Will Cannabis Banking Ever be “Safe”?

There is cautious optimism that 2022 will be the year that federal legislation will open the door to the banking of cannabis transactions. But is the Safe Banking Act the answer? On the  latest episode of #CreditEcotoGo with Joann Needleman, Peter Su, Senior Vice President of Green Check Verified manages our expectations and tells us that the real issue is the lack of “capability, capacity, and cost”. The regulatory burden of taking on cannabis customers is significant for financial institutions.  The Safe Banking Act does not address how banks will be supervised and examined by prudential regulators. Adding to this confusion, some states like New York, are implementing policies like “Justice Involved”, which allows applicants who have had convictions for minor marijuana infractions to go to the head of the line when applying for a retail license. The standard customer due diligence policies and anti-money laundering regulations do not align with these potential banking customers and in the end their banking services will cost more. 

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DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Transcript

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Hello, and welcome to another episode of Clark Hill's Credit Ego to Go, curbside thought leadership for financial services. My name is Joanne Needleman, and I am a partner at Clark Hill. As well as a member of the firm's banking and financial services practice group. So year after year, more and more states are opening their doors to the cannabis industry, legalizing both medical and recreational use. But while visions of tax dollars dance in the heads of state coffers, we are still in the stone age when it comes to providing appropriate financial services to cannabis related businesses. Which brings me to my next guest, uh, Peter Sue is Vice President, uh, Senior Vice President with Green Check Verified, the top cannabis banking compliance software consultancy in the space, a longtime banker. Peter has spent 20 plus years in finance with stops at HSBC, Signature, Dime Bank, and East West Bank. He has personally spearheaded two separate cannabis banking programs, and in his current role at Greencheck, he is responsible for the growth of over 100 cannabis banking programs all over the country. A frequent speaker and sought after thought leader, He has been featured in Bloomberg, American Banker, Rolling Stone, and others. He holds several designations, including the accredited banking, cannabis banking professional, the ACBP. Oh, you got a lot of alphabets go alphabet soup going on here, Peter. I have to tell you, certified treasury professional, certified banking, cannabis banking professional, certified commercial cannabis experts, and is. Endo cannabinoid systems qualified. All right. We'll talk about that. Peter, thank you so much for coming on the podcast today. Thank you for having me join. I am so sorry. I feel so bad when you asked me for a bio, I didn't realize you let people self promote here. Don't be shy. Don't be shy. So Peter, I'm So you and I have spoken over the years and you're really my go to when it comes to this abyss of, you know, people talk about cannabis banking, they're like, well, there isn't any cannabis. Thank you. Well, that's true. But. Uh, there, there are people like yourself who have been such advocates, um, in, in really, it's not even, it's not about, you know, making money or, or, or, or getting money for your bank. It's really almost, it's a right and a privilege. We all have a right and a privilege to be serviced by our, by financial institutions. That's why we're really in this country. I don't want to stand on my soapbox too much, but you know, this is really. A problem and it doesn't seem to sink in with a lot of people, um, because everybody's like, Oh, we have to get into cannabis. And every time you talk about financial services, they're like, when I'm gonna talk about that. Well, to me, that was where the conversation should have started. And I think you believe the same way, uh, which is why I'm so thrilled that you're, you're coming on the podcast today. So. Setting that table a little bit. Let's talk about the big elephant in the room at right now, which is the safe banking act. And there's so much talk that this is the year that it's going to happen. Poor Ed Perlmutter has been pushing this since 2013, but. You know, this is going to be the year almost a decade later. This is going to be the year. But you and I both agree. And I certainly want to get your perspective. Is this going to be the panacea that everybody hopes it will be? Uh, you know, Joanne, it's funny. You and I have talked about this topic a lot, as you mentioned. First of all, I want to say I'm I'm super honored that someone of your stature considers me a go to for anything. So thank you. You're too kind, my friend. Thank you. You're too kind. Um, you know, I don't believe so. Although I would say that lately there's been some tweaks to the language and maybe things are a little bit different, um, but, but, but taking a step back, um, and look, it's called safe banking. So, so there's a, there's a natural inclination to think about banking, meaning depository services, you know, a checking account. Um, and the truth is, if it just means opening a checking account, then I'm not sure that SAIT would do much. Because the reality is, you can get a checking account today. Um, well, you can and you can't. I mean, yes, you can. It's expensive and It is