Regulation Reimagined: Banking Beyond Partisanship

0:02 You're listening to Leaders in Lending from Upstart, a podcast dedicated to helping consumer lenders grow their programs and improve their product offerings. Each week, here decision makers in the finance industry offer insights into the future of the lending industry, best practices around digital transformation, and more. Let's get into the show. Hi, you're here with Lynn and Matt from Upstart, and we're happy to have Kelvin from the CBI on the podcast today with Leaders of Lending. Kelvin, would you want to introduce yourself to our listeners? Sure, thanks so much, Lynn, and listeners that are on video, just be warned. I thought that this was a podcast, not a video podcast, which is why I'm dressed the way that I am so. I recently joined the Consumer Bankers Association about five months ago to help coordinate the policy work that we do.

0:52 And so you know, we have a new CEO, Lindsay Johnson, that y'all interviewed last February. And you know, one of the things that among the changes that Lindsay made, which I was super excited about, was she took our regulatory team, our lobbyists, our communications function, and a new data function and put them into one squad with a kind of recognition that advocacy these days has to go across those different travels. And prior to this, I was at Barclays in the US Consumer Bank, where I was in the ex CO, I was briefly very leading the regulations policy function. I was at Capital One where I led the bank regulatory and policy team for several years, and then I had roles at the Federal Reserve Board, the CFPB, and the Federal Trade Commission, and then I was allitigator in New York for several years. Oh wow, so you've had quite a great experience.

1:38 You're being like industry regulators, government litigation. So a little bit about rething my eleven year old. It's very worried that I can't keep a job, and I keep telling them that these are like progressives, but it's like this is like the new economy. But he's very old school. Yeah, always interested in banking. Or how did you get into the CBA, the aggressively mortar banking? So basically everything after CFPB was banking. Yeah, CFPV very topical. We had director of Choprah, we did and we did. What were your thoughts on his speech? His remarks. Uh, and maybe tie that back to your experience at the CFPV. Sure, I have to start by saying I love the CFPB. Right, So I was part of the kind of first generation of CFPB ers as was right. Oh see you were there when Quadra we're both from Ohio, part of Yeah, I actually before upstart met through politics. Oh why gosh, yeah, yeah, but that's right. So like I did, I did my my time at the Bureau under Rich Quadray, and you know, I am and continue to be a true believer of the CPB. I did moral minors at the CPB than I did in several years. And I have a practice in New York. But you know, uh, Lindsay recently testified to me hearing on the Hill where the focus was the politization of financial services regulation. And so as part of the wind up for that, you know, we sat down with a reporter and they said, well, gosh, like, isn't all regulation politicized?

2:55 What is it? What does this mean? Right? How things changed? And it was a it was a good moment to kind of stop and say, oh, how have things changed? And you know what I would say is that back in my day under Director Cordre, you would focus on facts. You had a bunch of resoarch economists, you had market analysts, and the facts were the facts, and you'd set out kind of a good understanding of the market, and then you'd lay out a menu of policy options, and then the director would choose from those policy options, and politics would have to play because you'd have to figure out like what would work and what wouldn't work. Then you write a headline and you go to market. While from the outside in and understanding that I'm on the outside now, it feels like the agency is starting with the headline and then working backwards. Right, So you have an administration that is fixated on junk fees and they recognize that among the electoral messaging, junk fees are one of the few things that sticks.

3:47 So then that message goes down to the team saying, okay, give me some policies that you can sell politically, and so picking on big banks is something that politically sells. Then you back up into that and say, okay, then what will be the policy interventions? And then perhaps the most concerningly, then you choose your facts, and so you know, one of the things that I can go on for like thirty minutes about this. But that we've been kind of really in just very concerned about are just the facts that are coming out of the BUREAUM. So the director today talked about competition in the credit card market, and there's this notion that the credit card market is not competitive, and this is pervasive, right, This is why they justify their late fees rulemaking, this is why people talk about credit card interchange.

