Banking on Cannabis: Risks, Rewards & Regulations

Sonia Portwood (00:06): Hello and welcome to Banking Out Loud, a podcast where we have candid conversations and deliver insights on banking topics that you care most about. I'm your host, I'm Sonia Portwood. And today, we're gonna talk about navigating the green frontier, the opportunities and the challenges of marijuana-related banking. In today's evolving landscape, marijuana-related banking presents a very complex and nuanced opportunity for community financial institutions, or CFIs as we call them. We're going to do our best to provide you a comprehensive exploration of the MRB banking sector. We're gonna examine the current regulatory environment and the potential risks and strategic opportunities. We aim to equip you with the knowledge needed to make informed decisions in this emerging market. (01:01): We have two very special guests with us today to help us cover this topic. First, we have Tony Repanich. He is the CEO of Shield Compliance where he leads the day-to-day operations and is the company's principal product architect. Prior to joining Shield, Tony operated a consulting firm focused on cannabis banking and previously served as a senior executive at Washington State-based community bank for 25 years. Tony has an in-depth knowledge of the banking industry and the regulatory and compliance requirements for high-risk industries. Today, he brings the knowledge to financial institutions serving and considering serving the legal cannabis industry. Welcome, Tony. Tony Repanich (01:47): Thank you. Sonia Portwood (01:49): We also have our very own Aviva Lipkin. She is senior vice president, BSA, AML, OFAC officer at PCBB, where she leverages her extensive expertise in regulatory compliance, anti-money laundering, and financial crime protection. Aviva plays a pivotal role in guiding the company's risk management strategies. She's also the founder of Audit and Compliance Advisors, demonstrating her entrepreneurial spirit and commitment to helping financial institutions strengthen their audit and compliance frameworks. Welcome, Aviva. Aviva Lipkin (02:27): Thank you, Sonia. Sonia Portwood (02:28): I'm so happy to have both of you here and I'm, I'm very anxious, uh, about this conversation because, uh, you know, there's a lot of talk, a lot of banks that are in this and they're doing a really good job of it, but there's also a lot of fear around it and I'm hoping we can des-, demystify some of that for our listeners. So, uh, why don't we just jump right in. Are y'all ready? Tony Repanich (02:49): We're ready. Aviva Lipkin (02:49): Let's go. Sonia Portwood (02:50): All right, great. So why don't we start with the green landscape, you know, kinda understanding the current MRB environment. Um, so Tony, if you don't mind, I'll start with you and I'll ask you to start by giving us an overview of the current state of the MRB industry and how community financial institutions, CFIs, are currently engaging with it. Tony Repanich (03:13): Well, Sonia, thank you for the introduction and for having me today. Looking forward to this conversation. You know, community financial institutions have really led the charge in terms of serving the legalized cannabis industry. This industry is now a $35 billion retail industry. Behind that is also product manufacturers and farmers in terms of cultivators, uh, growing the product. And so there's a, a huge group of folks on the wholesale side and the retail side that need access to banking services. At the same time, while adult use legislation continues to be adapted across the country, replicating what happened years ago in Washington and Colorado and California, we're now seeing that emerge in places like Minnesota and Ohio and New York. Um, there is a, a lot of consumer demand for these products. (04:12): Now, we're also in a situation with the cannabis industry itself, where if we kinda remember back to the early days of dotcom when it didn't seem like it mattered if people made money, it was just how many eyeballs we had and that was gonna be a measure of success. There was some of that same euphoria in the cannabis industry as legalization occurred. And we're really entering now into a second stage where, uh, more level heads are approaching the industry. We're seeing consolidating margins in the industry, the very compliance heavy business. And, uh, it is not, uh, lottery tickets when you get a cannabis license. It's a hard business to operate and they need access to good financial services. And so we see today about 240 financial institutions that have stepped up to serve the industry. Now contrast that against the fact that there's just a little bit shy of 10,000 banks and credit unions across the country. And so it's still a smaller subset of the, the larger universe of financial institutions. (05:19): As I mentioned earlier, community financial institutions have really led the charge with adapting to the guidance that was put out by FinCEN over a decade ago that outlines how to serve this industry and comply with the BSA/AML requirements knowing that this is federally illegal, but states across the