not. Everybody is in the space, and it is not as simple. It does happen. And certainly you're involved with a lot of institutions that do do it, but it's not as easy as that. Peter, you have to admit. Absolutely. Absolutely. There's definitely so. So I have this cliche that I like to push. I say what's really decision in the industry right now is a lack of capability, capacity and costs. Correct. Um, so to your point, it's not that you can't get a checking account. It's that you gotta work pretty hard for it. And when you find it, sometimes you might not be that satisfied with the product, right? Um, you might not be that satisfied with the costs, you know, et cetera. Um, but again, talking about safe, I think it, again, if, if all it does is mean that, you know, more banks get into the space, that that's a great incremental step. Um, but it is. Pretty incremental, um, as opposed to the tendency that some people seem to make it out to be, uh, but now let's say it included things like, um, you know, capital, meaning like capital markets, right? Uh, credit cards, you know, that would be a sea change. Yes. But say, like, companies were able to list to the NASDAQ as opposed to the Canadian Stock Exchange. Well, that would be a big step, right? That would, that would drastically change the capital markets for, for cannabis. Um, I don't know whether SAFE really addresses that, you know, the CLIMS Act, uh, which I know is still kind of. Sort of out there. Um, does address that to some extent. So, so we'll see. I mean, I think with some of these new tweaks, it feels like it may do more. So maybe they've been listening to your podcast. But, uh, but, um, yeah, I mean, I agree safe as, as this solution as if it's a cure. Uh, I'm not sure that that's true. Yeah, I agree. I think it's more perception and implementation more than it's anything else. I think to your point, if if a piece of legislation like this, which has taken so long, um, gets passed, I think just the the the PR aspect of it. Will will help, but there is you and I both know there's so many other pieces to this puzzle. And for me, and I've said this for a long time, you know. Even whether you pass safe or not, you still got to get the regulators on board and you got to get some consistency on what those regulations are going to be, or or how even they're going to supervise and examine banks because for banks. Obviously, deposits are a big thing. Customers are a big thing, but they spend the other 11 preparing for their next examination. Right? How are they going to do that? If you know, they have all these cannabis customers and that's where all these financial institutions have certainly tripped over themselves. You know, Joanne, what you're saying there is so insightful, and I think it's hard for, you know, I guess, non financial institution related people to really relate to, which is that so much of it is just about the examination. The examiners come, what would they see? What do they want to see? Um, so a lot of. Cannabis banking and the hesitation for it is actually just wrap that in that. It's the optics, the work involved. Um, so again, it's not that you can't bank cannabis today. You can the barrier of entry, in my opinion, is nothing more than a decision. Um, making that decision means means taking on a pretty significant regulatory burden, right? Um. And, and is there incentive to do that, meaning business reason profitability, frankly, you know, I, I feel like you don't even necessarily have to guess at it. We actually have a live example that we're seeing unfolding, uh, with respect to the hemp and CBD industry, perfectly legal. Right. Um, but you don't necessarily see banks bracing it. In fact, in some cases, you're seeing certain payment processors actively, you know, leaving the industry, kicking people out, et cetera. Yeah, because at the end of the day, I mean, hemp and CBD have their own issues. And I think that is, uh, I guess the term would be coverage, you know, is it really hemp or CBD? And so. In some respects, you know, it's cannabis. It's always going to be cannabis. But, you know, our is the product in an hemp and CBD situation meeting that threshold. So that's yet another layer of scrutiny. Requires a financial institution to undergo to make sure. In fact, it is. Have perceived and I think your point well, taken having been a banker yourself, you know, what are bankers? What do we always used to call bankers in the olden days? David. Peter, um, bean counters, right? And so, you know, as bean counters, uh, you want to count a lot of beans. If you have a lot of costs and you're counting less beans and you know, all of this. Translates into costs. Exactly. Yeah. And that is where, unfortunately, the rubber is meeting the road in in these, uh, in in these scenarios and circling back to this last point before we jump into our 2nd topic. It's it's it's safe bank. It's safe banking really going to fix that. See, I don't think so. Right. And I think I think with the CBD hemp example, I feel like that proves your point, I believe, which is there isn't enough clarity around what what what examiners are expecting to see. And so largely, that's why people are sitting out, right? Like, it's not that there is risk. So let's say a CBD. So, so hemp grower, obviously, there is some risk because, hey, how hard is it for hemp grower to speak in a couple of acres of marijuana, right? But if you talk about a CBD product, meaning they're, they're handling. You know, aftermarket products in some cases, not even handling the drop