Shaping Pragmatic Regulations for FinTech Innovation

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You are listening to Leaders in Lending
from Upstart, a podcast dedicated to helping

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consumer lenders grow their programs and improve
their product offerings. Each week, here

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decision makers in the finance industry offer
insights into the future of the lending industry,

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best practices around digital transformation, and
more. Let's get into the show.

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Hi everyone, This is Lyndsader Bill
of Upstart, and welcome to the

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Leaders in Lending podcast. I will
be joined today by Phil Goldfetter, who

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is the CEO of the American Fintech
Council, which is the industry association at

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the intersection of technology and financial services. Phil has a fascinating background working in

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politics and banking, so I'm very
excited to have him join us today and

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talk all things AI regulation and working
in fintech innovation. Let's get started,

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all right, Hi Phil, and
welcome to the Leaders in Lending. Hey

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really really such a pleasure to be
here. Great. Well, you know,

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I think you've got a really interesting
background and having worked in Congress becoming

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a legislator yourself. Can you just
tell me about your path and how you

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made your way through government to leading
the AFC that it's a great question I

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hope we have a couple of hours
at a sign for set aside for the

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conversation. I'm actually I spent the
vast majority of my career this far in

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public service. I came up in
New York City politics and the City Council.

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I had a very unique privilege of
working for what are you, probably

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one of the most unique mayors of
New York City ever had, in Mike

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Bloomer, and spent a number of
their number of years working in the city

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administration before taking a job with Senator
Chuck Schumer, who is now significantly more,

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significantly more popular across the country that
he was back into the night.

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But interesting time because when I was
working for the Senator it was at the

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same time that the President Obama had
taken office in the earlier part of two

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thousand and nine, so really unique
insight into so many different things happening in

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the federal government. And after spending
three years working with the Senator, I

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actually ran for state elected office here
in New York and served in the state

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legislature for five years. And sort
of the challenge with with public service is

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there's sort of the question is whether
you know for me, there was a

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political movement, right. You know, as things evolve, as people coming

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to office leave office, there's opportunities
to sort of move around. And I

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was very, very lucky in sort
of my time from the council to mayor

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working for the Senator. And the
question for me after running for office was

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what's next? Right do we stay
in public service? I will say that

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I loved every moment that I had
in service, serving my community and serving

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the Great Republic. I mean the
challenge is it takes its soul on your

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family and your life and on so
many other things. And so the question

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was what was next for me?
The opportunity presented itself to work at a

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fintech focused bank bank called Cross River, and I fought long and hard about

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what the next step was going to
be. Now. During my time in

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office, I represented neighborhoods that were
devastated during a hurricane Sandy, so Southern

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Queens Rockaway, our community is about
a year into my first term or devastated

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during the hurricane, and I learned
very very quickly the challenges not just of

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the insurance industry, but also of
the banking industry. And the next four

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years that I spent in office were
steeped in legislation regulation specifically related to financial

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services, as many people who I
represented it were struggling to get access to

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financial services because all of our bank
branches were destroyed during the during the hurricane.

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You know, how do you get
your insurance checks signed by your bank?

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Right? There were so many issues
that arose during the hurricane, and

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when the opportunity presented itself to work
at cross River, sort of the idea

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of you know, what is next
and what can I sort of continue?

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Where can I go in private industry? That sort of lend to my continuation

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of public service, and Cross River
was exactly that answer right as far as

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as my fault was very very simply
that as I continue my path in public

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service, it tried to find ways
to help folks. Fintech seem like the

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real natural answer, and so the
work that I did at over over six

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years sort of led to the continuation
of the public service and finding ways to

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make financial services more accessible to families
who have been unfortunately left out of the

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traditional financial services industry. After six
years at cross River, it's sort of

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the question was how can I do
more right? How can I sort of

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make even a larger impact, and
being here at the American Fintech Council enables

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me not just to report in one
company, but to speak on behalf of

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seventy five or eighty companies who were
all focused singularly of creating access to finance

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person So it's sort of a long
road, but I'm really excited to be

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here. Continued who I work.
Sure, Now, it's interesting you mentioned

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Hurricane Sandy. So prior to joining
Upstart, I worked for a major bank

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that is also headquartered in New York
and one of the downtown buildings was unavailable

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for several years, and I think
people people took their laptops home thinking they'd

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be able to get back in,
and in some cases it did not even

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take them home, and due to
the water damage, that building was not

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operational for several years. So I
can only imagine from a consumer level of

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people who live in those areas how
impactful that was on even just accessing really

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any sort of basic service. So
you've described the American Fintech Council as a

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collection of responsible innovators. What is
that mean to you? So that's a

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great question, and I say that
that that Upstarts the perfect example, right,

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you know, when you think about
innovation, right, it's not just

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innovation innovation's sake the purpose of building
your business. We think about members of

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the American Fintech Council. These are
responsible innovators who are looking to create access

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to financial services and utilize innovation,
but do it a responsible way. And

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so I often talk about the American
Fintech Council, I say that we're probably

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one of the only standards based trade
associations in that regulatory desk flop forward first.

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And so the goal is not just
you know, come one, come

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all for fintech innovators, it's really
about your commitment to standards and I,

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you know, I think about again, you know, sort of one of

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our founding members is up Start,
as you know, and the idea of

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using alternative data or AI underwriting decisioning
is something that Upstart was a pioneer at

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many many years ago. But it
wasn't just let's, you know, sort

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of open up this new innovation and
see what happens. It was carefully thought

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out and slowly rolled out and sort
of sort of walked through the challenges,

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the issues and worked it through to
a point where when we're offering a product,

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we can ensure that we are not
compromising on consumer safety in any way,

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shape or form. And so we're
essentially creating the access to financial services

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without compromising on any regulatory compliance.
And that's not what the American Fintech Council

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is today, where we're just shy
of eighty members who are changing the future

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of finance, but doing it with
a focus on standards and on compliance.

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And that's the way you want it
to be, right, I mean,

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when you think about building out,
when you think about traditional financial services,

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you know, I joke about this
all the time. We see the big

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pillars outside of traditional old school banks, and there was a reason for that.

