A Look at the Recommendations of the CFPBs Taskforce on Federal Consumer Financial Law with Special Guest Professor Todd Zywicki, Taskforce Chairman: Part I
Welcome to the consumer finance monitor. Podcast where we explore important new developments in the world of consumer financial services. And what they mean to your business your customers and the industry. I'm your host today. Alan kaplinsky at ballard spahr and i'll be moderating today's program for those of who want even more information about the subjects that we are covering In our podcast please remember to Subscribe to our blog Which is also called consumer finance monitor. We've posted this blog since two thousand eleven and there is a lot of content on there and indeed We recently published blog about the very subject that we're gonna be talking about today so Let's get to our topic of today and in just a moment. I'm going to introduce our speakers today. The topic is the A report recently issued by The task force onc federal consumer financial law This was issued in early january after the cfp. Be about a little more than a year ago. Decided that it was high time to Appoint a luxurious group of Experts in the area of consumer financial services and have them take a broad holistic view of the consumer financial services industry and The laws that apply to it. And the things that are outdated and the things that are missing because of technological changes and They produced a report That is Very worthwhile For antibody that spends any time in the industry to study in detail. But let me warn you. It's not Bedtime breeding this. This is a long report. it's in two volumes. There are seven hundred pages of background in one report which is gonna be a fantastic resource for people who are Studying particular issues That pertain the consumer financial services law. And then there is about a hundred page volume two which contains one hundred and two separate recommendations about various changes that the task force unanimously agreed upon And these changes Stations really cover the waterfront of consumer finance. There is a lot there. now Would be better to have as my guests on a program Covering this topic then the chair of the committee of the task force that Put together this report so Once again i want to welcome back to our podcast professor. Todd's wicky And a lot of Welcome back todd. Grew delighted to have you. Thank you allan. i'd thanks for the invitation and also thank you for your blog which i read every day and his any central resource for those of us trying to keep up in the fast moving developments in this world. So it's thrilled to be with you. Thank you let. Let me just say a few things about todd. He is previously been a guest on our podcast so This isn't the first time. And i'm sure it won't be the last time. He is a jew. George mason university foundation professor of law at george mason university antonian scalia school of law He is also senior fellow of the cato institute he as a bio and a resume literally a mile long he teaches at george mason. a number varies a law. Bankruptcy contracts commercial law law and economics and public choice in the law I've known him because of the focus said he's had over His career on consumer financial services law He also has been a frequent Commenter commentator i should say Ah just about every notable Talk show on radio and tv. Also too lengthy to mention Before we get into that the heart of our program today me also introduce My partner chris willis Chris willis just succeeded me as co chair of our consumer financial services group Chris is practices at deals with. Consumer finance is a litigator by background. is probably Handled more zia. Pb investigations Than anybody else. I know in the country literally dozens and dozens of them surprisingly not just during the richard cordray era but during the kathy chronicler era And he is Expert In a lot of the areas that The task force focused on. That's why i want to have him as my Also a guest today But our principal Focus is gonna be in Asking todd a number of questions about the task force and then having a christmas chime in when appropriate in certain areas so let's Let's begin it so Todd how did you get so lucky to be selected as share of this incredible task force. I mean how do they happen. Well allen i have to say it was a real privilege and honor to be trusted with this. I want it's often pro forma. But it's sincere here. I wanna thank director kranenburg for envisioning this and committing to it as busy as a big project and particularly personally for not only having the opportunity to serve as the chair but to work with this unbelievably gifted group of fellow taskforce members howard beales. Tom durkin bill. Mcleod g noonan and our staff of who was who was incredible. We have small staff but they did unbelievable work and Most of them. I've not even ever had a chance to meet in person because the task force started in january we had to in person meetings and literally the day we were finishing our second week of in person meetings as the day. They close the the building in march. And we've done the whole thing. Virtually since then so and the task and the in the staff his just been been unbelievable. That members were unbelievable. It's just been a real thrill so i take it. The staff was drawn from Staff at the cfp is that how worked Most of them. yes so we. We had a combination of a couple of staff members drawn directly from the cf. Pb we ha- we borrowed some people from From other agencies one from the department of transportation one from the fed and we hired some some new hires Into the into the task force in for all that i want to recognize that weber in particular. Who was our staff director. Who oversaw all that and built a great team. I also while. I'm thinking recognized. Brian johnson leonard chain and. Tom paul who are three deputy directors during the time that this was ongoing. Who just really totally enthusiastic about it than supportive. Yeah so when you got together For the first time how did the task force decide what issues it was gonna focus on. How did that come up. That's that's a great question. Now because this is so these efforts of