4:28 And the thing I would note is that one there four thousand issuers in the credit card mark. You guys know this better that you're your listeners know this better than anyone else, you know. The director talked about concentration of the twelve largest issuers, like I can't imagine any industry that has twelve of anything, right, like twelve leading airlines, twelve leading computer manufacturers, twelve leading cell phone manufacturers. But there are also like fifty billion dollars in billion transfers all using CFPP datum. And then I'll just a little bit more on this, then I'll stop, just because I get really fired up about credit cards, you know. The director also talked about how consumers are apparently firing more poorly credit cards when they talk about like super high interest rates. But in the speech today he repeated something that they'd said in their data before, where they said that the amount of subprime card holders has remainconsistent, and that's simply not true. Like, if you look at the cpeb Z owned Card Act data, the number of subprime card holders has gone up from like sixty two.

5:21 Sorry, the percentage of people that are the subprime space that have credit cards has increased about basically ten percent from twenty fifteen to twenty twenty twenty two. But then to the deep subprime space, we've seen massive inroads in underwriting to deep subprime consumers while keeping them paying their bills at good rates. So like that's financial inclusion working well. Actually you're seeing more more borrowers of the subprime space, not people kind of falling down to subprime, but actually like a growth of barrowers coming up to receiving credit, you know, and that's who may not have before. That's right, And that's the last part of my rant. And indeed, it's like I'll stop at this, but you know, there's this notion that you know, because you're bringing in and record numbers of deep SOB prime consumers but they're doing better than they ever have been before. So the Bureau also has charts where you're looking at basically the number of people that transact. Those numbers are all times highs. And then you're looking at the balance is that the progress people are paying into their balances.

6:15 And when the Card Act was first on in twenty fifteen, people are basically paying off like twenty eight percent of their loans each month, and we celebrated that. Under Director quadrat Well, they're paying thirty nine percent of their loans off each month. Right, And so again, like you can that's that whole kind of Daniel Patrick mornand thing where you can have your own opinion but you can't have your own facts. And that's where we're at right now. So I'll stop there. Thank you for letting me get that off my chest. So I like that. It seems like part of maybe your critique is that it wasn't a balanced view, right, So really focus on fees, deep on that versus understanding the whole consumer landscape and how each consumer is using the product and the need of the product and how we're better serving It's part of that, right, But it's also even if you're going to focus on fees, stick to object effects. Sure about the fees and how consumers are very One of the interesting things that that was part of the comments today was that the difference between a rewards versus non rewards credit card. And I don't know if you heard that, but it was kind of a you know, a nuanced that could be interpreted as consumers aren't aren't smart enough to choose whether they want their rewards versus versus maybe having a card with less cost but no rewards. So that was I think an interesting distinction to make was even not just the fees in general, but the very specific types of cards that are offered to do so, where do you see innovation coming from? Like it seemed like part of his message too, was like the government is necessary to drive innovation by creating some more parity or transparency. How do you feel about that? I struggle with that as well. I mean, I think the main thing I would look to just from the innovation space, and maybe it's

7:46 just because it's less flashy and people don't talk about it as much. If you think about all the innovations that have taken place in underwriting folks, and so you see that like to double down on this notion, like the deep penetration into the deep subprime space while ensuring that they're paying off their balances like at better and better rates. Like that requires a lot of like alchemy and data science and risk splitting, and it's I think it's kind of remarkable, and that's why I really bulk when we have policymakers that are kind of then bringing a chainsaw to something that is so delicately created. Yeah, I think and that you know, I know, you have been both kind of private and public sector, and so it kind of leads into into Map's question then, like you know, how is being on really both sides of that really kind of shape your perspective on kind of regulatory affairs and policy development. Yeah, I think that. You know, the interesting thing about financial services, so they're kind of two things that drive my personal career. One is even going as basic as like having grown up a minority in the Deep South, like I have a deep respect for what policy can do to making sure that people are treated fairly, particularly federal policy, So I think that's enormously important, particularly so in financial services. On the other hand, you know, when I was at the Bureau after we got through that first space of big rigs, you know, I started to see kind of the Bureau kind of moved to arguably kind of less impactful things. At the same time we saw the smartphone changing the world. Right, So I imagine like so many of the guests that you've had on the show, like head platforms that were built on or enabled by that one device. And so you know, I remember