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It was a you know, whether
it was marketing or whatever the suit

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wherever it came about the idea of
showing stable pillars in front of a bank

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assure consumers that this was a tough
structure. Right, my money is going

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to be safe when I put it
in. And I believe that AFC members

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are creating the exact same thing in
the fintech world and innovative world by creating

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a strong set of standards and so
that consumers know when they engage with AFC

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members like Upstart, you're getting the
exact same tections and regulatory sort of guard

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rails that you would get in traditional
financial institutions. And the difference is fintech

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is meeting consumers where they are,
and that's sort of the evolution of whereas

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traditional banks have exited most communities,
that's kind of where you know, new

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innovative, responsible fintech companies have stepped
in to fill that gap, and they've

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done it remarkably well well. I
can certainly say is as a guest at

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the policy summit last fall, fairness, access to service, is fair lending

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and all of the really risk and
regulatory concerns were a big, big focus

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of the attendees there. So you
know, certainly an interesting time generative AI

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making waves, bank failures last year, which I don't think any of us

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had on our bingo card, and
really everyone wanting to get into the business

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of regulating how these new new products
and tools were used. And I think

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is you know, certainly your background
is a state legislator. You know,

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lending regulation has always been on the
radar of states, but I think we're

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seeing more state legislatures kind of increasing
their focus on things like fees, interest

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rates, other consumer protections, and
passing legislation that impacts how how banks can

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either import or export rates. So
how do you see this impacting FinTechs and

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banks who offer products and services that
span the entire country. So that's a

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great question. I think there's a
sort of a lot of different directions.

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Number one, first influence almost in
the accent. In the absence of federal

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guidance, structure, rules, and
regulation, you find that a lot of

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states tend to step in to try
and fill that void. That sells good

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on its face. And I say
that as a as a former member of

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a legislature. I mean there's a
number of bills in my background that these

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are bills and laws that I that
I was the author and altimately passed.

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But you know, every one of
them was meant to solve a problem.

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And that's what you're seeing today as
it relates to fintech, right, solving

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problems on the state level in the
absence of federal regulatory structure. Now again

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it seems great on the serpents,
right, that's what we want. As

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I mentioned earlier, AFC believes in
regulatory structure. The challenge that we have

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is not in the regulatory structure.
The challenge we have is a patchwork of

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regulatory structures and that every state operates
independently. And I can tell you that

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laws that I passed here in New
York were very different than the laws and

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the structures that were passed in New
Jersey and in Connecticut and in Hell of

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Forna, and in states all across
the country. And so in theory,

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we're all doing the best we can
to protect our constituents. But I want

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to what I want people to think
about is how are companies having to operate

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within that regulatory structure. And so, as a company that is nationally based

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right that is serving consumers from California
to Mean and everywhere in between, the

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idea that they have to look at
a patchwork state regulatory structures, systems,

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interest rates, how they monitor and
jud bank fintech partnerships, how they think

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about so many of the different things
that innovative FinTechs have to deal with.

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Now, all of a sudden,
while it was done with the best of

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intentions, laws are passed with the
bench of best of attentions, you're actually

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you're actually doing the opposite of what
you're intended to do. And what I

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mean by that is every state steps
in and says it's our job and it's

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our responsibility to serve and protect our
consumers. But when you're doing that,

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you're inherently actually making it more difficult
for innovative, responsible companies to operate.

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And so what happens is as companies
say, forget it, it's too complicated

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to operate in this state or in
that state, and so we're actually going

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to take our hands off and not
offer our services at those states anymore.

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And so think about what you're actually
doing. You're taking away access to financial

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services in the name of protecting consumers. And I'll give you a perfect example

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of that. You know, last
April in the state of Colorado, they

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made a pretty significant change to state
banking regulations. And I don't want to

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board the audience with the nuances and
the details, but ultimately that law,

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if it is to take effect in
this coming July of twenty four, most

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responsible innovative online lenders will exit the
state of Colorado. And so, in

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the interest of consumer protection, the
legislature passed this law. But ultimately what's

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going to happen is that it's going
to significantly decrease access to credit and responsible

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options for Colorado family. And so
I think two things. Number one is

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I bring my unique experience to try
and work with legislators all across the country

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as it relates to online lending,
bank fintech partnerships, innovative products like earned

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wage access or buy now, pay
later, as we talked about, as

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you mentioned AI, alternative data,
and underwriting. And so we try to

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sort of take what all of our
companies are offering and work with state legislators

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to make them understand kind of the
nuances of the various product offerings and make

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sure that they recognize sort of the
unintended consequences. I used to say this

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all the time, and we were
in Albany, New York every single year,

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and you pick a subject, but
every single year we would pass historic

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legislative reforms every year. And when
you think about that, you can't have

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historic legislative reforms every year in the
same subject. NATA. Yeah, that's

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true. It's not historic if it
happens annually. So's annual annual changes exactly

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exactly right. And yet every legislator, everyone will say this is historic changes

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for education reform, for this reform
for that reform, and unfortunately, again

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in the interest of again what I
call reactionary legislating, you sometimes in your

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in your drive to create that reform, you don't necessarily recognize the unattended consequences.

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I think, as you know,
well, Upstart is doing things visit

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uncharted territory. Right, we're doing
things today in financial services that I was

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about to say fifteen years ago,
two years ago, we would never have

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imagined. I mean, you see
what's happening with AI today right like no

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one would have imagined it. And
you're you know, thankfully, you're seeing

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the federal government act. The Senate
created a working group, the House just

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announced a working group. Right,
you're seeing that action, but it's slow

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on the federal level. And so
at the same time in federal action,

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you're now seeing state actions and so
that you know, while usually I'm I

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feel good, like I said,
as a standards based organization, we'd love

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to see regulatory engagement. At the
same time, we want it to be

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responsible and we want it to be
thoughtful. I mean want regulators, attorneys

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general, state legislators are going to
respond understand what we're trying to do.

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Understand the process before they implement historic
change. And that's kind of what we

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try to do and some of the
challenges we face day in and day out.

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And I'll just end with one thing
we have, you know again,

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companies like Upstart who spend a lot
of time educating right, I mean,

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Upstart work with the CFPB and work
with other federal regulators. Before it was

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cool to do it right, before
all the cool kids wanted to do it,

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Upstart was sort of on the front
lines of that. Federal regulators also

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need to do a good job in
engaging right. It's not just about the

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innovator's job to engage with regulators.
And one of the big themes for AFC

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is regulatory modernization. The regulatory structures
need to evolve at the same pace as

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the innovators, and unfortunately today we're
just not seeing that sure and I think

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we you know, we certainly work
with many banks of various sizes, We

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work with many credit unions, and
so that kind of patchwork of legislation,

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whether it's their federal crudential regulators,
the NCUA, the FDA, c or

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we're talking about maybe state financial services
or UH organizations that don't have a lot

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of expertise in this area, How
are they really evaluating the business that those

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lenders are doing with us as it
relates to looking at our pricing and our

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models and really help we make decisions. So it obviously has been in the

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news a lot recently that the FDAC
has made some changes as it relates to

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their innovation and tech offices. And
I know that you and the team work

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closely both of the regulators and the
House Financial Services Committee on efforts to improve

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access to fair financial services. Can
you talk about what changes the FDIC has

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recently made and some of the statements
that the various members of the housemaid that

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they're actually moving innovation backwards with most
changes. Yeah, that's a great question.