country now have, um, legalized this. Financial institutions that are getting into this business, they are focused, first and foremost, on gaining low-cost deposit balances. And for the most part, the industry has most of their dollars parked in non-interest-bearing checking accounts. So in an environment where we have rising costs of deposits, that's very attractive to financial institutions that are looking for low-cost deposits. (06:10): At the same time, we see some of our bankers are getting into lending to the industry, although that has predominantly been commercial real estate, many of these businesses are still in that startup stage. Generally, not a place where community financial institutions participate in lending and some of the loan guarantee programs that would sometimes entice bankers to serve those more nascent or startup industries like SBA guarantees and USDA guarantees are not available because of the federal nature of those programs. But commercial real estate has been, uh, an area where bankers have been able to be rewarded for serving this industry. (06:52): And then, of course, non-interest income has been a big driver, although it is not the same driver it was in the early days of cannabis banking, partially because there's more competition in many markets, many bankers offering their services, and deposits are just worth more than they were a few years ago. And so some bankers are willing to sharpen their pencil in order to win those deposit relationships. And so the industry is, the industry is evolving and adapting. Um, sales are continued to, expected to grow to 70 million by the end of this decade. (07:31): Today, however, the $70 billion market is the illicit market. So we have a $35 billion legal market and a $70 billion illicit market across the country. And so as bankers, and we'll talk about this as we get into some of the BSA/AML risk considerations, it's not just about the difference between state and federal law, it's also the fact that the cannabis industry has existed in an illegal form for a long time in the United States, and it's gonna take a long time for that market to disappear. And as bankers, we're called upon to be the long arm of the law. And so we have to sort out between good businesses and bad businesses. Sonia Portwood (08:12): And tell me, how are the banks that are in this business today determining the good from the bad? Tony Repanich (08:18): Well, the states, uh, have done, for the most part, uh, a good job in terms of their state licensing, state licensing. So there is a, uh, program at each state level to identify who the licensed operators are and to vet those operators. Not all states are created equal in terms of the due diligence they do. And so it's important for bankers, first and foremost, to understand what are the licensing requirements in their individual state. Those licensing requirements also drive sort of the market economics. I'll give you a sort of a for example here. You've got Oklahoma that at one point had issued over 10,000 licenses for a medical only state. No offense to my friends in Oklahoma, but that's a lot of licenses for a state with a relatively low population. Sonia Portwood (09:09): (laughs) [inaudible 00:09:09] Tony Repanich (09:10): And so a- at the same time, you have a state like Florida that just issued a handful of licenses for a very populous state. And, and so the economics of those businesses were vastly different between an Oklahoma operator and a Florida operator and the amount of capital it took and the vetting of those license holders. So as a banker, I need to understand what are the licensing dynamics in my state and how does the state vet those license holders. That's gonna be my starting point to understand the quality of the people that will be applying for banking services and what additional vetting I might want to do. (09:50): In addition, most states have implemented a pretty thorough seed-to-sale tracking program, meaning they're tracking the movement of inventory from cultivation through the wholesale channels all the way to retail and out the front door of retail or the dispensary. Uh, and that information not only talks about the movement of inventory but the dollars associated with those moves of inventory. And so as a banker, I can capture that information and then begin to correlate that to my deposit activity occurring at the financial institution. So I, I wanna know that the dollars that I'm taking in are highly correlated to the legal sales activity that the state is monitoring and taxing. And so there's, um, good programs out there at the state level that companies like Shield, uh, can tap into, get that data for bankers, and then use that in the analysis. (10:49): In addition, you know, the offense and guidance calls out for continuous enhanced due diligence. And so the bankers not only are reconciling this deposit activity, but also monitoring the owners of these businesses on an ongoing basis, the business itself, the license that they've received from the state, making sure that they remain in good standing, not just at the time they applied for services at the