AFC Series: Open Finance Showdown: Suits, Countersuits, and the Future of Financial Data

Open Banking has become one of the most significant regulatory challenges of the last decade, with global implications for both financial services and consumers. As financial institutions and consumers navigate the evolving landscape of data sharing, the U.S. has recently introduced new regulations that may reshape the future of financial innovation. In this episode, we explore the launch of the Consumer Financial Protection Bureau's Final Rule for Open Banking, its mixed reception, and the lawsuits that followed its finalization.

Hosts: Rachel Morrissey, Money20/20 US

Phil Goldfeder, CEO, American Fintech Council

Guest: Alexandra Barrage, Partner, Troutman Pepper Locke

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Episode Transcript

Rachel Morrissey (00:05):
Welcome to the Money Pot.
My name is Rachel Morrissey, Iam here on the podcast from
Money 2020, and we are doing aspecial series with the American
FinTech Council around all ofthe very quick changes and
difficulties around issues oropportunities, around issues

(00:27):
happening in the fintech policyworld, and joining me as my
co-host for these is PhilGoldfeder.
He is the CEO of the AmericanFintech Council.
So, hi, phil, how are you doing?

Phil Goldfeder (00:40):
Great, so great to be here with you again,
rachel.

Rachel Morrissey (00:42):
It's good to be with you and here.
Our guest today is AlexandraSteinberg-Barrage, and I want to
make sure I got Steinberg rightand I didn't say the wrong.
Give it the wrong pronunciation, so and she is a partner at
Troutman Pepperlock and we arehere to talk about open finance,

(01:04):
the suits, the counter suitsand the future of financial data
.
So let's throw it to you, Phil,why don't you go ahead with the
first question?

Phil Goldfeder (01:13):
Yeah, I'm really excited to be here with you,
rachel, but Alex is really theleading expert on the subject.
I've been following her formonths and really just excited
to have this conversation andreally put it out for the world
to see some of the expertisethat have been leading from the
front line.
So, alex, we're going to jumpright in.
You know, open finance, openbanking, has been a hot topic

(01:33):
for quite some time.
Specifically, as we all know,the CFPB worked on this issue
for a long, long time, many,many, many more years than just,
I think, the one year thatpeople were focusing on it.
Meanwhile, if you look overseasin the UK and the EU, many
other jurisdictions are wayahead and have moved forward
with formal open financeregulation frameworks.

(01:54):
What do you think took the CFPBso long?
And, once they put it out, tellme about how you thought in
terms of the way you wanted toflavor the response and where
the law needed to end up in theUS.

Alexandra Barrage (02:08):
So thanks very much, phil, and thank you,
rachel, for inviting me on thepod.
I love these questions,especially around consumer
regulation.
I'm a bank former bankregulator and core bank
regulatory attorney, but I dosee so many crossover issues on
1033 and other consumer regissues that have significant

(02:29):
impacts on my practice.
So I think that your question,phil, is interesting and I, as a
lawyer, will want to take justa moment to step back and think
about the terms you used theterm open finance and the term
open banking.
For a lot of people, this isinterchangeable, these two ideas
.
For some, it's actually verydifferent.

(02:50):
So I want to talk about it inthe general sense of open
banking and I don't want to getoverly technical about this, but
I would say if you understandthe differences in these terms,
it helps you then understandmore broadly the context within
which these frameworks havegrown up across the world.
So when we think about openfinance, that is really a

(03:15):
broader concept to me than openbanking.
Open finance is focused on datasharing between banks and
literally any other third partyright that could be data
aggregators, could be insurancecompanies, could be non-bank
lenders just a much wideruniverse.
To me, open banking issomething more specific.