consumer financial form coincidentally seemed to come on fifty year cycles. In the nineteen twenties it was the modernization sort of people left. The farms and immigrants moved into the cities. There was a need for consumer finance. Like they didn't have in the past and that led to the uniform. Small loan law and a lot of reforms by the nineteen seventies nineteen sixties. What we saw was sort of a more national economy and the national economy basically called for for for for modernisation consumer finance laws but also a larger federal presence for things like dealing with declining cost of long distance calls for something for example. If you don't think about but which made the system of purely state based regulation of debt collection unworkable and so we get federal financial laws on on debt collection in the like so. We're on this fifth year cycle now and of course the development was the internet right. It's not just a national economy. We've got technology people using formation differently people shop differently all these different sorts of things so what we had was. We did have a big template to paint on allen and what sort of focused us throughout were or three goals. I was a focus on inclusion Financial inclusion and access which all of us believe is a moral imperative and the creating financial system that works for everyone is really important so that focused us a lot a second was thinking about focusing on consumer harm the and you know how to best use resources to minimize consumer harm maximize consumer welfare and the third thing was really modernisation which was to deal with the impact of technology and those sorts of shocks and so one of the things. You'll see alan. Is that the second. Half of that is. What didn't we address because people are often surprised just because something was important and we acknowledge a lot of things are that doesn't necessarily mean we address this and we laid this out in the forward the most obvious omission is. We don't say a lot about mortgages partly because mortgage is sort of a subject unto itself but what we when we were deciding what to address we ask three questions Which is i is this important. Second do we have a comparative advantage in saying something about it and third is do we have something useful to say about it and so if you take mortgages for example obviously that's hugely important but it's also the case that the cfp pb has done a huge amount of work on mortgages over the past past few years And and you know there's been a lot going on that that so so there are three par test and you know people can figure out You know what we decided to address on what we didn't partly based on that So one of the things. I noted that you didn't directly get into it. Although i guess i think it may be implicit in the section of the recommendations deals with small dollar lending. I don't think i saw anything in the report about the bill. Pending before congress to create a thirty six percent interest rate tap. We did not address. We did not address that and in allen partly what it is is i think You know there she you said there's there's two volumes. The second volume is addressed to pacific specific issues. That exists and i think there's a lot there that could easily read and figure out what but it's not intended to just be addressing kern bills current legislation right. It's basically here's some concrete proposals that might be done of the next you immediately next year or the next five years following. The one is the longer term sort of addressed in the next ten or twenty years of concepts and that sort of thing. And so i think the idea there is. Is this specific issues that come before the cfpb congress and other regulators. They're going to change right. They're going to vary over time and so we tried to do is basically say look. We're not going to write a report. That's going to be obsolete in a month or whatever we're going to write a report that address specific things that we think today could be things that would make the lives of consumers better and then we're also going to write a gigantic volume little say as new issues arise. Here's how you can go back to the principles we've laid out and apply those principles to specific proposals that come along or specific proposals. That might come along and so and so you know. There's really not anything in there. This addressed to particular legislative proposals in the lake. But but but you know the specific issues change. I think the report should be evergreen to say. Well here's a starting point to start thinking about things like a specific interest rate cap on in the like right so I think out of fairness to our listeners. They oughta be aware that there was and maybe still is some Controversies surrounding the creation of the task. Force a number of Consumer advocacy groups and a law professor I'm drawing a blank on her name right now but really I guess you could say They got their nose out of joint because they felt that the cfp be had appointed only industry people and they didn't appoint any consumer advocates and therefore it no matter what is in the report it ought to be disregarded because it does doesn't represent a fair cross section of us In the industry. So any and am filed a lawsuit against the cfp be Related to that What what's your reaction to that criticism Sheriff i'll say a few things. I and obviously i'm not gonna comment on the the lawsuit in like but that the first i wanna make clear. Is you know the five of us. We had nothing to do with selecting who was on the task force. We were select. t's not selectors and whether they may have asked other people who chose not to do it because they didn't want to or because they had conflicts issues or didn't want to divest conflicts issues as all kind of possibilities. I i don't know what it was. I know is that we had nothing to do with selecting the task force we were just. We were chosen. I think the second thing is our backgrounds in qualifications as consumer advocates i think speak for itself. We had to former bureau director of the bureau of consumer of the bureau of consumer protection at the federal trade commission. Tom durkin is. i think. Generally