shipping. Um, conceptually, you don't have a heightened, uh, regulatory risk. You don't have a heightened money laundering risk, but again, you don't see banks embracing it. And I think it's, I agree with you. It's because. They don't know what they're supposed to do with it. That's right. So why bother, right? Right. That's right. Yeah. So there just isn't enough profitability to say, yeah, I'm going to go through all this trouble figuring it out. And I have no idea what the examiners are asking for. That's right. That's right. I remember, um, uh, a former client of mine in the I'm here in Philadelphia. Uh, I was meeting with him around another issue. And, uh, I said to him after we were done our meeting, you know, I got to ask you a question, you know, is, is, is your bank going to consider, uh, you know, cat embracing cannabis and taking cannabis deposits. And, you know, this smile came on his face. He's like, I would love to, he said, but do you know what it's going to cost for us? To get ready for an examination. He said, you know, when I look at that questionnaire, the pre examination questionnaire, you know, if I say yes to cannabis, because it is on questionnaires now, it definitely is. But every banker is afraid to check that box because that number one, that examination now is probably going to go on a couple more days. If not, right, right, right. And, you know, how do I get my people prepared for that? And do I want to get dinged on this when everything else I've been spending a fortune on everything else and getting my compliance systems, you know, in line. So it's a struggle. And again, I think it's, you know, in typical, uh, fashion, certainly at the federal level, um, We always tend to look at things through, through a pinhole and not look, as we say, look through, look at the forest through the trees. And it's going to be a while. It's, it's definitely going to be a while. It's needed, but it is definitely going to be a while. So stay tuned and see what happens with safe banking. I kind of think that the Senate has a lot of, or Congress has a lot on their plate besides that. Legislation, but yeah, there's a few other things going on. So we'll see. So let's turn to the states a little bit. And definitely your wonderful state of New York where you are sitting right now, um, you brought something up to me, which I thought was fascinating, which spawned a really good conversation that I hope we can continue here was that, um, you know, you talk with a lot of banking regulators. You're talking a lot with DFS in New York and, um, They obviously are now have recreational, I believe in New York now, and they've had medical and they're trying to expand it, but they also in typical New York fashion want to expand opportunities, you know, for the for for compromised communities, uh, for people's for people of color for minorities. We, we get all of that. It's a great, uh, mission of the DFS. Wonderful. But with respect to cannabis, they want to target those who have been, um, disproportionately impacted by cannabis infractions. Throwing, you know, expunging those records and giving these people, quote, a second chance, allowing them to get involved in the industry and presumably coming to you, Peter, or your bank or others in New York to say, Hey. We want to start doing business and can we open up a bank account? I think it's wrought with problems and really want to hear your perspective. Yeah, you know, I, I, I don't listen. I love the concept, right? Yes. Um, exactly. Justice Involved is this category that we created, um, again here in New York, uh, essentially, you know, to your point that there's, there's some, there's a record involved, there's conviction, there was an arrest, uh, based on marijuana. Now there's some nuances there, it could be a relative, so it may or may not necessarily be the, be the, um, the person in But the point is, let's say it is, let's say I'm a person that has been arrested for, you know, marijuana possession, you know, I don't know, years ago, let's say, um, the Justice Involved license essentially says that I go to the front of the line now when I apply. So, the first 100 licenses, retail licenses that we're rolling out here are actually reserved purely for Justice Involved individuals. Um, so Jannie, here's the question. Person has a record, right? How will they get banking? Well, it's a problem. It's a big problem. Now, but I think it's a, it's a, it's a double edged problem in the sense that I understand, you know, that's a question when you open up any bank account or any bank wants to do business with you. Do you have a criminal record? Okay. So you got to answer truthfully. Um, I understand they were for, for many, they could have, could have been, we'll talk about that. Some minor infractions. So they expunge it. All right, fine. But, um, some of them are not minor infractions. Some of them involve other things. It's kind of if you're outside of New York, explaining that people with records are going to go to the head of the line for law in front of law abiding citizens is. One of the reasons people look at New York and California and go, huh? I don't understand. I don't, I don't get it. I don't, what am I missing here? But you're telling me that happened. I've never heard that. Yeah, right. Exactly. Um, but here's an even bigger problem. As you know, Peter, um, banks operate under the, the premise and it's baked into all the regulations and statutes that you and I read every day is that you have to have safety and soundness. Yes, and doing business with people