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As I mentioned, in the absence
of federal regulatory structure, states tend

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to step in. That doesn't limit
our work at the federal level as well,

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and sort of we as I mentioned
earlier, it's just as important for

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the regulators to commit to working with
fintech companies as it is for the fintech

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companies to commit to working with the
regulations. So, as I mentioned,

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you know, all AFC members are
standards based and are fully committed to regulatory

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best practice, but that only works
when you're getting clear guidance from the regulators,

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right. Unfortunately, you know a
lot of agencies have really stepped in

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to try and solve for that.
I think, you know, sort of

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chasm, right, They've tried to
bridge the gap, and you've seen the

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FED Federal Reserve come out with what
they call it Novel Activity Supervisory Program,

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right, which is great, Right, It's sort of the concept is we're

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going to sort of really steep ourselves
some of the banks that are offering BASS

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programs, BASS work innovative program who
are doing innovative partnerships, so we can

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learn the systems, we can understand
what they're doing, we can understand the

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way in which they're engaging with the
financial services ecosystem, so we can actually

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best regulate them. Right, And
that's what we want. I think that's

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what the fintech companies want, that's
what the innovative banks want, and that's

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what the regulators want. We saw
the same thing at the OCC and their

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Office of Innovation. A tremendous credit
to the team there they I would argue

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probably the OCC was you know,
was probably way ahead of the pack many

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many years ago. I remember my
earliest days at Kors River, going back

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to twenty sixteen, twenty seventeen,
you've had you know, we were taking

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meetings with people at the OCC about
some of the work we were doing.

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It's on our innovation. The FDI
C about three years ago maybe four created

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what they call the FDI Tech Office, which again was essentially the same concept,

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which is we're going to engage with
fintech. None of these innovation offices

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created a free pass for anybody.
I want to be very clear about that

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because oftentimes there's this confusion that you
know, it was a you know,

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a free pass for companies doing what
they wanted to do. It was quite

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the opposite. It was really it
was a tool for everybody to learn about

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the other side. Meaning again I
think about a company like upstart that engages

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right. This was a great opportunity, an open door where we can go

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meet with the OCC. There was
an office and an entity within the OCC

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or within the FED, within the
FDIIC Treasury where we can go and have

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a on you know, whether off
the record, on the record, but

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it was an honest conversation about what
you're doing, how you're doing it,

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how you think about regulatory structure.
I think there's a there's a good kind

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of upstart origin story early on that
I'm sure you've heard Jeff and others tell,

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where as the company was being founded
and this idea to start working with

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more banks outside of kind of a
primary sponsor bank, they just walked into

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the office in San Francisco and introduced
themselves and wanted to have a conversation and

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a little bit maybe early for that
at the regulators. That certainly the idea,

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yeah, and that I mean again
you give again. It sort of

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talks about the forward leaning in terms
of fintech companies that are not hiding behind

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sort of some shroud of you know, sort of algorithms, right Like,

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obviously they're innovating, but they they're
eager, I say, they're aggressive in

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their transparency, right like they're putting
their story out, their ideas out long

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before the regulators are coming in.
Unfortunately, the FDI C over the last

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couple of years, UH has really
withdrawn from that and that they've they they've

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turned off the spigot in that they're
they're not taking those meetings. They're not

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the FDI Tech Office, which showed
so much promise about engagement and understanding what's

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happening with regulated banking institutions. They've
basically shut it down. And what we're

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seeing the the what's happening because of
that is that no one understands what the

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rules of the road are, right. You know, innovative companies who want

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to be responsible don't understand or appreciate
what the reight, you know, sort

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of what they need to do or
how they need to do it. And

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so when you think about newcomers to
this ecosystem, you know, how they're

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learning about it is they're learning about
it by looking how other banks published.

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Right. It's what we call regulation
by enforcement, right, And so all

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of a sudden, the FDI says, well, we're going to we're going

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to raise enforcements because we don't like
the way this bank ran x Y or

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Z program. They didn't communicate with
that bank before they got in trouble.

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The nature of the engagement didn't exist
with the financial institutions before they got in

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trouble. The bank found out after
the fact. And so now how do

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other banks learn about the process or
what they should do. They look sort

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of where the other guys went wrong
or where at least publicly they went wrong,

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and they try to do it that
way and work that way. It's

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not the way you know, regulation
should work. Right. When you mix

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pragmatic regulators with responsible innovators, you
can actually create a system that is going

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to serve consumers, create the access
to financial services without compromising on consumer protection.

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But that requires a pragmatic, forward
thinking, engaging regulator, and unfortunately

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recently from the FDIIC we're just not
seeing that. And so we for you

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know, sort of our services at
the American Think Tech Council in sort of

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trying to convene that. You know, what we'd like to think is either

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a working group or some sort of
listening session where I think sometimes you know,

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you need the opportunity for reasonable people
on either side of the table to

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converse with each other, yell at
each other, engage with each other,

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meaning if we're doing it wrong,
if responsible innovative companies are doing it wrong,

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tell us right. The beauty of
a responsible innovative bank is they understand

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regulatory structures right. Banks inherently are
charged with protecting the integrity of the financial

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institution, as we learned just a
year ago. Right, sometimes the regulators

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are just not keeping pace, and
unfortunately, we see the consequences of that.

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And so you would think that regulators
would have learned from some of those

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mistakes, said let's lean in and
learn what banks are doing, how they're

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doing it, so we've better understand
it. And I credit where credit is

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due, because I'll say this about
the CFPB and about the Federal Reserve and

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THEOCC. Sadly, we're not seeing
that at every agency, and we're hoping

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that they're going to engage. Hey
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310
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319
00:24:56.759 --> 00:25:03.079
Sure, sure, And I think
your point earlier about sometimes that regulation has

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has the best of intentions but then
consequences on consumers who cannot access traditional financial

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services and then also see limited kind
of novel financial services they can they can

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access. I know there's been a
lot of conversation about the sponsor banks or

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banking is a service and additional focus
from the regulators, but not really a

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lot of clear guidance about what that
means and where they fit within the overall

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structure, and then where the FinTechs
fits. So what are your what are

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your thoughts about how a banking is
a service or sponsor bank can navigate in

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this really uncertain period with what the
rules are for their their businesses. So

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that's a great question and also sort
of a key differentiator for the American Fintech

329
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Council because I speak a lot about
our standards base, you know, us

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being a standard based trade association.
We're also one of the very few organizations,

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if not the only trade association that
counts innovative fintech companies as members,

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but also the leading bass banks across
the country. So in addition to Upstart

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and all of our fintech partners,
we also count you know, Cross River

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and Customers and Coastal and so many
other leading BASS banks as our members.