9:18 sitting at the Bureau thinking, oh, I'll work like another two years and another rule that might like move the needle a little bit, whereas like these people in California are making the pie larger for everyone. They're changing lives, and so just a real recognition that you need the rules and you need to understand them in financial services, but that the only thing that makes the HIE larger for people and the only thing that really advances financial health to many products for it. Yeah, and so trying to mar the two has been kind of where I try to take my career since then. Well, and maybe describe a little bit for those who aren't familiar with the CBA and the different committees, like what what is your role as had a policy? Like what does what does that entail? And the day to day to week to week base with sure. So the Consumer Bankers Association is a banking trade group. We focus primarily out of retail banks and increasingly on banks that are ten billion dollars or more so banks is that are just above like the Durban threshold all the way up to the very largest banks. We have, as map points out, a wide range of committees in which basically bankers get together and just compare notes in an anti trust compliant way on how the world is changing, right, and so you know that the example I would use there is during the pandemic, like a lot of people are trying to figure out like is it safe to like reopen branches, but then how do we serve our customers and you know, how do you handle cash? And so we created a new committee that still stands now that helps people compare notes on that and just ensure that there's best practices there on the other side of the house. And that's regulatory change, and so you know, the goal there is to understand what regulations are coming down the pipeline and how they'll impact the banking industry and most importantly banks and ability to serve their consumers. And so we run data,

10:50 we talk to the hill, we work with the regulators, and ultimately like try to even talk to consumers so that we can help people understand how that regulatory change will path through lives and in some cases maybe impact the regulatory changes. I definitely think like your background, certainly in kind of consumer protection payments. I think payment space vans are about credit cards a little bit, but just payments in general, not being able to maybe go into branches for people who don't have internet access at home during the pandemic. I think what are you seeing is kind of the evolution of the payments landscape there. I think there's a proliferation of payments providers, and some of it's pretty concentrated still in some of the big banks. But like, what are some of those key considerations you think about, like policies, it relates to payments that would be good for the industry but also help innovation continue. It's a great question, Lynn, You know, when I think about payments, I think of it as like one example of why silos are so dangerous in regulation in payments right now. In many ways we're kind of typified by fraud, right, and so that's one of the things that we're all focused on the making industr orty is just and you hear stories. I mean, it's it's not uncommon to just hear whispers of institutions saying that credit losses are now like rivaling fraud losses because proud losses are so high. The thing I would note there is that you know, we have from like an advocacy and really a communications issue in the space, because when people think about broad in this space, there a lot of concerns are like a lot of people are looking backs to fix things, and a lot of people are thinking about even reopening long standing regulations

12:24 and that have governed the payment space since quite literally since I was born, because I guess Rege and the electronic funds transfer active done in seventy eight. The concern there is that there's this line in New jack City, right, this is bigger than you know Brown, right, And I think a lot of people don't really don't seem to appreciate, particularly for people that are folks in the banking sector, that a lot of the problems in this space exist outside the banking space. And so there are things that will involve the telecommunications companies, they'll involve the social media companies, they'll involve other government actors and so well, we're going to have to really work hard in the near future the de silo all that be able to start addressing these issues. So are you able to participate with those groups outside of the CBA or bringing some of those in or house collaboration go on with some of those. We're working on it. But I think that the thing that's interesting about REGs it's kind of different a business, is that in the government there's literally like a reg E part eight person at the bureau and like a Reggae Part B person of the bureau, and you coexist by like not not getting each other a stamp base, right, And you know, and the thing about fraud is kind of typified by its ability to arc over Like who would have thought, yeah, that like telephone companies would be the gateway for security for financial services, right, And so you know, trying to encourage people that to be more open minded and kind of learn across disciplines is we're all gonna have to learn that together. Yeah, I think we've certainly seen that. I know some of our attorneys and people in the government affairs space have been at industry events where a lot of the payments processors now are are companies like Meta or or really