(03:37):
It's really about improvingconsumer choice, convenience,
making it easier for consumersto share their financial data
with financial institutions inour construct, primarily banks
and so when you kind ofunderstand those differences and

(03:58):
you look at, okay, what'sspecial about open banking?
If we were to step back and lookat open banking frameworks
across the world, we would seebasically three things.
The first thing is how are wegoing to standardize the data?
We want the data in the sameformat.
We want protocols for easysharing.
We want to create rules toresolve conflicts between

(04:22):
participants.
That's definitely one theme.
Another theme is aroundconsumer safety and consent and
disclosure.
So a lot of open bankingframeworks focus on protecting
consumers from bad actors andensuring consumers have a say
around who can access their data.
And then the third elementthat's common to open banking

(04:46):
frameworks is data access.
So we want to set limitationson who has access to data and
how third parties use and savethat data after they have
permission.
So then you step back and you'relike, okay, what has the US
done and what has the rest ofthe world done?
You're like, okay, what has theUS done?
What has the rest of the worlddone?
And certainly the US, you couldsay credibly has been at the

(05:09):
tail end of this open finance,open banking kind of chronology.
But at the same time, we can'tbe making apples to apples
comparisons on these frameworks,right?
So you know, one way to thinkabout the evolution of these
frameworks is to start with whatEurope has done.

(05:30):
You know, the first realregulatory development we saw in
Europe was back in 2015, soliterally 10 years ago, when the
European Parliament adopted apayment services directive that
was known as PSD2.
That was not a regulation.
That was basically a directivethat required member countries

(05:51):
in the EU to develop their ownrules, which they have, and
essentially this was kind oflike the first effort at open
banking.
There were definitions in thePSD2 directive obligations for
market participants and so on.
The PSD2 directive, obligationsfor market participants and so
on.
Some of the friction, I think,across the world has just been

(06:15):
banks in general being slow toagree to the technical specs for
how they share customer data.
That's a theme that we see eventoday, with the 1033 final rule
Following the EU over the nextsix to seven years, other
countries enacted laws andregulations, such as Australia
and also the UK, than the UShave.

(06:44):
So we should just like giveourselves a little bit of credit
that we even got a final ruledone, because, you know, we have
something like upwards of 5000banks and the UK and the EU have
a significant fraction of that.
But the UK, you know the UK hasa similar framework that is
called that's under thefinancial conduct authority and
competition markets regulator,and so these things have been

(07:08):
happening in parallel.
What has taken us so long here,right apart from the fact that
we have a significant number ofbanks in our jurisdiction, we
have thousands of banks andhundreds of fintechs based in
the us of banks and hundreds offintechs based in the US I think

(07:29):
part of the reason is just ourframework is different.
Some people look to Dodd-FrankSection 1033, as the basis for
open banking.
I think a lot of banks wouldtake issue with that.
They would say, well, 1033really wasn't just about open
banking.
It was really more about howyou share data with consumers.
So where do we land on?

(07:50):
This Terminology is different.
Concepts and principles mightbe the same.
We are where we are in theUnited States and then query how
far are we?
Because, of course, 1033, theday that it was announced, the
day that former directorRoetropa gave a speech at Philly
FinTech that same afternoon.
There was a lawsuit, so I'llpause there.

Rachel Morrissey (08:23):
And I've said a lot, but I'm glad that you
differentiated that, becauseopen finance is about a much
different picture than openbanking is, and the other part
about the vastness of theAmerican market.
As far as banks go.
You said 5,000, and there were5,000 banks, but there's over

(08:49):
10,000 depository institutionsin the United States.
There's like 180 plus in the UKand across Europe.
It's far less than the systemin the US, and then the
differentiation between thoseinstitutions is even greater.