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And the beauty of that is is
that it creates a very wide shared ecosystem

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of information about best practice, about
sort of rules of the road, about

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the best ways to think about third
party risk management, and hopefully create kind

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of you know, in the absence
of federal rules or regulatory rules of the

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road from regulators, it creates rules
of the road for you know, industry

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participants. And so it's that diverse
membership that enables us to create the standards

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that we fake ultimately will best serve
consumers. And I think sadly, very

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single day we're learning more, mostly
by you know, because we're the enforcements

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are starting to come more and more. And it's unfortunate. It's unfortunate because

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there's so many industry participants who you
know, we say this as members of

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the American Fintech Council, we never
say that, No Kurgan and not you

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know, we're not saying we're never
going to get in trouble, right or

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someone's not going to make a mistake. No one is perfect. I want

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to be very clear about that.
No, fintech, I don't care how

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responsible and how great you are.
No one is perfect, and you're gonna

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make mistakes. That's not wrong.
Look, I have three kids at home,

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right, like, we expect them
to spill milk on the floor,

352
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right, I'm not gonna forever prohibit
them from drinking milk a yet, right

353
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like that, as long as you
just don't want them to intentionally spill milk

354
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on the floor if they accidentally spell
it is different than opening the fridge.

355
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And I also have three kids,
so although only only one lives at home

356
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now, two are out for you
know, minor are still little, but

357
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mine are still very very little.
And so, but but that happened,

358
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right, you open the fridge and
the milk spills, right, we don't

359
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prohibit them from drinking milking yet.
Now what you said is exactly right.

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If they took the milk out of
the fridge just because they're in a bad

361
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mood or and they spilled it on
the floor, right like, then there's

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a different there's a different level of
consequence to that. I would use that

363
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same analogy here, right, And
This is quite the opposite talking them out

364
00:28:26.799 --> 00:28:30.559
sort of fully mature companies. Right
Upstart is not a you know, they're

365
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in emerging industries. But this is
a company that's been around for a bit,

366
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right, and who has dedicated a
significant amount of resources to compliance.

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I'd be remiss if I didn't talk
about my partner, and this is Nad

368
00:28:42.720 --> 00:28:47.960
Boots, who runs your public policy
obviously who it probably works harder than we

369
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do in terms of engagement. That
level engagement should be rewarded, not with

370
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the free paths. That level of
engagement should be rewarded with engagement and worturn.

371
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Right. And when you said about
what I'm saying, it's not asking

372
00:29:02.079 --> 00:29:06.359
for very much, right, I'm
not asking for anything more than tell me

373
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what I need to be doing.
Crowd should be thinking about it. Crowd

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should be thinking about my innovation.
Same thing you do with your kids when

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00:29:11.559 --> 00:29:15.039
the milk spills, right, you
help them clean it up, Right,

376
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You fix up the problem, and
then you talk to them. We have

377
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to be a bit more careful when
you open the fridge that you know,

378
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you have to make sure that nothing
is leaning on the edge that creates,

379
00:29:25.160 --> 00:29:29.920
you know, a future for everybody, right, unfortunately again. And I

380
00:29:29.960 --> 00:29:32.680
you know, I hate to be
negative so much, right, I think

381
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the challenge is is that, you
know, there's this what I talked about

382
00:29:36.480 --> 00:29:42.720
earlier, reactionary legislating right, instead
of further engagement post the Silicon Valley debacle

383
00:29:42.799 --> 00:29:48.079
from regulators, I think the reaction
the reactionary legislating right or regulating in that

384
00:29:48.240 --> 00:29:52.480
like, oh my gosh, we
have to stop everything because we don't want

385
00:29:52.480 --> 00:29:56.240
to get up with our pants down
like we did the first time. And

386
00:29:56.279 --> 00:29:59.799
that's just the wrong approach because it
goes back to what I said earlier.

387
00:30:00.079 --> 00:30:03.960
Perfect way to tie it all together
is in the interest of protecting consumers,

388
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you're actually hurting consumers because you're removing
financial you know, reasonable responsible financial options

389
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from the table. And when you
think about then, you know, think

390
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about the partners of upstart right,
the banks that you're helping, the credit

391
00:30:19.559 --> 00:30:23.759
unions that you're helping, not just
you know, you think about your partners,

392
00:30:23.759 --> 00:30:30.559
and it's easy to forget that those
partners are servicing thousands of consumers in

393
00:30:30.640 --> 00:30:37.119
a reasonable, responsible, you know, affordable way. All of a sudden

394
00:30:37.160 --> 00:30:41.400
you call into questions some of the
practices and you're pulling that you know sort

395
00:30:41.440 --> 00:30:45.640
of that that that sheet out from
under that consumer and you're taking it off.

396
00:30:45.640 --> 00:30:49.359
So where does that consumer go?
Right when you remove responsible options?

397
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And I talked for a moment earlier
about Colorado. Responsible actors are going to

398
00:30:55.599 --> 00:31:00.240
comply, meaning responsible actors who are
going to as I said, and all

399
00:31:00.279 --> 00:31:04.119
of our AFC members who are looking
for are are looking always for the regulatory

400
00:31:04.119 --> 00:31:10.759
gold standard. If the law changes
it prohibits them from operating, they will

401
00:31:10.839 --> 00:31:14.559
walk away from any state right,
They'll stop operating because the state laws have

402
00:31:14.599 --> 00:31:18.519
made it more difficult. You know, who's not going to stop operating than

403
00:31:18.519 --> 00:31:22.480
a farious actors, right, like
those folks who are looking to skirt the

404
00:31:22.599 --> 00:31:26.559
rules to take advantage of consumers.
We talked about Hurricane Sandy before there was

405
00:31:26.599 --> 00:31:32.880
a lot of affarious actors who came
to my neighborhood and to all neighborhoods impacted,

406
00:31:33.000 --> 00:31:37.720
who look to take advantage of consumers
at their worst. I would say