who have criminal records, especially if they could, you know, remember to if someone was really dealing in a lot of marijuana, they also probably were not paying their taxes. So that's fraud and dishonesty and fraud are key elements. The financial institutions. Must look at and are required to look at when they start doing business, not only with their own depositors, but third party vendors or anybody else. So you're bringing potentially problematic. Persons into the banking system, and yet the regulators are asking you to turn a blind eye. That's going to be tough. Yeah. Yeah. I mean, Joanne, I think you understand. I, I am absolutely in no way saying we shouldn't do this. Neither am I. But I see the problem being, you know, a central tenant, uh, uh, the BSA and, and, you know, your, your responsibility as a financial institution. Yeah. Like you're, you're not supposed to allow someone like this into the financial system. Now, I, I grant you that they, we will expunge, um, marijuana related charges, uh, but to your point, and, you know, again, you and I discussed this, which is there tends to be associated charges, right? And, and yeah, if you, if, especially if you move some real weight, the likelihood is there was a money laundering charge, right? There was tax evasion, there was fraud. Um, now I realize it's a hard conversation to have because it's a case by case basis, like what if the person had, you know, a cannabis charge and murder? Well, of course, you don't want to license that person, right? But what do you draw the line? What if they had a, uh, you know, a cannabis charge and, you know, they were driving under the influence, you know, is that okay? Like, so, so again, now you're making this weird judge, very subjective judgment call of what is and is not okay. And then kicking that can down the road, which is the banks, the institution saying, okay, do we want to bank this person? Um, and I can't sway to this, but I I assume that every BSA policy at every institution in America says if there's a criminal record, you know, we will decline that account. So I think I do. I think I have to because otherwise it's not it's it's it's it's a black and white risk. And that's what regulators are looking for. And they're, you know, Assuming this law didn't exist. All right. If a regulator came into your bank and wanted to, to look at your policies, proceed your, your, your opening account policies and procedures and the due diligence, their customer due diligence that you're going to do. And you didn't have a policy to ask for a criminal record at right. Reject. I mean, you know, your, your, your matters requiring attention are going to be long. Yeah. So, so what would you do? What's the right way to solve that? If I wanted to make that happen, I'm the regulator. I want justice involved licenses. I need the banks to be okay with it. Well, if my estate regulator or federal regulator, because I think that's going to be a big problem too. Yeah. Yeah. That's a key question here. So the state regulator, I assume can come in and perhaps has some willingness to do that. What water, what weight does it carry on a federal level? Well, yeah, that's it. It's an excellent point. I don't know. And we're going to talk about the P. A. Law in a minute because they are going to want to try to figure, try to balance that act. You know, I'm not sure. I think it's going to require, um, I think it's going to require a whole new set of policies. Your, your, your C. D. D. Your customer due diligence is going to be very different for these type of, um, Yeah. These type of new account holders. So I, I think what New York is saying is, look, we want them in the front of the line. We want you to evaluate them and they're going to get a different risk score than some of your other. Uh, applicants, they will be, they will be. Uh, you know, allowed to come in and allowed to do business, but boy, oh, boy, I can totally see what's going to happen. Those folks, the costs for them to do business in your bank, it's going to be a lot higher. It's going to be higher. Yeah. Much higher than, than, than a non, uh, you know, someone that had some sort of criminal conviction. Yeah. Well, now that also begs this question. Yeah. Will the those that are where it's going to cost more. My guess is that they're going to be from they're going to be minorities, women, uh, people of color. And now you're getting back into the same thing all over again. So they're going to be discriminated against, even though you let them in the cost. For them to do business is going to be higher, so they aren't going to be treated fairly. Yeah, but the system is going to ultimately dictate that. Right. Precisely the demographic you shouldn't overcharge, you have to now. Yeah, that's right. That's and look, keep in mind you and I are just making this up, right? Like we're talking like, like recent regulations, you've seen federal ones, federal proposals have have included various forms of, you know, Um, clemencies and, you know, meaning the New York model on a federal level is, it appears to be where some of these bregs are moving. So if they try to do this on a federal level, now we're going to have every bank in America having this problem, right? So. Yeah, I know. I agree. You know, I also think it made me think to a solution could be to put those, um, those depositors and also in almost like a one year trial period. So, yeah, you will charge them more, but if they show through a period of time that they're doing what they're supposed to do, they're reporting