(09:12):
The array of the types ofinstitutions there are that
would need to be participants orcould be participants in open
banking is really different.
One thing we've always talkedabout is that the US took a very
market-driven approach, so itwasn't as if Rule 1033 made it,

(09:36):
so open banking was suddenly athrust upon everybody.
There's plenty of Americanorganizations that have
implemented APIs in theinfrastructure for open banking,
but it's just now we have thisframework that is being
challenged and I'm really Iappreciate that you've set that

(09:59):
up.
So, if we focus in on what theCFPB has decided, you know when
they closed Rule 1033, they cameto our show immediately after
the Philly FinTech one.
I think the Philly FinTech wasTuesday, and then they were on
our stages on Sunday put in and,you know, filed, and there was

(10:31):
already discussion about thenature of what was going to
happen there, and so it allhappened very fast.
So if we look back at theCFPB's process, I think we can
look a little bit about theproposed rule and that process
towards the end where thefinalized rule, and when they
closed their proposed rule,before they reviewed them, they

(10:55):
had 11,000 submissionsrepresenting all the different
aspects of the financialservices industry.
Many other stakeholder groupshad also submitted and I'm sure
you reviewed your fair share ofthe comments.
So where did you find to be thegeneral themes?
What were the general themes ofthe comments, and were there

(11:17):
any surprises on theperspectives that you didn't
expect to see?

Alexandra Barrage (11:23):
Yeah.
So look, I love really readingcomment letters.
I'm a big nerd, but I alsothink comment letters are a
really unique window into theindustry and a voice that you
don't hear unless you read them.
I mean, you can read speechesfrom regulators, but it's really
not the same.
Comment letters in general gointo a lot more depth because

(11:44):
the best ones are reactingspecifically to questions raised
by any regulator.
So there's some rigor to theprocess around comment letters,
I think, if you're doing itcorrectly.
Anyway, so I didn't read all11,000 letters, to be fair, but
I'll tell you I think I have aunique.
No, I hope hopefully the oneperson didn't have to do that.

(12:07):
Clearly, there's a lot ofrepetition and we'll talk about
how they look thematically andI'll tell you, as a banking
lawyer, a few of the things thatreally stood out for me that
are still real.
Issue that I actually thinkwhoever takes over at the at the
CFPB and I assume that will beJonathan McKernan over at the

(12:28):
CFPB, and I assume that will beJonathan McKernan this will be
an area of focus.
So I think a lot of the issuesthat I remember reading were
ones that I had anticipated justafter reading the proposal.
I'll focus on two issues.
One really interesting issuethat comes out in a few of the

(12:49):
letters and some of theregulatory statements is this
idea of consumer choice, right.
So one of the themes of thiswhole effort around open banking
is for consumers to be able topre-permission the data sharing
and, to quote, be able to breakup with their bank the data
sharing and, to quote, be ableto break up with their bank,

(13:11):
right.
And that's, from a consumerchoice perspective, a really
compelling idea.
But there's another side tothat idea of consumer choice if
you're a bank, right.
And so just remember back toSVB and those failures.
Just remember back to SVB andthose failures.
And when we think about howsticky deposits really are, we

(13:33):
have these rules.
One of them is called LCR.
We have other liquidity-basedrules that basically try to help
banks manage their liquidityrisk in all these different
scenarios, and they have certainoutflow assumptions they need
to make.
And you know, post SVB, theseassumptions around who's going
to leave the bank and howquickly can they leave were

(13:56):
really turned on their heads,right, because we saw massive
deposit flight on a single day,something upwards of like I
forget, I think it was like 40billion, it was maybe 45, 60.
I can't remember the number.
I think it was like 40 billion.
It was maybe 45, 60.
I can't remember the number.
If you have a framework that notonly envisions that but
encourages, you know, customersgoing to the bank that makes the

(14:19):
most sense for theirrelationship, easily Right
Pre-permission what does thatmean for deposit stickiness?
What does that mean for bankswho are going to have to
navigate the liquidity risks inthat world?
That's not really a comment on1033.
That's a broader comment on howare banks going to adapt to

(14:41):
this.
You can imagine an AI agentbasically being programmed by a
customer who say look, if thebank within a 50 mile radius of
my house has a yield of X plusin certain number of basis
points that I pre-permission thesharing of my customer data and
the movement of my account thebank doesn't know anything about

(15:03):
that, but that's the worldwe're headed into, this world of
driverless money, and so Ithink one of the interesting
takeaways from 1033 is how arebanks going to manage that?
There's a lot of stuff in theletters around increased account

(15:23):
portability and making iteasier for customers to move to
different relationships,including involving fintechs,
and so I think that's just areally interesting issue to
think about In terms of the realsubstantive issue that you saw
across many of these commaletters.