407
00:31:37.720 --> 00:31:41.559
that the paycheck Protection program very similar. You know, great idea, best

408
00:31:41.559 --> 00:31:45.559
of intentions, but the execution of
it led to a significant amount of fraud

409
00:31:47.400 --> 00:31:52.880
and the expanded unemployments benefit same thing. A lot of fraudulent actors who saw

410
00:31:52.119 --> 00:31:56.160
opportunity in a very bad situation for
the country. Yeah, and so it

411
00:31:56.200 --> 00:32:00.000
comes back to and I talk about
this a lot. Not all fintech is

412
00:32:00.079 --> 00:32:06.000
created equal, right, Like AFC
members are responsible innovators who are doing you

413
00:32:06.039 --> 00:32:08.599
know, are doing the best they
can to follow regulatory structure to provide that

414
00:32:08.640 --> 00:32:14.039
consumer access. And then there's a
whole other segment of fintech companies who are

415
00:32:14.119 --> 00:32:19.799
not. Here's the challenge. You
change the law and the responsible companies will

416
00:32:19.799 --> 00:32:22.359
walk the way, right, the
responsible companies, I look, it's too

417
00:32:22.400 --> 00:32:24.200
hard for me to offer my products
in that state, are in that way.

418
00:32:24.759 --> 00:32:29.480
Then if faeries actors will still be
there. And so I think about

419
00:32:29.480 --> 00:32:32.880
Colorado and I say, okay,
all the good responsible bank fintech partnerships and

420
00:32:32.960 --> 00:32:37.839
online lenders are going to walk away. Who's left the payday lenders, the

421
00:32:37.640 --> 00:32:43.599
the you know sort of the triple
digits digit lenders, those people who will

422
00:32:43.640 --> 00:32:47.319
and where does think about the consumer? The consumer who was utilizing an upstart

423
00:32:47.359 --> 00:32:51.519
product literally has nowhere to go.
Up start, you know, sort of

424
00:32:51.519 --> 00:32:53.599
walks away from a state like Colorado
or any state, you know. Use

425
00:32:53.720 --> 00:32:58.960
that as an example that consumer has
nowhere else to go, and so he

426
00:32:59.160 --> 00:33:01.880
instead he goes to the pown shop, right, and he goes to the

427
00:33:01.880 --> 00:33:07.720
page lender. And so now in
the interest of reaction, they're legislating who

428
00:33:07.759 --> 00:33:12.440
did we actually protect? Right?
And again I say this as someone who

429
00:33:12.519 --> 00:33:15.160
spent an entire career on the public
service side. Right. I worked in

430
00:33:15.200 --> 00:33:20.440
the US Senate, I worked in
the state legislature, I serve, and

431
00:33:20.519 --> 00:33:22.039
I, by the way, I'll
say this about myself, I'll be the

432
00:33:22.039 --> 00:33:25.599
first to admit it. I made
mistakes in the legislature where I passed laws

433
00:33:25.640 --> 00:33:29.880
and realized, you know what,
I may have made done more damage,

434
00:33:29.880 --> 00:33:32.920
and we went back to fix it
and figure out what the unattended consequences are

435
00:33:34.720 --> 00:33:37.000
if we can. The American FINTA
Council is trying to prevent that before it

436
00:33:37.039 --> 00:33:42.440
happens. But we do that by
educating and by speaking a lot about the

437
00:33:42.519 --> 00:33:46.039
nuances of responsible innovation versus not a
responsible innovation. And I think that's a

438
00:33:46.039 --> 00:33:51.880
big part of what we do for
the ecosystem. Absolutely. So, you

439
00:33:51.880 --> 00:33:54.400
know, one of the things we've
done over really the past year and a

440
00:33:54.400 --> 00:34:00.880
half and put an extensive focus on
is is what we call our regular readiness

441
00:34:00.920 --> 00:34:06.240
for our bank partners and credit union
partners, and so my team worked with

442
00:34:06.240 --> 00:34:09.880
our risking compliance partners internally, worked
with Nat Hoops of course on the work

443
00:34:09.880 --> 00:34:15.880
that he's been doing with the OCC
and the MDI, various programs that he

444
00:34:15.960 --> 00:34:21.679
works with, and we're really outlining
best practices for our lenders of how to

445
00:34:21.800 --> 00:34:27.239
oversee a third party in a fintech, how to build your oversight program,

446
00:34:27.280 --> 00:34:30.639
how to document your diligence, how
to make sure that you have the tools

447
00:34:30.679 --> 00:34:34.119
to really understand how you're partnering with
us, so that when you do get

448
00:34:34.119 --> 00:34:37.840
into that regulatory exam, you're equipped
to support it. And I think we're

449
00:34:37.880 --> 00:34:43.880
definitely seeing from a variety of regulators
that the questions vary of what they want

450
00:34:43.920 --> 00:34:51.199
to know and certainly their expertise in
understanding and evaluating a fintech relationship. Are

451
00:34:51.199 --> 00:34:57.360
you seeing anything from the other fintech
members of the AFC where they're feeling similar

452
00:34:57.400 --> 00:35:00.159
to us, that we feel like
we have a responsibility to help our our

453
00:35:00.199 --> 00:35:06.760
banks and credit unions support themselves through
regulatory exams. Yeah, I mean that's

454
00:35:06.960 --> 00:35:08.559
that. I mean we talk about
that a lot as a sort of one

455
00:35:08.559 --> 00:35:12.920
of the value propositions for being a
part of the AFC. So two things.

456
00:35:12.920 --> 00:35:15.199
So we're one. As I have
mentioned a number of times, and

457
00:35:15.239 --> 00:35:19.599
I say a lot, right is
our commitment to regulatory deest practice and standards

458
00:35:19.639 --> 00:35:22.800
based. But I think what we
do is we try to use the network

459
00:35:22.840 --> 00:35:30.360
effects and that the shared ecosystem to
best educate each other and the wider world

460
00:35:30.400 --> 00:35:34.119
about the best ways to do it. Now, I'll start with our bank

461
00:35:34.159 --> 00:35:39.599
membership. Our bank membership sort of
is comprised of some of the biggest banks

462
00:35:39.639 --> 00:35:44.880
in the fintech ecosystem who have you
know, sort of large asset sizes,

463
00:35:45.039 --> 00:35:50.199
right north of twenty billion in assets. We also have bank members who are

464
00:35:50.199 --> 00:35:52.440
in the past space who are less
than one hundred million in assets, right.