financial institution, but throughout the course of the relationship. And so bankers need to be able to demonstrate that to their regulators when they come in. And a good playbook has been written and regulators are accepting of that playbook of how financial institutions are accomplishing that. Sonia Portwood (11:32): Okay, that's good information. So following the playbook is key. It's been proven in talking to regulators, so at least there's a template out there for banks to consider should they wanna enter this industry. Tony Repanich (11:44): Absolutely. Oh, Sonia, and I would mention, I think one of the things that comes up in, in a number of our conversations is, well, you know, community financial institutions, um, are serving this in- industry, but it's of all charter types. And so we ... You know, a lot of times, people say, "Oh, it must only be state-chartered banks or state-chartered credit unions." In fact, in our portfolio loan, we have folks in every single charter type. And so all the bank regulators, state and federal, have exposure to financial institutions serving this industry. Sonia Portwood (12:17): Can we assume that it's not just within the states that have some form of laws in place for cannabis? Tony Repanich (12:24): Well, it's interesting. One of the kind of larger programs in the central part of the country is actually a, a Texas-based financial institution. And while cannabis is not legal in Texas, they're making hay in places like Oklahoma, New Mexico, and Colorado ... Sonia Portwood (12:38): Yeah. Tony Repanich (12:39): ... from their headquarters in Texas. Yes. Sonia Portwood (12:41): Perfect example. Yeah. Okay, thank you. So Aviva, what do you think is the most significant regulatory and compliance challenges that they're facing right now? Both federal and state. Aviva Lipkin (12:55): Yeah, very similar to what Tony had, you know, mentioned earlier on, I think it's the current challenges have been the differences between federal and state laws. As we are all aware, under federal law, marijuana is still considered a Schedule I drug, hence making it illegal. And under state laws, many states have legalized marijuana in one shape or another. And so as a, as a bank trying to get into this space, that bank really needs to juggle the differences between their state laws and what's allowed versus the federal law that still considers this to be illegal activity. And that definitely is a, is a big, uh, challenge for banks. Sonia Portwood (13:38): Right. Um, so there's rumblings out there about potential legislative changes with the new regime in Washington and then there's the SAFE Banking Act that may alter the landscape a bit. Uh, why don't y'all comment on that? You wanna start, Tony? Tony Repanich (13:58): You know, I'm not very optimistic about this administration taking, uh, aggressive action on cannabis reform and ... Sonia Portwood (14:10): You know, I'm gonna pause you there. It's funny, I've had this conversation with at least six people in the last two weeks and very different opinions on what's gonna come out of this, so should have taken bets on it. But anyway, sorry, go ahead. Tony Repanich (14:25): (laughs) Sonia Portwood (14:25): (laughs) Tony Repanich (14:27): Well, I ... And I'd be curious to hear what some of those opinions are. I think that, um, you know, the, Trump, uh, supported legalization in Florida a- and that did not pass for adult use. They have, currently have a medical program there. They required a supermajority. So, uh, majority of Floridians wanted legalized cannabis but did not reach that supermajority threshold, but Trump did throw his support behind that. At the same time, uh, Pam Bondi, who is up for DOJ or for the AG's position, uh, was spearheading legislation in Florida that indicated that marijuana was a gateway drug to fentanyl. And so there's these sort of competing factions within the Trump administration about, uh, the role of cannabis in society. At the same time, uh, in Congress, you've got Mike Johnson who's never supported safe banking and he controls what goes to the floor. Obviously, he's a good soldier, and if Trump really wants something, I, he will, uh, comply, I would suppose. And, and Thune is not super interested in cannabis either. So I don't think we're gonna see a lot of political capital being spent around cannabis, especially given some of the other priorities of this administration. (15:45): Now, barring some sort of event where Martha Stewart and Snoop Dogg show up at the White House for coffee, um, you know, that, there are personality-driven decisions that also happen within the administration and that could change the dynamics there. So I think we're gonna be in this holding pattern for a while where we have this difference between state and federal law. We're also waiting to see in May, uh, what happens with rescheduling that is now in the administrative process but was delayed by the courts. Basically, DEA and HHS were sort of at war with each other about how to move forward with, uh, rescheduling. And so rescheduling would have some added benefits around taxation and sort of lower the, the