(15:44):
It comes down to liability andconcerns that the proposal and
frankly, also the final rule,which didn't really differ too
much in this regard that itdoesn't appropriately address
allocation of liability amongthe different participants in
the event there's fraud orbreach or stolen credentials and

(16:06):
banks are on record about beingvery concerned about this right
In each of these you know casesof bad actors.
Whether you're a data provideror you're a third party or
you're a data aggregator, youstill would be required to
comply with whatever respectivelegal obligations you have under
state and federal law If you'rea data provider.
If you're a data provider, thatwould likely include regulation

(16:30):
E and Z.
But it's less clear for banksexactly where the liability
begins and ends, and that lackof clarity is, I think, one of
the key reasons so many bankswere against this proposal and,
of course, ultimately they woundup litigating it within hours

(16:52):
of its issuance.
So if I were to pick one thingthat I expected and that is
common, it is this liability thelack of granular detail on how
the liability gets apportionedacross this broad ecosystem.

Phil Goldfeder (17:13):
So I love that you said that when you started
to answer to this question.
In terms of open banking, CFPB'sproposal per the director at
the time was really aboutconsumer choice and portability
and making sure you're buildinga lot of competition into the
market.
I think you know, obviouslythere was a lot of differing
opinions on sort of the best wayto do it and there's a bit of

(17:36):
uncertainty, but I think whatwas fascinating was the pace at
which the response came and, asRachel mentioned earlier, I
happened to have been at thePhilly Fed when it all went down
, I think, as many of us were,but that Sunday Director Chopra
was actually at Money 2020.

(17:56):
And again, same day as CFPBissued the rule, BPI and the
Kentucky Bankers Associationfiled suit, the director was
asked on the stage was what doyou think about the lawsuit?
And I think his direct quotewas I haven't read their lawsuit
and they clearly haven't readmy rule, and so obviously

(18:16):
there's a lot of gamesmanshipwhere, you know, the American
FinTech Council is a tradeassociation as well, and so we
look at various rules and how itimpacts our members and you
know, obviously you know legaloption is always an option in
terms of how do you combat tobest protect your members and,
most importantly, protect theirconsumers?
How do you think and I knowwe're going to get into the
politics how do you think thelitigation potentially impacts

(18:41):
sort of what the ultimate resultis with 1033 and open banking?

Alexandra Barrage (18:47):
I think the litigation is a very clear
marker for where a huge swath ofthis industry is right the
banks, especially the largestbanks and I think it's an
important marker.
I think, personally, there'vebeen a number of instances in
the prior administration wherethe CFPB acted outside of its

(19:09):
jurisdiction.
That said, I think 1033, in thespirit of 1033, is correct.
I'm not, don't misunderstand.
I think it's a really importantdevelopment and so to me, the
lawsuit was like the line in thesand.
We wrote about it, we sent youcomment letters about it, we

(19:30):
really, really mean it andfrankly, I'm sympathetic to the
bank's arguments and I thinkthat where this should land and
where I hope it lands under, Iassume, future director McKernan
is that you know we take a stepback.
We ask ourselves what, withinthis rule, was in that CFPB

(19:51):
statutory authority, and that'sgoing to be done across the
board, not just with 1033.
We engage with the banks ontheir liability issues, and
that's just one issue.
There are other issues, but tome that is like probably the
biggest one that impacts themost number of.
That is like probably thebiggest one that impacts the
most number of entities in this,in this ecosystem, and we we
get smarter about how toapportion it and we have more

(20:16):
engagement on it, and I'mhopeful that with that
engagement and new leadership wewill get there.
Would we have gotten there inthe absence of a lawsuit?
I don't know, maybe, but youknow, that's a really important
process that lays out all theconcerns and all the arguments
in a different way and, um, atthe same time, I think, is an

(20:40):
opportunity to have a newconversation with a new
administration about theconcerns.
So, um, that's as much as I canimagine, kind of where we're
sitting today.
I don't think 1033 is goingaway.
There's too much in it.
That's actually, I think, good,but some stuff that needs some

(21:01):
calibration, I think.