the way they should be reporting their, you know, all the information is correct. I could see them then coming out of it. So it's kind of like there's like somewhat of a grace period for a period of time, and then once they meet all those requirements, you know, transition into a more affordable type of arrangement. But look, I'm thinking of ideas off the top of my head. I don't know necessarily how that could work and I can certainly see regulators, especially consumer protection regulators saying that's unfair. Right. Right. Right. Um, I mean, I know so on a much smaller scale, you know, if you're on check systems, for example, or you, you've got a bad credit history, um, you've heard of like second chance accounts. So conceptually I could see that, but, but mind you, I, that, that, that's kind of like small potato stuff. Right. Exactly. Exactly. It's it's it's really going to be hard. It's there's a lot of head scratching about this and we'll have to see how it's going to play out. Have you had any instances of that right now? Or is this just an aspirational wish of DFS? Um, well, so. I, I, I would say it's aspirational in the sense that we don't actually, we haven't rolled out any of those licenses, right? Mm-hmm.. Um, but that said, all, as you can imagine, if you are thinking, even thinking about a license, applying for a license, that process kind of starts like right now, right? Or maybe yesterday, really. Right? Um, you know, you need. Open an LLC, right? Start paying, uh, attorneys and accountants, you know, et cetera, right? So it's not like you can just flip a switch and go apply for a license. Like you need to lay the groundwork for that. So I imagine, um, frankly, that there's lots of groups, investor groups. So, so LLCs out there. That are lying to their banks right now, right? We knew that we knew no names provided, but we knew that we absolutely knew that. So, um, well, this brings us to the PA law, which wow, that came out. Someone had to call me about that. I didn't know anything about it. It was really under the radar. At least in my little world. Um, and maybe my world's too small, but EA did enact a law, which to your point, Peter, what you were talking about in the last topic, basically allows the state to say to a bank, you can, you, you know, don't discriminate because they are a cannabis industry. Uh, don't, um, entice. People not to come and get a bank account. Don't, uh, you know, we're going to let you in even though if you meet the definition of a of a legitimate cannabis cannabis related business, that's fine. Okay. And, and the law says, you know, don't worry about what the Fed federal regulators say we're going to. I mean, great. That's wonderful on paper. I don't know how this is going to be implemented. And again, I think a bank, maybe a state chartered bank who is otherwise examined by, say, the FDIC, a small community bank examined by the FDIC. Um, that's wonderful. You have this law that's going to do nothing for when the FDIC comes in and examines me. Right. So, you know, a state version of like a safe banking act. I mean, it makes a lot of sense on paper. Um, I can see that, you know, state chartered institutions, you know, what would that would be a good thing? You know, in 2018, um, in New York state, our, our DFS department of financial services released a memo, uh, essentially encouraging, you know, state chartered institution to bank what was then a medical only, Um, and it had it had positive impact. Um, so I can definitely see a state charter institution saying, okay, well, you know, my regulator is basically saying we're good to go. Right? Um, now, again, it does create some uncomfortable moment when you turn around and you go to your FDIC and say, um, you know, hey, you know, are these deposits FDIC insured, for example. Right, right, right. So, you know, there's look, there's a good amount of state chartered banks. Um, a good amount, certainly in Pennsylvania, but there's still that friction between, you know, we have a dual banking system, as you know, and there is still that friction between state and federal regulators. And even if you to your point, even if you are state chartered, you still have to deal with the feds At some level, and you're still going to have to deal with the fact, certainly through your clearing houses, right? The money's going in the Fed wire, you know, that's wonderful that you have a charter in Pennsylvania, but the feds govern the wire. And that's always been the issue with the federal regulators in that, you know, minute hits that wire, that's the problem that they, that they've had. Yeah, I mean, in a way that this, the, I don't know that the disparity is clear, right? Like, like the fact that there is, um, you know, a clear, like oxymoron, I guess you could say. Right. Like, so for example, if you were to take, so you know how in the, in the old days, um, the cannabis business, they used to literally drive cash to like the local fed to pay their taxes. Right. Yep. Yep. But that's the fed. Are you taking cannabis money then? Right. Exactly. Exactly. Exactly. Um, I think it's kind of a way in, in my opinion with Pennsylvania is a way to kind of justify. Well, you know, now that we're saying that you can go to these, you know, these financial institutions, so it'll be much easier now to pay your taxes. I think it's, rather than this being a, a state safe banking act, it's an easier way to pay your taxes act. So I mean, summary, I think to your point about like a brick in the wall, right? Yes, another brick in the