legal umbrella that covers marijuana, although I will say that Schedule III of the Controlled Substances Act still does not adequately represent what the cannabis market looks like today. There are no recreational drugs on Schedule III of today's controlled substances schedule. So I'm not super excited about regulatory reform or the passage of safe banking, but I don't think we're gonna go backwards with this administration. Uh, I think they understand this is, this is big business now. Aviva Lipkin (17:05): Uh, and, and if I could add to that, um, and I, I wholeheartedly agree with what Tony has said. When Trump came in in his first administration, he did rescind the Cole Memorandum. And if, if you recall, the Cole Memorandum actually was the memorandum issued to banks that gave us the ability to work with legalized marijuana shops with the rescission of this memorandum. Even though banks still maintain kind of the spirit of the Cole Memorandum, it did put a little bit more scrutiny on the fact that, once again, we were left with this world of, um, inconclusiveness, you know, where you just didn't really know how the federal government would react, so. Tony Repanich (17:46): Yeah, Aviva, I think you're, I think you're spot on cuz if you think about the Treasury's FinCEN guidance, it actually references the Cole Memo. They reasserted the FinCEN guidance even with that reference in there, but as you said, Jeff Sessions threw the, threw the Cole Memo in the garbage can in that first administration. Aviva Lipkin (18:03): Yeah, so I, I'm with you. I think we're gonna be sitting for the next, you know, year or two, for sure, in the same kind of pattern of do the best (laughs) you can and hope that no one comes after you. Sonia Portwood (18:16): (laughs) Well, we've kind of been in that state at least from where I sit for some time, but what we're trying to do is help alleviate the risk that goes into marijuana banking. So why don't we jump in a little bit about regulatory challenges and compliance strategies? So I'm gonna start with you, Aviva, and I'd like, uh, to talk a little bit about community banks, their reputation risk, and other risks that go along with that and what they can do to mitigate those. Aviva Lipkin (18:44): Uh, yeah, sure. So if I was sitting here advising community banks on best steps in getting into the space or if you're in the space to maintaining a healthy program, it really usually starts with a solid risk assessment. A bank would wanna take a look at their overall products and services and just see how does getting into the MRB space impact its overall risk and really do a deep dive, you know, risk reward, is it worth to get into the space? What would that look like after the bank assesses that risk and assume they determine, yeah, it's something that they would like to get into? Board approval is very important. It's good to get senior leadership on your board, uh, on board (laughs), so to say, to ensure that everyone kind of understands the risks and rewards. And then you start to build your program, right? You reach out to experts in the field, maybe you reach out to a Tony and you say, "Hey, you know, help me create a program that's fit for me, you know, for my institution." And that would include everything from starting with policies and procedures down to how will you on board your potential MRB client, what will that look like? Do you go out and do site visits? Uh, what type of paperwork do you require? (20:07): Obviously, you wanna make sure that they're licensed. Once you onboard them, with what frequency do you re-review them? Is it every six months? Is it every 12 years? Again, very risk-based kind of analysis. You know, the Bank Secrecy Act requires banks to file SARs. So the community bank would need to ensure that they have adequate transaction monitoring, that they're not only filing SARs tied to potential illicit activity, but that they're also filing SARs that are limited SARs or marijuana-limited SARs, where you really are just filing for the mere fact that you have a customer that's an MRB and they might not be doing anything wrong, but you still are required to file the particular activity for that customer. And then you go into a whole other set of, uh, requirements around training, training your in-house people, maybe even training some of your customers to ensure that they kind of understand the landscape. So all of that (laughs) kind of would build a solid compliance program for an institution that wanted to get into the space. Sonia Portwood (21:15): That's a lot, but a lot of those processes are already in place. You're just having to get your arms around and maybe additional monitoring into a different high-risk vertical. Aviva Lipkin (21:28): Yeah, I would completely agree with that. A lot of these processes are in place, but they, they would need to be enhanced, meaning, yes, banks are monitoring for illicit activity, but here, maybe banks would need to monitor slightly differently, uh, when it comes to marijuana-related activity and banks conduct onboarding and periodic reviews. But in this case, they might opt to do more frequent