Rachel Morrissey (21:04):
So I'm curious about this a little bit,
because I totally understand thesympathy with the banks and
what the bank's position is.
At the same time, I don't feellike the CFPB acted rashly or
acted overly fast.
They took quite a bit of timeto consider this and they did

(21:26):
pull in a lot.
So I'm curious.
Pull in a lot, so I'm curious.

(21:55):
I haven't seen that be a bigfactor in the realities.
As these things were implementedin other countries, as they
took on rules the UK, forexample they made their rule.
It only ended up applying totheir nine biggest institutions

(22:16):
you didn't see a lot of accountmovement between the banks
because there was, frankly, nota lot of differentiation or
market differentiation betweenthe ones that it was implemented
in, between the ones that itwas implemented in, and so this

(22:36):
idea that bank choice leads tothis flurry of movement there's
not a lot of examples of it inthe reality.
Theoretically, it definitelyallows for it.
I've never seen it happen inany of the markets where it's
been implemented.
So I'm curious about that aswell.

(22:58):
What do you think that?
How much of this is the banksfighting against something
theoretical or something thatthey just feel is loosey-goosey,
for lack of a better legal termand how much of it is based in
something else.
And what do you think from 1033should stand?

Alexandra Barrage (23:26):
Sure, those are great.
Let me take them in order.
I think in general, therewasn't a whole lot of change
between the proposed and thefinal, with a few exceptions
that I think are worth changing.
Definitely, the CFPB heard theindustry on having longer
implementation timeframes.
That should absolutely be kept,especially for some of the

(23:48):
smaller banks that frankly,don't have or haven't had the
resources to implement what theywill need to, and there's also
a threshold that was put intothe final rule.
So it's not as if the CFPBdidn't hear comments and react.
I don't mean to suggest that.
I also agree with you that onthe concept of bank choice, even

(24:10):
though that was the tagline inthe release, it hasn't borne out
, at least historically.
However, I think we also needto be thinking about money
movement in a much more futurestate world where we have AI,
where we have the technologythat basically facilitates that

(24:30):
movement a lot easier, like inSVB.
It almost seems likeprehistoric, but we had apps
that allowed people to do thisvery easily.
Those apps are going to looklike ancient compared to what I
think we're going to see justover the next three to five
years, and it's going to be aworld where you don't actually,
as a human being, have to do itat the time.

(24:52):
You just pre-program some otherapp or AI agent or whatever to
do it for you upon certainconditions, and so maybe that's
the reason we haven't reallyseen the money movement.
Or it could just be people havebeen happy with their banks and
there's been so much competitionthat there would be no reason
to leave one bank for another.
That's that's an entirelyplausible, you know, reason for

(25:17):
why we haven't seen that moneymovement.
So I think that I would say thejury is out on that.
Let's see how tech developsover the next several years and
revisit your question years.
And revisit your question maybeon a future podcast, because I
think that that will change andthe pace of that change is

(25:40):
really hard for me to predict,so I don't know how much time.

Phil Goldfeder (25:41):
I think we have a few minutes left, but I think,
we would be remiss if we didn'tjump, maybe, into the.
Obviously there's been a hugepolitical shift since the rule
was finalized.
So you talked for a bit aboutthe court case.
But what does thisadministration do?
I mean there's been a hugepolitical shift since the rule
was finalized, so you talked fora bit about the court case.
But what does thisadministration do?
I mean there's a lot of talkabout rules that are getting
Congressional Review Act, cra,and sort of.
There's a conversation in bothhouses of, in both sides of that

(26:04):
of Congress and the House andthe Senate, about sort of what
to do with this one and how tomanage it.
What do you think happens andhow do you think that plays out?