465
00:35:52.880 --> 00:35:55.480
And when you think about that,
you say, well, how is

466
00:35:55.519 --> 00:36:00.360
it possible that a trade association is
servicing an answering the needs of the biggest

467
00:36:00.400 --> 00:36:05.639
banks and the smallest right And the
answer is is that they're both helping each

468
00:36:05.679 --> 00:36:08.679
other, right like that The value
prop is that they're both together. Why

469
00:36:09.280 --> 00:36:14.719
because the biggest banks get to understand
some of the newer questions from the smaller

470
00:36:14.760 --> 00:36:17.119
banks of the way the smaller banks
thinking about things. Because sometimes you know

471
00:36:17.159 --> 00:36:21.800
when you're you know, look,
I say this about different you know,

472
00:36:22.199 --> 00:36:23.920
me and my brothers, right,
like you have different levels of when you

473
00:36:23.960 --> 00:36:29.039
reach a certain age think about the
world a different way, and sometimes younger

474
00:36:29.079 --> 00:36:32.079
perspective is helpful even though you're older, right. And so same thing with

475
00:36:32.199 --> 00:36:39.039
banks in that the younger the smaller
banks more nascent in terms of their engagement

476
00:36:39.119 --> 00:36:45.159
in the bass and the thin tech
ecosystem provides additional clarity where the bigger banks

477
00:36:45.159 --> 00:36:47.559
sometimes like, oh, they don't
think about these things anymore because they're so

478
00:36:47.599 --> 00:36:51.800
long past it. I think it
kind of keeps them humble and sort of

479
00:36:51.880 --> 00:36:54.880
asking those questions. And in that
conversation, on the flip side, the

480
00:36:54.920 --> 00:36:59.239
younger, the smaller banks get to
learn from the bigger banks, right,

481
00:36:59.280 --> 00:37:04.760
And so we really created a shared
ecosystem that works, and most importantly,

482
00:37:04.800 --> 00:37:08.480
they're sharing their their compliance now and
what that standard looks like. It So,

483
00:37:08.519 --> 00:37:13.199
as an example of that, as
soon as there was a in June

484
00:37:13.280 --> 00:37:17.719
of twenty three, there was a
joint guidance from the regulators about third party

485
00:37:19.039 --> 00:37:22.519
risk oversight, and immediately we brought
all of our members together to think about,

486
00:37:22.519 --> 00:37:25.079
Okay, what does that mean and
how does that change what we do,

487
00:37:25.320 --> 00:37:29.840
and not just in a macro sense. We had general counsels like,

488
00:37:29.880 --> 00:37:31.559
hey, are you changing up your
contracts based on that? Like how are

489
00:37:31.559 --> 00:37:36.360
you looking at the nature of the
partnerships, like what needs change and how

490
00:37:36.400 --> 00:37:38.639
do we need to change it?
And so that's how we think about it.

491
00:37:38.679 --> 00:37:43.440
On the bank side, as I
talked a bit earlier about how putting

492
00:37:43.440 --> 00:37:47.320
the banks and the fintech companies in
the same ecosystem inherently creates kind of like

493
00:37:47.840 --> 00:37:52.400
sort of who is doing what in
the nature of that relationship and helping everybody

494
00:37:52.400 --> 00:37:55.960
get better. And then the fintech
companies, right, and I similar to

495
00:37:57.000 --> 00:38:00.119
the banks the smallest companies, right, those who have not even raised money,

496
00:38:00.440 --> 00:38:04.920
to those who are in Serie C
or D right like those who are

497
00:38:05.079 --> 00:38:10.840
are larger, and I run the
gamut of those companies who literally are whether

498
00:38:10.840 --> 00:38:14.920
it's part of our working groups where
we're talking about a specific issue. And

499
00:38:14.960 --> 00:38:17.719
so we got working groups related to
you know, banks and dick partnerships to

500
00:38:17.960 --> 00:38:23.079
data privacy, to open banking and
things of that nature where you're finding everybody

501
00:38:23.079 --> 00:38:30.079
come together to think through some of
the challenges they're facing, to vocalize some

502
00:38:30.159 --> 00:38:35.360
of the challenges they're facing and work
together. Again, you have to remember

503
00:38:35.400 --> 00:38:39.480
we're still competitors on some level,
right, mean that in a capitalist society

504
00:38:39.480 --> 00:38:44.119
where folks are trying to build successful
businesses. But I think they recognize that

505
00:38:44.159 --> 00:38:47.320
in the AFC ecosystem, there's a
natural benefit. We're all you know,

506
00:38:47.360 --> 00:38:51.280
as they say, a rising tide
raises all ships, and I think,

507
00:38:51.960 --> 00:38:54.360
you know, up starts a perfect
example of that is that we're going to

508
00:38:54.440 --> 00:38:59.199
commit ourselves, our time, and
our resources, whether it's you know,

509
00:38:59.239 --> 00:39:05.159
financially or with the expertise of a
guy like Oopsie. Again, the expertise

510
00:39:05.280 --> 00:39:07.400
is just as important, right Your
your sweat equity is just as important,

511
00:39:07.519 --> 00:39:13.199
is as as zero as the real
equity. And so sort of building those

512
00:39:13.440 --> 00:39:17.440
sharing ecosystems, you know, enables
everybody to understand the challenges and then solve

513
00:39:17.480 --> 00:39:21.679
them long before their challenge is for
them. And like I said, there's

514
00:39:21.679 --> 00:39:24.920
this pay it forward where we're continuously
building out this ecosystem. I say,

515
00:39:25.079 --> 00:39:30.360
I say this a lot where we're
not just the biggest sort of fintech you

516
00:39:30.400 --> 00:39:35.840
know, trade association where probably the
fastest growing because folks see that we're doing

517
00:39:35.920 --> 00:39:38.760
it in a I joke about this
a lot in a warm and fuzzy way,

518
00:39:39.000 --> 00:39:43.000
right, like where you know,
we try to bring to our trade

519
00:39:43.039 --> 00:39:45.920
a mechanism of comfort, right,
similar the way we talk about traditional banks.

520
00:39:46.000 --> 00:39:50.840
Right, there's a level of comfort
that we could talk about innovation,

521
00:39:50.960 --> 00:39:52.960
we could talk about things like AI, we can talk about things like data

522
00:39:53.000 --> 00:39:58.639
sharing, but in a non threatening, non competitive way, so we can

523
00:39:58.679 --> 00:40:01.840
actually all walk away with best practice
and then go change the future of finance.