periodic reviews, do site visits, uh, ensure the licenses are still up to par. So it's, it's, it's like, it's what would be called enhanced monitoring and enhanced due diligence for, for this particular business. Sonia Portwood (22:12): Um, so from having this conversation, we have proven models that work with the regulators, right? There are models that you can follow to ensure that you are meeting the regulatory requirements for this business. So Tony, do you have s-, uh, maybe a case study or a story from an institution that's been successful at integrating this service that you might be willing to share with us? Tony Repanich (22:40): Yeah, I, I think we ha-, we have a number and they have some very similar characteristics for these highly successful programs. And, a- and it really starts with some of the things that Aviva was talking about in terms of management's understanding of the economic benefits to the financial institution and the risk assessment for the institution. Really, what is the talent that we have in our team to do this enhanced due diligence? And so what we see that's really common in these programs is, one, is what is the financial institution trying to accomplish by serving this market and taking this additional risk? Also, having very open conversations with their regulators as they're building and getting into this, this business. And what we found in most cases is the regulators have been very willing to provide initial feedback on the institution's policy and risk assessment. And so they're never gonna say, "Woohoo, you should get into cannabis banking," but they will say, "Hey, have you considered this?" or, "This looks similar to what we've seen in other successful programs." And so- Sonia Portwood (23:49): And Tony, just to be clear, this is in pretty much all the states where, uh, where the banks have started cannabis banking, right? Tony Repanich (23:57): Correct. Sonia Portwood (23:57): You're hearing this from all the regulators? Tony Repanich (23:59): Uh, I would say ... I mean, the, the state and federal regulators have been, um, very good about, um, wanting to understand these programs. You know, I'll give you ... For example, the Federal Reserve Bank, uh, in Chicago, uh, invited us, us in to do training with them because they wanted to better understand how banks were using technology to help with this challenge. And so I think the regulators, you know, they are also working in a situation where they are wor-, where they are having to rely on the FinCEN guidance and not the normal exam procedures that would be published for things like payment processing. And now they're high-risk businesses. And so they've been building their own playbook, too. And, and they are, for the most part, willing to engage in these conversations and make sure ... They want their bankers to be successful and don't want their bankers to be in a situation where they're out over their skis. And so we encourage those early and frequent conversations with their regulators. (25:00): The other thing that we've seen in the, in the most successful programs is really understanding that these clients are being asked for a lot of information, not just at the time of new account, but throughout the course of the relationship. And so really having a sales and relationship management team that i- is highly engaged in the industry, it helps with gaining referrals, but also there's a language for this industry. Um, things like seed-to-sale tracking and understanding what different licenses do and just how product moves within a given market. And so a banker that understands those things can be able to relate to that customer and build trust and, and rapport. And so when I'm asking you for more things, when I'm coming by for that next site visit, it's a relationship, um, that's less adversarial. Oftentimes, you know, compliance can feel adversarial for, for customers. (26:01): And so that dedicated sales team or at least folks within the institution that this is a high area of focus for them is really important. And then i-, real alignment between what's happening in the BSA function and on the sales side of the organization and clear accountability and responsibility for different pieces of the compliance program. And then lastly, there's impacts on places like finance, internal audit, and making sure that those folks are buying in and understanding what the institution is doing. This doesn't solely just live in BSA on a little island. It is, can impact the whole institution. And so, for example, are these customers gonna have access to the branches and what impact does that have on the branch environment? And so it's managing all of those different departments within the organization and making sure that everybody's aligned. And, and when people ... When organizations do a good job with that, we see they have really successful programs. Programs that live on an island oftentimes struggle. Sonia Portwood (27:05): Now you're gonna not only have to have approval from the board all the way down, you're gonna have to have top-down involvement and support for, it sounds like, almost every area of