13:58 what you think of the social media companies not not specifically a payments processor. And I think some of the some of the friction put in even by some of the banks to protect consumers can then make it hard to transact. So finding that balance is certainly hard. Do do does this see being involved in anything related to digital assets or anything crypto or is there something kind of outside of your space today? It's we care about it to the extent that it intersects retail banking, which right now, you know, most of the crypto conversation is more of nastic class or you know, kind of the background rails. I will say, like when I I'm a member of there's a group called the Digital Dollar Project that does some really interesting work thinking about a central bank issue digital currency. And you know, one of the questions I often raise in those conversations is, you know, what is the need that they're addressing and the thing that kind of take it back to the advocacy discussion.

14:54 People will often point to financial inclusion, the point to ubiquitous and faster payments, and you know, I'm stuck thinking, well, gosh, like we have a banking system that like we've got record levels of people being baked, we have record levels of subprime card penetration, and said, we're doing historically well. And I'm you know, taking my kid on travel overseas and like I'm not taking cash because like I can take this thing intab it anywhere in the world and I get points back, all right, and like like we're not talking about that, all right. And so one of the things we're realizing as a banking industry is we have to tell our own narrative matter because if we don't, like people are painting a picture of us, if we're not paying that picture for them. So what are some ways that you're able to do that being more proactive about that's a great question. Some of it is like, as you can tell, I get like really excited talking about this stuff. Some of this is really taking the facts in and educating folks.

15:46 So if you think about it's kind of before we start up with the credit card space, like we have a deck where we are going through and say, Okay, here's all the things that our regulators have said that's that their own data is incorrect. About que cards, and we are taking that to reporters, We're taking that to modern democrats on the hill and just educating people and just kind of sitting them down and kind of nerding out with them and showing the charts. The other thing I would note, you know, I used to say this when I was in government, is that the average American has to hear a song seven times where they like it right. And depending on what you think of government, regulators are either better or less than average. And so it takes time. But we're doing that work, trying to pay into building those relationships and trying to earn that trust with folks being received well or I think so, I mean, I think the thing is and this is the beauty of facts. And this is why I really worry a lot about just about the future of the CFPB. Like the data is the data, right, and so if you go in there and you're earnest with books, I mean, we go in there with some of the most hardcore like super progressive offices, but like the old heads that like help write the Card Act, if you sit down with them and you show them the data, like they're the ones that are most willing to engage because they kind of see the patterns, they see the numbers. Do you see most of that happening at the federal level or we're seeing even some activity at the state level in terms of great exportation or trying to bring control of the banking industry.

17:07 It's it's tricky in the states, goodness. I mean, we don't do a lot of work at CBA in the state space, but I will note like like increasingly everything from state legislation that would impact state tax and interchange to things like fair access requirements. It's just a very tricky space to navigate, you know. I think we've we've certainly heard that from from banks as they kind of crushed that gurban threshold and then have to pay the interchange fees where before they were exampt from them is a is a pain point. It sounds like the CBA many of the bank members are above that. So there you know, any any thoughts about those those kind of banks that are kind of right at the edge like where they you know, it's kind of a little bit above in assets and being subject to those is pretty painful versus like do you keep your assets a little bit low and need to do an acquisition to grow or how are the members thinking about that, about navigating that transition between those two two and aligns on the interchange space. That's a great question.