wall. And yes, it's a great one. Optically, does that make people feel, you know, hey, we're we're one step closer. Hey, that makes me feel good. You know, you know, when we when I started a program. In New York. We did take that DFS memo and stick it in our BSA policy. You know, it was part of the justification part of the pitch to the board. So does it have value? Of course. Yes. But then on a practical level, what value does it have? What does it actually do? Um, and I think there's someone there's some, you know. Clear questions. Well, as they say, you always have to crawl before you can walk. So I think we shouldn't we should be thankful that we're having these kind of incremental baby steps towards, um, building a comprehensive financial services process, uh, for people in the industry. But in our little critical minds, we have to say, this is a, this is complicated and yet cracks in the wall are good, but we have a lot more demolition to do. That is for sure. Yeah, yeah, Peter terrific conversation. Thank you so much for coming. But before I let you go, I have a couple questions and asks of you as I do all my Predat Eco2Go podcast guests. Uh, the first one is, uh, when I started the podcast, I asked everyone, uh, what they were doing because they were sheltering in place. Cause I started the podcast in, uh, June of 2020, right? Still in COVID, unfortunately. And, um, so now that we. Thankfully have, I wouldn't say all of us have left our homes, but life is getting back to somewhat of a normal, uh, uh, environment. Uh, wanted to know what have you done? Is there something that you've been doing in the last, uh, two years that you wouldn't have done but for COVID? Oh, um, you know, actually I'm going to answer the question in the reverse. Okay. Uh, when I first started out during COVID, I absolutely leaned in. I was, you know, rolling around in my pajamas. I, you know, didn't shave, you know, not that I grow much facial hair, but you're young. And I, it occurred to me that that was, it became a detriment to my daily process. Like, like I started to get lazy, you know, I was, like I said, literally rolling around the house Um, and I had to force myself to follow a routine, even though I was just sitting around the house. Um, and so, so actually what I did was I went back to normal. Uh, now granted, I'm not commuting, you know, stuff like that, but, um, I, I did have to physically, you know, mentally stop myself from changing my routine in order to like, you know, stay sane, I guess. Good for you. Good for you. No, I, I think that's, I think that has been a struggle for a lot of people, uh, during COVID. It's like, you know, I used to get up and get dressed and go out of the house. Now I'm wearing Lululemon all the time. And, you know, I, I think people are kind of feeling either guilty about it or just trying to wrap their hands around that kind of new. routine. So I think you're very smart for doing what you did. So I, I certainly applaud you on that. That's great. Um, the last thing is in consideration of your time, uh, credit eco to go would like to make a small donation on your, on your behalf to an organization that is making an impact on people's lives. Now, I will tell you when I started the podcast, we really focused a lot on food, which is why the, to go a title of the podcast, but now I ask people. All the time. Uh, you know, just name an organization that you, you know, have an affinity with. You really, you know, appreciate, you really admire. And I really learned of some really wonderful organizations, and I'm hope you have an organization that you'd like to identify. So I I was fully ashamed that I did not. I wanted to tell you, though, I was like, Wow, that's so cool that you do that. I did reach out. So one of my esteemed colleagues, Stacy Licky, gave me a name because unfortunately, I didn't have my own name to give, which I do feel ashamed about. Three squares, New England, which is a regional food bank is the name that she gave me. But, uh, but yeah, you, you simultaneously made me inspired and ashamed. I have that impact on people. Well, that sounds, I am very interested in looking them up and learning about them. And I've heard about all kinds of wonderful organizations like that. through this podcast. So thank you so much. Thank you for reaching out to Stacey and we appreciate her that she gave you the recommendation. So again, Peter, thank you so much for coming onto the podcast and many thanks to our loyal Credit Eco2Go listeners for tuning in and logging on. All episodes of Credit Eco2Go can be found on Buzzsprout, Spotify, and Apple podcast among others. Information on our podcast can also be found on my clarkhill. com bio page, as well as my LinkedIn page. If you'd like to be a guest on the show or have ideas for future show topics, please email us at credit eco to go at clarkhill. com. Thank you. Be well and stay safe. This podcast is intended for general education and informational purposes only, and should not be regarded as either legal advice. or a legal opinion. You should not act upon or use this publication or any of its contents for any specific situation. Recipients are cautioned to obtain legal advice from their legal counsel with respect to any decision or course of action contemplated in a specific situation. Clark Hill PLC and its attorneys provide legal advice only after establishing an attorney client relationship through a written attorney client engagement agreement. This recording does not establish an attorney client relationship with any recipient.