the financial institution. Tony Repanich (27:18): Absolutely. Sonia Portwood (27:19): Yeah. I love the idea about the specialist. You know, that makes such a huge difference because I would imagine that some of these MRBs are looking for some guidance potentially from their financial institution. Tony Repanich (27:32): Absolutely. And I, I think about it back from my being a banker days and part of our portfolio was ag and I, I think one of our commercial lenders, Bill, and if you are a farmer and a dairy farmer, you probably wanted Bill as your banker. He knew everything about running a dairy business. And so he was a real partner to those customers. There's a similar relationship that happens here. These businesses not only require a lot of compliance, but they also require a lot of capital to be successful. And so having a banker that understands your business, eventually, hopefully these customers will become better borrowers and qualified for loans with the financial institution and you'll have a real advantage by understanding the business and, and what drives success and margin improvement and all the things that allow you to repay loans. Sonia Portwood (28:26): Yeah. Okay. So l- let me ask y'all, do you see any changes coming or do you have any insights into where you think this may evolve? And, and I realize this is strictly opinion, uh, but is there anything you wanna share? Tony Repanich (28:48): Well, Sonia, uh, I think what we're going to see i- is sort of three key things over the next few years. One is I think we're gonna see continued consolidation within the cannabis industry and, and realignment within the industry because it is a difficult market. And so we're kind of coming to those second-stage owners. And ... So I think owner quality is going to improve significantly operator quality as this realignment continues to occur. Sonia Portwood (29:14): And you're talking about the MRBs. Tony Repanich (29:16): On the MRB side. And we're gonna see that from a banker's standpoint is really finding those operators that are, that are rolling up businesses and then that are acquiring assets that may be very, uh, well priced today because the legacy operator i- is under financial constraints. And so we're gonna see some real, I think, sorting out of the winners and losers over the next few years. And, and there's opportunity for bankers to find those, those winners and support them. (29:45): I think we're also going to see an emphasis, uh, to really crack down or change the nature of the intoxicating hemp market. That provides ... That intoxicating hemp market that really developed out of the farm bill and is different than the state-based cannabis programs that we've been talking about today does create a lot of confusion and competition for the state-based cannabis programs. And there's a lot of concerns about product quality, product safety, access for children of those products that come from the intoxicating hemp market. I think Congress may actually be motivated to do something there around the farm bill to try to rein that in. In the meantime, we've seen individual states try to rein in access or at least the disclosures around those intoxicating hemp products. And then I think the last thing we're gonna see is, um ... You know, I think about ... When I started in banking, I think there were 14,000 banks, not even including credit unions back in the early '90s. And, y- you know, we're down to sub-5,000 banks now. At the beginning of the financial crisis, we were at almost 10 of the last financial crisis. We were almost at 10,000 banks. There's ... We're gonna see further consolidation in banking probably over the next few years if we follow that same sort of every decade cycle of, uh, mergers and acquisitions. (31:14): And with that, there will be financial institutions that decide I'm buying this bank, but t- that ca-, this cannabis program does not fit my risk profile. So we'll see people move in and out of the business based on their risk appetite. And what we are seeing is some financial institutions that have really doubled down on this line of business and are looking to acquire those books when they become available. Sonia Portwood (31:44): Yeah. Tony Repanich (31:45): And they are building national programs and expertise in cannabis banking. So scale will matter for financial institutions getting into this space if they wanna attract the best operators serving either in a single state or region of the country or, or, for some, a national approach to cannabis banking. Sonia Portwood (32:06): I have two questions from that. First is from a staffing standpoint within the bank, who banks MRBs, is there any statistical data that would give you an indication how many employees you need based on the number of transactions you're processing? Tony Repanich (32:24): We do an annual benchmark study with our financial institutions to, uh, evaluate their staffing levels against the number of MRB relationships that they service. And so what we generally see is about one BSA analyst to every 50 relationships. And so the transaction volume does impact that, uh, slightly, but when