524
00:40:02.760 --> 00:40:07.320
Sure, And I definitely think some
of the points you made about the

525
00:40:07.719 --> 00:40:13.679
team, the different companies working together, and what the smaller organizations can learn

526
00:40:13.760 --> 00:40:17.280
from the bigger, more mature ones, And certainly it is a resource challenge.

527
00:40:17.360 --> 00:40:22.159
I think for many of those smaller
organizations, whether they're a community bank

528
00:40:22.320 --> 00:40:28.440
or a smaller credit union, or
whether they're a startup fintech entering the space,

529
00:40:28.599 --> 00:40:35.920
the cost burden of having enough risk
and compliance professionals that can effectively navigate

530
00:40:36.000 --> 00:40:39.039
all of the things that are changing
is pretty large, and I think definitely

531
00:40:39.039 --> 00:40:45.400
gives an advantage in some ways to
the bigger players that can hire and pay

532
00:40:45.440 --> 00:40:50.239
for all of the talent to do
those things. So we use the interagency

533
00:40:50.280 --> 00:40:53.360
guidance as a part of the guidebook
to our regulatory playbook, to work with

534
00:40:53.400 --> 00:40:57.960
our partners to help them understand that
and where we can lean in with our

535
00:40:58.079 --> 00:41:05.039
with our resources. The certainly last
year the Executive Order on ai came out

536
00:41:05.079 --> 00:41:10.199
as well, and it feels like
there's just a proliferation of orders and guidance

537
00:41:10.320 --> 00:41:15.519
and statements made by a variety of
organizations. But there was some thought that

538
00:41:15.519 --> 00:41:19.639
that was potentially in the way that
it was written, was also maybe opening

539
00:41:19.639 --> 00:41:25.840
the door for the CFPB two more
directly oversee non bank fintech companies. What

540
00:41:25.880 --> 00:41:29.360
are your thoughts on there? I
know that I think the AFC, of

541
00:41:29.400 --> 00:41:31.679
course, as you said, is
standards base and really almost like a self

542
00:41:31.719 --> 00:41:38.159
regulatory organization like a FINRA or similar. But what are your thoughts about the

543
00:41:38.599 --> 00:41:42.840
future if you had to look out
five ten years, do you think that

544
00:41:42.880 --> 00:41:46.679
there is a world where the you
know, certainly there are state exams already,

545
00:41:46.800 --> 00:41:52.039
there are FTC and other audits and
exams of FinTechs, but more kind

546
00:41:52.079 --> 00:41:58.519
of direct regulation from the national regulators. So it's a great question, and

547
00:41:58.599 --> 00:42:02.079
I you know, what I'll say
is that I'll go as far as five

548
00:42:02.159 --> 00:42:07.599
years. In five years, we're
no longer. It's not going to be

549
00:42:07.599 --> 00:42:12.000
a question of banks and FinTechs.
Fintech is going to be banking. Meaning

550
00:42:12.079 --> 00:42:15.880
the concept that there is this divide
or differentiation is is, you know,

551
00:42:16.119 --> 00:42:20.079
the lines are quickly getting blurred.
Not in a bad way, right,

552
00:42:20.119 --> 00:42:22.280
somebody will hear that and say like, oh, you're blurring the lines.

553
00:42:22.320 --> 00:42:29.480
No, quite the opposite. Responsible
fintech companies are embracing the regulatory structure.

554
00:42:29.480 --> 00:42:31.639
I mean, everything you just talked
about in terms of your you know,

555
00:42:31.719 --> 00:42:36.960
upstart is educating the banks on third
party risk management and think about what you're

556
00:42:37.000 --> 00:42:40.280
creating through the larger ecosystem. Every
time that bank now partners with another company

557
00:42:40.360 --> 00:42:45.079
or talks to another bank, they're
using kind of that model to sort of

558
00:42:45.119 --> 00:42:47.599
pass it on, right, and
creating a wider ecosystem. In five years

559
00:42:47.639 --> 00:42:51.719
from now, we're not going to
call it fintech. We're just gonna call

560
00:42:51.760 --> 00:42:58.840
it banking. And those people and
those entities who embrace the regulatory structure today

561
00:42:59.639 --> 00:43:04.719
will be the ones who are offering
the services in five years. And I

562
00:43:04.719 --> 00:43:06.559
I, I, you know,
I, you know, I could not

563
00:43:06.719 --> 00:43:12.760
say that any more emphatically in that
it's sort of like it's always hard to

564
00:43:12.840 --> 00:43:15.599
turn a battleship right, and so
the idea that you do it organically and

565
00:43:15.719 --> 00:43:21.599
slowly and you sort of evolved over
time sort of makes for a much stronger

566
00:43:21.880 --> 00:43:24.760
foundation. And I think that's where
companies like Upstart come in and all of

567
00:43:24.840 --> 00:43:30.400
I would say, all of AFC
members, where we're building a strong foundation

568
00:43:30.800 --> 00:43:36.280
built on the structure of regulatory compliance, so that in five years we talk

569
00:43:36.320 --> 00:43:38.840
about who is going to be the
trusted entities, it's going to be the

570
00:43:38.920 --> 00:43:44.199
upstarts of the world who are going
to be poised to, you know,

571
00:43:44.320 --> 00:43:47.559
sort of displace kind of some of
those traditional banks who have basically abandoned communities

572
00:43:47.599 --> 00:43:52.639
all across the country because they just
they can't be bothered with it. Whereas

573
00:43:52.840 --> 00:43:54.920
think about what your business model is, your business model is, I'm going

574
00:43:54.960 --> 00:43:59.119
to lean into the credit unions.
I'm going to lean into the the community

575
00:43:59.119 --> 00:44:01.800
banks, and the community banks that
are able to embrace that accepted, that

576
00:44:01.880 --> 00:44:07.400
provide those services are the ones that
are to survive along with you to create

577
00:44:07.440 --> 00:44:10.360
the future financial services. And so
I think, you know, again,

578
00:44:10.440 --> 00:44:15.559
everything I say about fintech, as
I've mentioned, needs to be the same

579
00:44:15.599 --> 00:44:19.039
on the government side, and huge
credit to the bide administrations. I think

580
00:44:19.079 --> 00:44:23.280
the Executive Order kind of laid out
very you know, sometimes they're lofty goals,

581
00:44:23.360 --> 00:44:25.880
right, but like you know,
shoot for the moon and hope to

582
00:44:27.199 --> 00:44:29.639
get to a couple of stars,
right, And I think that's kind of

583
00:44:29.679 --> 00:44:32.840
where we're going, you know,
tremendous credit. You know, oftentimes government