regarded brunell this the leading consumer consumer finance economists of his generation. He was just honored last year by the pb at their annual research conference for his contributions to this and g noonan was the founder of the first lawyer hired and the credit practices division at the ftc. many ago and later went on to the to the To the farmer's a i can't remember the name fans are too so i think it i think what we have speaks for itself. People decide what that is. But there's a larger point here alan. Which is that. I think this whole idea of consumer advocate and industry and all this sort of stuff. It's just we wanted to get beyond that in this report. This whole idea that right. Consumer financial regulation is a zero sum. Gang says you. Some conflict between more and less regulation is just not a productive way to think about this. I don't even know if we use the term deregulation in the entire report. Because that's just not the way we think of it and we say specifically in chapter six of volume one. We got to get beyond the idea that there's a zero sum game here. Consumer financial regulation should be aiming at creating a positive sum game with regulations. That are good for consumers. Good for providers in good for the economy at large right. And that's and that's what we should be aiming for and that in a lot of regulations relations are like that in that that should be the goal and so So i think from that perspective. That's what oriented us. That's why we have a seven hundred ninety eight page volume one. Is we show our homework. I think they should be able you know our old. Our overarching goals of a more effective regulatory system financial inclusion of financial modernization should be able to agree on that the goals that we do were the goals of the national consumer. Nc fifty years ago they may disagree with specific proposals and recommendations. We have but we go through painstaking detail over seven hundred ninety eight pages to explain where we came down to what we came down on and if they disagree they can disagree. But i think we're about as transparent as you could be As to are reasons for why we said included what we did right. So let's dive into the report right now. a one of the I thought more interesting segments of the report. was the one dealing with alternative data And maybe before we get into what the task force recommended How do you define alternative data. Todd what is really the way we define and one thing. I should say i want us. Also this. this was a consensus report. Everything in this report all five of us agree to its speaks. It speaks for all of us. Alternative data we just kind of a working definition not a specific one but really what it is is the use of data and that's not part of a traditional credit underwriting model essentially the things that go into a fico score and that's really sort of our working definition of what is alternative data. But we don't try to pin it down specifically because we kind of wanted to keep a functional definition rather than some formal definition. And i which i think is important right in. This might seem like a bit of a digression but one of the other things we says. This whole idea of banked or unbagged is not not a productive way of thinking about financial inclusion people consume financial services and all kinds of different ways these different types of payment providers and so i think alternative data versus regular data. It's kind of a continuum But it's really information that could be provided in the system. That's not part of a traditional underwriting model that could be useful for consumers in gaining access to to financial products and financial products a greater variety to lower price. okay and what exactly did The taskforce recommend with respect to alternative data. And then after you comment on that. I'd like to get chris's reaction as an industry lawyer to what has been recommended. So we have a three things three specific recommendations on this The first is an access to financial data. Which is that cash flow payments information. Things like that right. This is something that everybody agrees is useful in probative and should be allowed to happen. Basically can you pay your bills. Even you know even if you're you don't have credit card now that you're paying regularly. Do you have adequate cash flow to be able to service a debt for example these sorts of things right w ability to pay bills like rent and utilities and things like that to the extent that that can be useful to consumers to To include this the second thing we were really careful about. It's kind of a a a negative recommended dacian in in some sense which is to say. Don't freeze whatever we have today. Don't freeze in place. People's preferences people's expectations change over time. Right what people think of as an appropriate or an inappropriate use of consumer information changes and so don't put in very prescriptive rules that are going to tie. The hands of people in the future is to what they think should or should not be Permissible to include allow that to to to evolve without heavy-handed legislation or something like that The third thing that we We point to is just a lot of it is just simply is focused on particularly with people for thin or no credit report files and it also relates to any place that it's necessary for congress on this kind of a catchall to include clarification of laws are statutes that might be necessary to use this information We got a you know we. As part of the report we sent out our f. I request we are staff. Did a We did a comprehensive review of all the the websites and materials put out by consumer advocacy groups and others and we got a lot of feedback and one of the things we heard was that one of the obstacles to greater use of alternative data was a perception of regulatory. Uncertainty wasn't always clear to us whether that was justified or not. But but we but we did hear that and so we said basically wherever it is thought useful to clarify people's opportunities to furnish data that that should be done to to add those kind of clarifications whether through rule guidance or some other vehicle. Chris what is