we look across our portfolio, you can do the reviews, file your SARs, manage your CTR reporting at about one analyst per 50 relationships. Now that analyst is gonna have a BSA officer that is supervising and reviewing their work, so there's some impact on that BSA officer's time, but the analyst will be doing the heavy lifting. Sonia Portwood (33:12): Okay. That's good information. Uh, secondly, I'd be remiss if I didn't ask you, I would imagine that, uh, relationship managers or anyone on the front side of the bank and calling on these industries are, are in high demand. If a bank was looking to get into this and they were looking to hire someone that could help lead the sales side of the business, where would they find them? Tony Repanich (33:36): Well, that ... You know, that's a very interesting question. If I look at our portfolio, um, many of our best bankers are sort of homegrown. Sonia Portwood (33:46): Okay. Tony Repanich (33:48): Here's what we do see in terms of, uh, where there's been real success for financial institutions in home growing these folks is think about cash management and treasury officers. They often, uh, are selling deposit products or cash management products that require additional underwriting. And so it's not as simple as just walking into the branch and walking out with a checking account. There's complexity in terms of the technology the customer might be using and the security requirements and the underwriting of the business if there's financial risk for the community financial institution. And so those folks are generally really good at taking referrals from commercial lenders and branch staff. They, they kind of cultivate business from those internal referral sources in addition to their own calling activities. And so we find that oftentimes the personality that does well in those cash management or treasury jobs, um, can be trained up to learn the cannabis industry and leverage those banking skills that they already have. Sonia Portwood (34:55): And that's perfect. That's kind of the way the bankers grew up, um ... Tony Repanich (34:59): (laughs) Sonia Portwood (34:59): ... like, in their own. So it makes perfect sense. Aviva Lipkin (35:03): Yeah, you can always, uh, reach out to your BSA officers who are interested in changing jobs and maybe wanna be on the sales side. Sonia Portwood (35:11): Oh, are you hinting at something, Aviva? Aviva Lipkin (35:12): Uh, no, not necessarily, but, you know ... Sonia Portwood (35:14): (laughs) Tony Repanich (35:15): (laughs) Aviva Lipkin (35:17): ... k- keeping it light. Sonia Portwood (35:18): We'll talk. We'll talk. Tony Repanich (35:19): (laughs) Sonia Portwood (35:21): I hope we've shared, uh, a lot of information that was very useful to, to our listeners, but, um, is there anything that we didn't cover that either one of you or both of you think is important that we share before we end this podcast today? Tony Repanich (35:38): Well, Sonia, I would add, as bankers look at entering the space, one of the key considerations is, is counterparty risk. And so as a financial institution, I need to evaluate, does this negatively impact my D&O insurance coverage, for example? So talk to my insurance carrier. But one of the other conversations that you're gonna need to have is with your correspondent banker, um. Sonia Portwood (36:01): Right. Tony Repanich (36:02): There are ... Obviously, there's a lot of functions where it's a relationship between the, the financial institution and that correspondent, but there are times that there are services that are provided where there's a named customer that's part of that transaction. Think about international wires or currency exchange. And these businesses, especially some of the more complex, larger, uh, operations, need some of those services. And so understanding how will your correspondent view your entry into this business, what restrictions will they place on you as a financial institution in terms of the products and services that you can extend to your customers? And so it's engaging in a conversation and understanding what your expectations are. Sonia Portwood (36:48): Excellent advice. Uh, so what a pleasure it's been to have both of you on this podcast. Uh, we really thank you both for joining us and, and sharing your invaluable insights and expertise. It, it's been a pleasure. Aviva Lipkin (37:01): Well, thank you. Tony Repanich (37:02): Thank you, Aviva. Thank you so much. Sonia Portwood (37:04): And so for our listeners, we wanna thank you again for tuning in. We hope you found this conversation beneficial. I certainly did. We've covered a lot, but hopefully, you're walking away learning something new or with takeaways that will help you and your institution succeed, which is always our goal. If you haven't already, make sure to check out our other episodes and subscribe, so you'll be the first to know when we drop a new episode. Also, we're always looking for suggestions on what to cover. So if you have something in mind and would like to be a guest on our podcast, please let us know by emailing us at bankingoutloud@pcbb.com. Until next time. Happy banking.