18:11 I can't speak to necessarily how the members are thinking about it, but what I would say is that that is a great example of how regulations can lead to kind of unnatural, like like business practices. I had dinner last night with a group of CEF and B alumni, including a fellow that was in the most recent team, and we lovingly got into almost like a real Housewives like table flipping argument because there's just a regulation on open banking, right, and they have this regulation that we kind of dream up this entirely new world that would have like they literally have two new definitions of consumer, one of which doesn't include natural consumers. Right, So it's like a very complex rule set that in many cases like they have weirdly specific definitions and then other cases weirdly vague spaces. And I use the Durban example that you just raised trusted look like when the Fed and Durbin did that ten years ago, I think no one anticipated that you would have bang intentional was staying below the number, Like no one anticipated the rise of these neo bakes, right, Like who wouldn't want to grow? Right? And like I think no one really thought about the impact like that has now been demonstrated of free checking and so then when you come in and like you kind of pan outside the lines of your statute and create all these new rules, just having a little humility to think about gosh, like what are the unintended impacts? Like what are the weird places we might to be pushing the market. It's just something that I think regulators have to keep in mind. Yeah, it you know, we push ourselves to like test and iterate so fast. Like do you see that happening in the government again, like recognizing where a law maybe was good for a time but needs to be adapted. Is it is there a faster rate of change do you think happening? I wish and you know, and this

19:41 is where I really want to have some empathy to regulators, you know, with the increased like politization and polarization that we're saying, and to some degree industry we did a little bit of ourselves. So there was a big lawsuit called Celia Law where we said, hey, ceefp of this five year term you should really be appointed by the executive and removable by the executive. But then like we then can't really complain then when then like the CPP is like more aligned with the executive and importantly is on a four year term. And so you know, I've done it where you know that you know that the administration flips, you have four years, you know, and then it's just a race to get the regulations done because you're worried, like my rule actually got undone by a new Congress because we didn't get out of the gate fast enough. And so you know, they're just kind of breaking off the mirrors and all the regulatory Of course they can to get to the end, but it doesn't lead to great results too. And we've depitate been I think it is kind of peering and seeing some of that. But the regulators, knowing this as an election year, what does make the regulation sticky? Then, like how do you differentiate between you know, kind of things that are put in place between now and maybe a change of administration and what can stick or it's really everything up for rescinding it that if the leadership changes. Gosh, that's a great question. You know that you can teach a whole lot of I've even tried to draw out like a lawsul law school syllabus. I'm like, if you had a class, I'm like, how do you make a persistent regulatory change? I mean, I think the biggest thing, ideally would be to to start with consumer need right, start with the data like where the market actually drives you, and then try to lead to a space where

21:12 people can serve their customers in a productive manner. I think once you go beyond that to kind of broader designs around the economy and kind of forcing it into natural spaces, your regulations necessarily get more brittle. Is that a consideration as you're going through the is like hey, I want this to last wherever, or you're just thinking like here's the problem in front of me, let's solve it and move on to the next thing. Or when when you're writing rights around here on our side of it. Either, Yeah, I mean, ideally, when you're writing regulations, you're thinking about like how do you kind of get the market in a natural space in a better equilibrium. You know. The one thing under director Coadre that I mean many things that I thought that was really kind of smart is that he would often look at the industry and say, okay, is the industry getting to a better place on its own right? And then so where do I then need to nudge right or provide clarity to get it there? You know? I think it's when you kind of again depart from that that it starts to get a little dangerous.

22:08 Yeah. And I think with the maybe we had some folks from the Fair Responsible Banking Committee on the podcast as well, the chair and vice chair. And I think fairness of lending has been obviously a key topic. And I think particularly with AI. Any thoughts on the Executive Order of AI last year that came out and it was pretty broad and not necessarily industry specific, but I think, how did you message that within the CBA or any feedback from the banks? Yeah, I mean I can do better than that. I'll tell you how we messaged it when I was in the government. Like so, when I was at the FED, I did a speech with Leel Brayer, who was amazing, and we did a speech in twenty seventeen about kind of where we saw artificial intelligence, where she saw artificial intelligence going in financial services. And one of the things that then Governor bring Her said was look, you don't always need to reinvent the wheel. You need to stop and kind of look and see what toolskits you already have and then see what needs to be again kind of the early point we made right like what are the incremental fixes you need to make? And in banking, as it turns out, there are a lot of regulations and guidances that apply to the use of artificial intelligence. There's model risk management, there's for a lending, there's guidance on third part of risk management. There's guidance on adopt bringing in new technologies and products, and so there's a lot of great talking collaboration needs to happen there, but there's a lot of good tools to start with that you don't need to reinvent. We see the CFPP increasingly leaning in on the use of AI in financial services, so they're calling for whistleblowers data thing today where