your reaction. I know you've done a lotto counseling of clients About alternative data. What do you think i think this is. One of the recommendations of the task force made that hold the greatest promise for increasing inclusion in our financial services system. We have been stuck for a long time in traditional way of underwriting credit products that looks at. What's on a person's credit bureau with the three big national credit reporting agencies and that's it and the cfp has expressed a massive amount of concern over what it calls the credit invisibles even writing three reports about them and this isn't a small group of people. The cfp bees reports say that there are like thirty million american adults who were frozen out of access to credit because they're thin fouls are no hits the national credit reporting agencies and they may have patterns of behavior. That don't cause them reflected in those databases so right now if we don't use alternative data they're frozen out of the system and that's not desirable not from anybody standpoint and the cfpb in particular has said that it's not desirable and i think the bureau has that the use of alternative data is the number one thing that can be done to accurately underwrite applications from people like this and so one of the things that i found most telling about the task force report was it's admonition for regulators to be cautious about restricting the use of that data and credit underwriting and in that vein what i would point out is the use of alternative data is subject in today's conversation to both general and specific issues that i think are very unfounded and very counterproductive from consumer welfare standpoint. You have this general attack that well. If we use alternative data in credit underwriting models it may have disparate impact and it may reinforcer perpetuate traditional notions of of discrimination that are embedded in our society and so therefore it must be a bad thing to to use it and then you have specific attacks on the use of specific types of alternative data so for example you have a collection of democratic senators who wrote letters to the cfpb accusing various student lenders of using alternative data in student loan. Underwriting that the senators say is a potential violation of the equal credit opportunity. Act again based on this idea that there may be a disparate impact in the use of that data and credit underwriting. What i think all this criticism fails to realize is the level of disparate impact. That's present in the usa. Fico scores or traditional credit bureau. Attributes is very large and all of the data that i've seen and we do work for a lot of alternative data providers as well as creditors who use alternative data and their models and invariably the data shows that the use of that alternative data increases the inclusiveness of the credit underwriting models. So it moves us in the right direction. It doesn't eliminate disparate impact like. There's nothing that i'm aware of in credit. That will eliminate it altogether but what we should do is we should move as an industry and as regulators in the right direction of allowing this data to be used and to be very cautious about starting to attach fair lending problem areas to the use of alternative data because if you want to deter the industry from doing something go out and say it's a potential fair lending violation that is the surest way to deterrent and the cfpb to his credit has done the opposite. The pb granted a no action letter to upstart that includes the use of some elements of alternative data. And then patrice vickland. The director of the fair lending office at the. Pb wrote a blog post a couple of years later sank. We've looked at the fair lending monitoring for upstarts underwriting model and we see no areas of fair lending concern so the bureau has not been party to this attempted discouragement of the use of alternative data. It's happening more in the private in private commentators. And so i think. The task force took it upon itself to respond to that criticism. Show that it is unfounded and to me we did a very valuable service both for consumers and the industry in doing so okay Thank you chris. let let me What why were on the subject of access and we've talked about the disparate impact. Theory let me A focus on something that is also hot issue namely ldp limited english proficiency. That is marketing. Two and an offering products to customers who main language is not english. Something gals And they may speak no english or very little english and that's been a a major headache because companies have felt that gee yet we want to make things available but you know if we open up that door Emily start you know Saying something's and a foreign language or languages does that mean we've got a everything's gotta be done in that language and we've got documents in that language it. We have two people who speak the language in every branch. So what what did. What'd the task force do their dot. Yeah that's great. I'm glad you picked up by one on that one. Allen or one of the things that i've been gratified with a dumb some people picked up the media's picked up sort of the flash and dazzle woah big high-profile things. But i appreciate that. You and chris and others have noted how much value there isn't a lot of these relatively smaller more technical that could really benefit consumers and i think that's a that's a good example the recommendation we have on that and and and it again is is christmas. Just suggesting in many ways with alternative data. It's a off question which is that. There's great benefit to be able to for financial inclusion of being able to reach out to consumers but if it's going to be a huge costly undertaking especially to reach consumers with relatively limited assets and income in opening up to liability and a large costs. Like you're saying to make everything comprehensively in that language that's gonna raise the cost of servicing those consumers. And so you know our report. This is basically. Let's focus on making sure that the relevant information you know the most important information and things are really matter are giving people in a language