584
00:44:32.960 --> 00:44:37.039
tends to lag behind the industry.
I think they recognize. I think government

585
00:44:37.119 --> 00:44:42.360
today is recognizing the challenges of AI, and not just in financial services obviously,

586
00:44:42.440 --> 00:44:46.880
but in multiple ways across the world
and across society. And so I

587
00:44:46.920 --> 00:44:52.119
think financial service is just one aspect
of that, and you're seeing more and

588
00:44:52.280 --> 00:44:57.719
more government agencies engaged to try and
understand it. There was recently an announcement

589
00:44:58.159 --> 00:45:01.920
from the White House that Elizabeth Kelly, who is a senior advisor at the

590
00:45:02.000 --> 00:45:08.639
NEC, is going to lead a
new program and you know, specifically focused

591
00:45:08.639 --> 00:45:13.159
on AI and regulatory structures. And
I think that you know, there is

592
00:45:13.639 --> 00:45:19.760
a significant more learning to do as
relates specifically to AI, But like I

593
00:45:19.840 --> 00:45:23.599
said, it's the folks who embrace
it early, right. Unfortunately, you're

594
00:45:23.599 --> 00:45:28.239
gonna find and let you see it
every single day. They're gonna be companies

595
00:45:28.239 --> 00:45:30.960
we're gonna put their head in the
sand, right, like, we don't

596
00:45:30.960 --> 00:45:31.360
know from it, we don't want
to hear from it. And by the

597
00:45:31.360 --> 00:45:36.039
way, there'll be regulatory agencies that
will do the same thing. We don't

598
00:45:36.079 --> 00:45:39.079
want it, we don't need it. It doesn't help, it doesn't Ultimately,

599
00:45:39.480 --> 00:45:42.719
it doesn't work to put your head
in the sand. If you're an

600
00:45:42.760 --> 00:45:45.239
agency and you're a regulator, it
doesn't work to put your head in the

601
00:45:45.280 --> 00:45:47.960
sand. If you're a you know, sort of a company, a fintech

602
00:45:49.000 --> 00:45:53.920
company or an innovative company, if
you engage responsibly, organically and slowly,

603
00:45:54.159 --> 00:45:59.719
you're able to implement certain things.
And again, upstarts just a great example

604
00:45:59.719 --> 00:46:02.880
of that, where I would argue, like AI is not something that is

605
00:46:04.000 --> 00:46:07.039
new to Upstart, right, the
concept of alternative data and how do we

606
00:46:07.440 --> 00:46:12.360
sort of reach more and more consumers
who have been traditionally left out is not

607
00:46:12.679 --> 00:46:16.000
new to Upstart and to your partners. But I would argue to thousands of

608
00:46:16.039 --> 00:46:19.760
community banks across the country, they're
still putting their head in the sand.

609
00:46:19.880 --> 00:46:21.679
Right. They don't want to hear
from it, they don't want to know

610
00:46:21.760 --> 00:46:23.599
from it. They want to do
it the same way they did it sixty

611
00:46:23.679 --> 00:46:28.639
years ago, they want to do
it today. And the interest think about

612
00:46:28.639 --> 00:46:30.599
this and the interest of well,
because we don't want to hurt the system

613
00:46:30.960 --> 00:46:36.079
or upset the system. So who
loses? The consumers lose, right,

614
00:46:36.159 --> 00:46:40.559
because you're basically denying them their right
to get bank accounts, to get access

615
00:46:40.599 --> 00:46:45.880
to credit, to get access to
financial services. And so responsible innovation breeds

616
00:46:45.960 --> 00:46:52.719
access, bridges the gap to democratizes
financial services, and really is preparing us

617
00:46:52.719 --> 00:46:57.039
for the next stages. And I
think burying your head in the sand,

618
00:46:57.039 --> 00:47:01.440
whether your government or whether your fintech
companies just the long move. Well,

619
00:47:01.440 --> 00:47:06.639
great, well, I think that's
a fantastic one to end on. I

620
00:47:06.679 --> 00:47:09.039
was going to maybe ask about any
other other hot takes, but I think

621
00:47:09.039 --> 00:47:14.239
that one is a great way to
close it out. So Phil, very

622
00:47:14.360 --> 00:47:17.159
much appreciate you being on the show
today. Glad to have you here,

623
00:47:17.159 --> 00:47:21.840
great insights as usual, Glad to
see your your on location. I know

624
00:47:21.880 --> 00:47:27.559
you're you move around a lot and
traverse the country in many states, talking

625
00:47:27.599 --> 00:47:32.960
to to AFC members and to regulators
and various groups. So appreciate you taking

626
00:47:34.000 --> 00:47:38.199
the time for this and uh looking
forward to this episode getting out there.

627
00:47:38.719 --> 00:47:42.119
Yeah, no, thank you,
and more importantly, not just for today,

628
00:47:42.119 --> 00:47:45.159
but for all the work than Upstart
does and their dedication to not just

629
00:47:45.719 --> 00:47:50.320
you know again, not just growing
their business, but to growing the entire

630
00:47:50.360 --> 00:47:53.559
ecosystem and lending their expertise and their
capital to that. So it'sreminouschool rats,

631
00:47:53.599 --> 00:47:58.559
and thank you to you and the
entire up Star can you love Start partners

632
00:47:58.559 --> 00:48:01.920
with thanks and credit unions to row
households and expand consumer lending through its leading

633
00:48:01.960 --> 00:48:07.559
AI lending platform. Upstart powered banks
and credit unions leverage AI to offer higher

634
00:48:07.559 --> 00:48:14.679
approval rates and experience lower loss rates
while simultaneously delivering the exceptional digital first lending

635
00:48:14.719 --> 00:48:19.440
experience that consumers demand. Whether you're
looking to grow and enhance your existing personal

636
00:48:19.480 --> 00:48:23.840
and auto lending programs or you're just
getting started, Upstart can help. Upstart

637
00:48:23.880 --> 00:48:28.840
offers an end to end solution that
can help you find more credit worthy borrowers

638
00:48:28.960 --> 00:48:34.320
within your risk profile with all digital
underwriting, verification, loan closing, and

639
00:48:34.440 --> 00:48:37.960
servicing, It's all possible with Upstart
in your corner. Learn more about finding

640
00:48:38.000 --> 00:48:43.840
new borrowers, enhancing your credit decisioning
process, and growing your business by visiting

641
00:48:43.960 --> 00:48:49.199
upstart dot com slash lenders. That's
upstart dot com slash lenders.