23:41 they're calling from our technologists. The concern that I have is that the CFPV, among other things, was created to basically ensure that consumers get the same protections whether they're with banks or non banks, but the Bureau, when they're thinking about AI releasing, is focused on big banks, where in many ways, like there's already like a good framework or tools, Like in the non bank space, non banks have no understanding of model risk management because there's no there's no regulator there, they aren't regularly examined for a co there's no TPRM guidance, third party risk management guidance, there isn't this guidance on new products and services, and so like I would like, there's so much good that the bureau could do if they would just like take that framework and start talking to non banks. It just doesn't seem to be that that's not putting their chips there, which is a little concerting. Do you think they're just kind of staying where maybe the I guess clientele is more comfortable that they're not ready to because I know the CFPB has made some statements and that you know, if there is a possibility of consumer harm, then they feel like they do have had a regulatory oversight over that, and they've gone after some non bank lenders recently. Do you think that they're just not quite ready to jump that farther, expecting an industry reaction or or what do you thinks holding them back from doing that. The CFPP for all the reasons they discussed before is very politically savvy. I'll give you the cynical view, and I'll give you the positive view. So the positive, the positive view is that consumers, a lot a lot of consumers used to be banks. Said you beat up on a couple of big banks, then you theoretically address a lot of consumers.

25:11 That more cynical view of that would be. I used to tell this story when I was at Barklays where there are two pieces of bipartisan legislation at the time that Tim Scott and Shared Brown were we're sponsoring. One was stopping fencible and then the other was taking executive conversation away from big banks. Right. So like that, I would say, welcome Bakers, like the one area where there's bipartisan support, is you infencible and not something you've would have been along, right? And so I think the bureaus like smartly realized and you see this in their messaging right kind of when they started out by saying, hey, we're after big banks, not relationship banks, right, And you see these carbouts with overdraft, we see these carbouts with late fees, like they thoughtfully kind of triangulated that if we beat up on this sector, that we're going to basically get a free pass on both sides. And so that's something that again like if that's the best politics. But I mean, I think I said it's perfectause like i'd write, it's my job to gribe like heard who cares about what spirit of banks? Right? It's not good for consumers, like because because every consumer, like you could, you know, Plaid has an update where they say, hey, like more people are using fintech than are using screening services, right, Like, we need the bureau there, like that's why the bureau exists, and so you know, I'm hoping that the bureau gets there. I was reading an interesting article earlier this week. I think I shared internally in our slack channels that many people who work for FinTechs have not the majority of people who work for FinTechs actually use a traditional bank for their banking services though, and have not poured it over their kind of day to day banking. So I do think that like,

26:41 FinTechs have made inroads in a lot of a lot of places, but many consumers are still working with the major banks or the regional banks on their their standard banking. So what are some of the current I mean other than you know, the things we've talked about credit cards, interchange fees, certainly a lot of a lot of complexity in headwinds. Anything else that are you see is like current pressing, trends, challenges, things you're hearing from the membership that they're worried about that you know what's next on the horizon. Yeah, I mean, I think the thing that I would note is that you know, we're seeing such a caste of regulatory change in an uncoordinated manner, Like in my limited government to a career, I've never seen so much change happening from so many different places in a non talk together way, right, Like at Dodd Frank at least there's like one piece of paper that it was all on, like one PDF that you download. In this case, like if you take them, if you think about like the banker that we've got that's trying to make sure that he or she can provide low cost checking account services to consumers. Right, so this is like a mitzvah, right, Like you're just like low cost checking accounts for people. That's like a platform that consumers can build their lives on. They've got a P and L that you're trying to manage down to like the penny. You've got the CFPV coming at you with overdraft regulation that could limit it to anywhere from three to fourteen dollars or something of this kind of CPB said price. At the same time, you have the Federal Reserve coming in cutting debit interchange rates by a third.