accessible version. Think about how more flexible ways of serving those consumers. And why does this matter. Well if you look at the fdic studies on On unbend consumers. What you see is and we talk about this in chapter ten of the report which is what you see is the fdic reports that the second largest caused of by consumers say they're on bank is a generic expressions called. Don't trust banks but it turns out if you peel that back a little bit. What you see is that's now a catchall for Questions that we're asking earlier studies toward more disaggregated. They limited the number of choices. And what one of the things that seems to be picking up. Is this question of foreign language. Access that back when they asked this question and one of the big reasons consumers say they were. Unbagged was because of foreign language problems and so we wanted to try to make it the case that you could at a cost. Effective efficient manner provide information in a foreign language so the customers could feel like they knew at least what was going on. Obviously obviously you wanna police that with you depp. And other sorts of sorts of things but this is a good example of of using those sorts of more principles based flexible rules of dealing with the problem rather than a highly prescriptive expensive regulatory system that has unintended consequences. The yeah so chris. What's your reaction to what the task force did with respect to ldp again. I think it's a step in the right direction. And it's really consistent with the position that the bureau has been taking over the last several years with respect to nine english languages if you look at the supervisory highlights guidance that the bureau put in two thousand sixteen on leap. They were very much of the view of trying to encourage financial institutions to do something in non english languages and not requiring then everything had to be in the non english language because the bureau rightly perceived that would be a barrier to doing anything in a non english language. And you see it again. In a very recent reflection the final cfp debt collection role which the second piece of came out on december eighteenth. It contains a provision about providing validation notices under the fda to consumers by debt collectors and giving them the option of providing in spanish. It's not required but a debt collector has the option of giving one in spanish notably though the rule or the official commentary says that if a debt collector chooses to provide that validation notice in spanish. It doesn't imply a requirement for the debt collector to do other activities in the collection of the debt in that other language. The idea is to ease the industry in to providing non english-language support by allowing them to do at one small piece at a time which is actually ascertainable and easy for the industry to do. Because if you tell the industry you can't roll out any part in spanish until you can do it all in spanish then. No one will ever do it. And when the industry believe that was the rule based on some consent orders that predated the supervisory highlights in two thousand sixteen. Guess what nobody was doing. Anything in non english languages so i think the task force and the fair lending staff have both seized on the correct way to address this in a way that in the practical real world means more financial inclusion for people who don't speak english as their first language. Okay i'm a. Wow we're on a roll talking about the fair lending and fair access Y there's reference has been made to this Disparate impact doctrine And our despite the fact doctrine a a doctrine very heavily utilized by director cordray During the for many years I invested when they were investigating auto finance companies companies were buying retail installment sale contracts from auto dealers around the country and First of all Just you know. Make sure Were everybody listening to our program. Today understands what it is. Maybe you could describe todd. What is displayed. Impact and Under the equal credit opportunity act. And then i'd like to you to tell our listeners. What it did you recommend there well. That's a hard one to to summarize. And if you look at the recommendations that's one of the more complicated in dense recommendations the the reader's digest because there's questions about this This basically what it did for reader's digest version. Most people think about discrimination through a lens of whether somebody intentionally discriminates against some other person based on their race sex or some other some of their characteristics. This bird impact Concepts basically deal with the idea of if you find a statistical disparity among people that is Correlated in some way with their race sex or some other impermissible characteristic that What are the circumstances under which that can be inferred to be caused by by by by discrimination in in chris. Might have clarification on that. And that's i say very very dense and very detailed as to to what it is and obviously this is something we took very seriously. And because you know we feel very strongly in equal credit access That's a very strong societal view. With respect to that. One of the things that i'm particularly i think is important in our report is that we urge more attention to that in modernization and review of of fair lending generally so for example. One of our proposals is that we should study and consider the obstacles with respect to disability. Disability is not currently included under rico. We don't say that it should necessarily be but we do but what the report does say is. We should investigate to see. What the challenges are we know that Households with this able people are more likely to be on banked for example. And so we don't know whether there's there's issues they're not but it's worthy of consideration we also talk about modernizing it to get rid of you know sort of somewhat archaic regulation so for example one of the where. It's not really necessary anymore counterproductive. So one of the interesting things is you're not allowed to ask about somebody's child bearing plans well one products z. Merged in recent years is people find providing