather, it is time for us to challenge the traditional processes and oversight that we have layered around the existing processes to make us feel good. If the bank is willing to remove those kind of oversights and truly rely on technology and you can back test it, of course we always have to back test to make sure the model is working the way it should be. If you could do those things and you can reject transactions and not have a manual review done, I would strongly believe that AI and machine learning is probably be ready to leverage it.

Jesse Honigberg (27:38):

I will tell you that we have a weekly management call with all the senior leaders in the bank, and probably hard for you guys to realize, but I am a bit of a geek. And so with ChatGPT when it came out, I was playing around with it quite a bit and I stood up in instance of auto GPT, which is kind of the version of ChatGPT or the GPT three five turbo engine, whatever that you can implement, that will actually be a bit autonomous. So it will go spin up browser windows, it will search for things, it will produce a finalized document for you. And so on this management team meeting, I asked it while we were talking to tell me how to run a bank more effectively and it spit out, opened up a bunch of browser windows, it did all this stuff, and it actually spit out a relatively comprehensive answer to this.

(28:29)

The reason why that is relevant to payments and fraud is that think about if I said, how would Jesse Hoberg based on his social media profile answer a question like this? And I can as a fraudster now spin up that tool to think about it based on data I get off the dark web looking at transaction heuristics. What would their transactions look like? How would I replicate that? How would I keep it so I stay under an 80% variance because I know that the banks will typically look at anything that is three sigma. And so it presents a lot of interesting challenges for us if we think about things, but it also gives us opportunities to think about how do we leverage that? And things like system to system payments, embedding directly within your customer's flows. It won't necessarily solve the consumer payment risk entirely, but on the commercial side, it is a huge opportunity for you to go to your largest clients and say to them, why do you have an AP group logging into online banking to originate wires when you have NetSuite and we have an integration that we can put together for NetSuite with you.

(29:44)

Right? Once you are doing that, you have eliminated the entire most of that threat factor. And I think that the opportunity for us with these tools is to figure out how do we use them as levers to drive behavior we want while being aware of just how scary it is that they could be if put in the wrong hands.

Chana Schoenberger (30:08):

That is really frightening, but an interesting idea. Okay. We are running low on time, so I am just going to take one question. Yes. Right in the middle of the room. There is a microphone coming your way.

Audience Member (30:24):

Hi. Hello. Thank you. Great session. Some more enjoys from paper plane. I am really interested in chargebacks on scheme rails, thinking about consumers potentially using real-time payments to pay for goods and services and not having the protection of raising a chargeback if something goes wrong. Conversely, on the other side of that, do you think that there is a risk of merchants who may have been at risk of going above the 1% chargeback golden rule of, oh, there is something maybe we do not want to keep acquiring for this particular customer. Do you think realtime payments has the ability to start masking some of those problems because of the lack of chargeback rules?

Uma Wilson (31:07):

Okay, so I just want to make sure I understand your question. It is more the chargeback questions that.

Audience Member (31:12):

Yeah, so scheme rules that cover the card networks do not really apply to real-time payments.

Uma Wilson (31:18):

I know the session is all about Fed Now or the instant payments or faster payments, whatever terminology we wanted to use. We have been living with a concept around faster payments or real-time payments in the form of cards and card network. It is not new to bankers or technologies and systems and our customers are used to it rather than using a card. Maybe they go to a digital portal or something that they just order through an API transaction, somebody is making transactions. So it is not new chargeback. I would say that the whole purpose of this being a credit push only application, it just beats the purpose of having chargeback, then you are going to have return rules and things like that. So it burns a lot more, I think costs associated with the payments if you are going to add all those complexity. So chargeback, I do not think they would probably consider, there is another form, there is an option to return the transactions, but the goal is if we do not use that frequently and keep it very simple. I think that will help our exception process as in the banking network is the best way I would say it.

Jesse Honigberg (32:25):

Yeah, I think it goes back to why do we have chargebacks and we have it because we do not know if there is finality on settlement. And so, all right, well, is the money going to actually be there from the issuing bank and am I going to get it and is the acquiring processor and is the whole mess going to work? And then it probably also turned into a way for people to make money and everything else. It evolved that I think the, while there is a request for return of funds in the real time payment schemas. I mean when I was at CRB, we never received one, I think the whole time I was there. And I think that we need to challenge our customers and challenge our internal folks around those things that we hold onto that are our safety blankets on process. And when someone asks you, well, what do I do with this?

(33:26)

And you say, well, why do we need to worry about that? If we understand the way a real-time payment works, if we understand that when the bank that sends it says yes, and I get that money, the bank can not ask for it back. They can, well, they can ask for it, but there is no guarantee they will get it back. You do not have to give it back and you do not have to give it back. It is a final payment. It is governed by UCC, like all sorts of interesting things. And it allows us to go to our internal teams and say, how would we design this process if we did not have all of this mess behind it? What happens if we did not have to worry about a chargeback? What happens if we knew we were going to get the funds or we were not going to get the funds? Would we need all of these different checks and balances and processes? And someone will inevitably argue yes. And hopefully there is more people arguing now.

Chana Schoenberger (34:17):

Well, thank you very much. We are out of time thanks to Jesse and to Umma for this very interesting panel and I am going to go reinstall my Zelle now.