28:07 You've got possil rules that would require you to hold capital against this CFB overdraft credit. And then you've got the CPB requiring you to create APIs for third parties that you're supposed to pay for for free forever. And then this ten thirty four C thing, we're supposed to give away any records to consumers for free whatever they may ask for. That's kind of this unbounded manner. I just I don't see how that's sustainable, right, And I don't think And the worst part about it is, I don't think the regulators should like really feel the need to even say, oh, like what are you doing? Like what are you doing? Like let's think about like like get it all on one page and then think about like what's happening to the consumer. Do you think that'll lead to lawer consolidation, more merger and acquosition activity. I mean, if that if the cost of operating get more expensive and you really need that size and scale, it feels like things would I know that the CBA is primarily that you know, ten billion out of buff banks, but feels like the opportunity for community banks and even smaller banks for ones on that threshold and gets even harder. So so, and this is where I can only see problems. I can't see answers right now. We have this weird squeeze really, I think on the regional banks, because you've got on the top end of the you've got prudential regulations that are coming down, right, so you've got these like long term debt requirements and such that are trying of trickling down to these resolution planning requirements that are coming down to the regional bank level. At the same time, you've got these this kind of massive and well and ultimately like basically potential regulations saying hey, make less money on lending,

29:38 make more money on fees, and then you have consumer regulators coming in and saying, oh, you can't, you can't even make a revenue on fees. Like that's a whole thing. That's like a whole other podcast where it's like there you've got regulators saying that you can only recoup your costs on fees, but then they're carving out the smalls, right, and so like for overdraft, for late fees, for REGII, smalls are carved at. So for those reagonal banks in the middle, right, you can neither lend nor generate fee income. I don't know what happens to them, And like like what if it's you know, increasing when you're starting to hear even in public earning earnings polls, executives kind of questioning like like do regulators recognize how hard it will be for them to stay in the consumer retail space? And at the same time you have the CPV coming out saying we don't want you to emerge. So I, well, I don't know what's going to happen there, but it's it's another good example of work. We can like please sit everyone around a table, like put it all on one piece of paper.

30:30 Maybe that's a start. Any Uh, speaking of murders, any any hot takes on whether or not the capital one and discover murders that to be approved takes it takes it home. Yeah, we've learned there's some topics that people won't cover with a microphone. Here. We won't put you on the spot on predicting or endorsing a candidate either, but anything you see happening in the next four years, like or you just kind of wait and see. Oh gosh, is it that by are like you're saying that the polarization, like it's really that hard to tell where you know where legislation may go or reaction to I mean, the thing I would note is that this is unsustainable, right, Like this notion of like a new administration coming in and then you spend all your time kind of throwing out some things that happened in the last administration. It's it's not good for the industry, but most importantly, it's just terrible for consumers. And so I don't know what the answers are going to be, but we've got to find some way to kind of come to more middle ground on these issues and to kind of normalize this and get back to the facts. That's better. Whole thing that's matter. I've been put that on your shirt. Yeah, yeah, thank you very much.

31:40 Calvin Briefinding exploring conversation. I didn't realize how much like this is very cathartic. We're We're here the rest of the day. If you don't, I'll Start partners with banks and credit unions to grow households and expand consumer lending through its leading AI lending platform. Off Start powered banks and credit unions leverage to offer higher approval rates and experience lower loss rates while simultaneously delivering the exceptional digital first lending experience that consumers demand. Whether you're looking to grow and enhance your existing personal and auto lending programs or you're just getting started, Upstart can help. Upstart offers an end to end solution that can help you find more credit worthy borrowers within your risk profile with all digital underwriting, verification, loan closing, and servicing. It's all possible with Upstart in your corner. Learn more about finding new borrowers, enhancing your credit decisioning process, and growing your business by visiting upstart dot com slash lenders. That's upstart dot com slash lenders