financing for expensive alternative for fertility right. I've and that sort of thing and this may come as a shock to you but that tends to be disproportionately women who have childbearing plans. And nobody really thinks anymore that. Somebody's going to discriminate against you because you have childbearing plants a bud. It could interfere with these things. So i think you know a lot of what we're saying is let's look at this. You know it's been a real charter. That people believing since the seventies but there may be some changes With respect to with respect to this but let's also a lot of what we talk about here in the states very detailed and very precise is is drawing the line the christmas talking about which is ensuring fair access. But you know in in nondiscrimination but also doing it in such a fashion that it doesn't unduly interfere with Financial inclusion and the other that that that that people have in want it can make their lives better off and so are a lot of our recommendations are sort of tailored towards drawing that line creating more predictability in this world so that people aren't chilled in the way christmas describing earlier For for lending purposes in like and so a lot of what we have relates to things basically clarifying the law in in the like so chris Any reaction to what towns has had to say. You know one of the things that have always said to clients about the fair lending laws. Is that the first mistake that lawyers make is trying to make rational sense out of them in the way that they are applied. And the reason that i say that is because it's one of the least predictable consumer credit regulations that we have on the books. Because you have this idea that i you have a disparate impact so whatever the creditors doing will disproportionately impact someone on the basis of a protected characteristic but the thing is a lot of things creditors do have such an impact like using fico scores for example but that by itself doesn't make it illegal right because the disparate impact test has two reports first there has to be a disparate impact then if the creditor said shows that it's doing whatever it's doing for a legitimate business purpose then it's okay theoretically it's off the hook only does it then get liability imposed on it. If the government or the plaintiff proves that there's less discriminatory alternative that serves the business justification equally. Well the problem though is that everything creates a disparate impact and credit. Because that's just the way that the data is and we hope to move in the right direction on that but that's the state of affairs and the enforcement activity that we've seen under the fair lending. Laws is marked by a selective disregard of companies legitimate business interests. And so you could say well. Hey i'm doing something and here's my legitimate business interest and sometimes the government will say that interest is okay and sometimes the government will say we disregard it and there's no predicting when the government will disregard versus not disregard. What your legitimate business. Interest is for doing something on in connection with a credit product. And so the predictability point that todd just made is one that the industry could really use because i think there's very little predictability because the thing is you can sit there and look at what the enforcement activity has been over the past ten twenty thirty years and say okay. I don't wanna do that. The thing that other entity got in trouble for. I won't do that. But what you don't know is what's the next innovation that the regulator or a court made but more likely a regulator and say. Okay here's something that hasn't been done before. But now i will find this to be a violation of the equal credit opportunity. Act under the disparate impact doctrine. There's no predicting that and that does act as a great sort of deterrent to innovation. And i think to strategies that would involve more inclusion of more people within the credit system. Me if i could just add on that because this is something we you know that the task force talks a lot about in the report is sunday thinking about this in a wide angle lens about overall as i already mentioned inclusion but if you think about the auto dealer example For example in chapter ten we note that the pc chose a particular way of dealing with the allegations of the disparate impact in dealing with the auto dealer litigation. There's some evidence that what they ended up doing was essentially the the effect of it to make sure everybody's getting the same price was to raise prices for consumers in stifle competition right so one way in which you can make sure nobody gets a different prices to have a perfect cartel right where all consumers pay more now. We don't know that that's the case there. There's some suggesting that it was but one of the proposals that we have in the report. That kind of are under good government type thing is. We suggest that the bureau should do just as bureau does retrospective review of its major regulations. We say the bureau should do retrospective review of its major enforcement initiatives to find out sort of what they wanted to do whether they did it and what were. The unintended consequences might have flowed from it. Because that's a possible example of a situation in which the tool that they chose may have reduced disparities in pricing between between different groups. But maybe at the cost of increasing costs for everybody bringing the bottom up rather than the top down which would be very informative going forward as to how you might want to deal with situations like that in the future. We've covered a lot of ground today. todd and We're going to have to bring this segment to a close However next week We will continue on Because i still have a lot of areas to explore with you. So lobby Thank you so far todd. But you're not done yet and let the also thank all of our listeners. Today and Urge i all view to download The next podcast where in which we will deal with The remaining Important issues pertaining to the cfp b.'s. Task force on federal consumer financial law with our special guest. Professor todd zoecke.