Alexandra Barrage (26:14):
Yeah.
So this is a hard one becauseyou know we don't want to get
ahead of leadership that hasn'tbeen confirmed yet, so it's
going to take a couple ofassumptions, but but I'm going
to assume, as I said earlier,jonathan McKernan will have the
votes to be confirmed.
I worked with Jonathan a littlebit and I think he's going to

(26:36):
be a terrific leader for theCFPB.
He's very focused on makingsure agencies act within their
statutory authority.
That certainly was the casewhen he was a member of the
board at the FDIC.
I don't know what his policypriorities are going to be or
what the agenda will be once hesteps in, but, knowing a little

(26:58):
bit about him, I think he willfirst look at every rule,
including 1033, and look at, youknow, is there statutory
authority for the CFPP to dothis?
And second, is this rule reallyreflective of what we started
out with?
Is this really open banking ordoes this rule just fail to

(27:22):
address some critical elementsaround liability and security?
Does it?
Does it fall short, maybe, ofother models that have been
successful in otherjurisdictions?
How about we think about that?
So I I know a lot of folksthink that the CFPB is going to
do absolutely nothing that theCFPB and its new leadership will

(27:54):
take a close look at, kind ofwhere we are current state on
this rule and whether there is apath to get large swaths of the
industry, primarily banks, onboard.
If that's the direction theCFPB takes, kind of an openness
to rethinking the rule, thatwill involve a lot of

(28:14):
stakeholder dialogue and timeand we might see a reproposal of
the rule in that instance.
But alternatively maybe it goesnowhere.
I think I'm more hopeful thannot that we'll have some new
version of it.
But again, don't hold me tothat.
That's just.
Those are my own thoughts.

Rachel Morrissey (28:37):
Fair enough.
Okay, there was one thing thatI was thinking about here.
With the new administration inthe future of the CFPB has been
put into question a lot.
They have the new leader comingin.
You've already said you'repretty hopeful.

(28:57):
Do you think that that centerwill hold?
Is, I guess, what I'm asking.

Alexandra Barrage (29:08):
I think the focus of the CFPB will be on
looking at rules, either gettingrid of them or fine-tuning them
.
I think whoever the rulewriters are the CFPB
historically that stuff theywill be really important to
whatever version of the CFPBwill occur.
Enforcement and supervision isnot as important in this new

(29:34):
CFPB.
That's not to say they'reunimportant.
I just don't see the emphasisthere, and we've already seen a
number of instances whereenforcement actions have either
been withdrawn or dropped.
Not even speaking about otherregulators, just talking
specifically to the CFPB.
So those are the signs that I'mreading Regulators just talking
specifically to the CFPB.
So those are the signs that I'mreading.
If I'm right that rulemakingand rule revisiting will be a

(30:02):
priority, then then we may seesome movement here.

Rachel Morrissey (30:06):
It's just there's so many questions and
they range from all the way fromquite I don't.
I don't want to reallycharacterize them as hopeful or
not hopeful, because a lot ofpeople have a lot of different
hopes for a lot of differentoutcomes, but they're very wide

(30:29):
in their perspective of whatthey hope happens and everything
seems to be on the table.

Alexandra Barrage (30:34):
Yeah, there's another element to your
question.
I'm sorry, I didn't mean tointerrupt you.
Your question just reminded meof something really important,
which is that we can think aboutthe CFPB just as its own thing,
or we can step back and thinkabout consumer regulation in the
patchwork of states and theCFPB right and in a world where

(30:56):
the CFPB does nothing andthere's a void.
We're already seeing stateslike going full steam ahead on
earned wage access.
I mean, phil's the expert onthat.
That principle, that dynamic,is not limited to ewa, nor is it
limited to opting out ofdinmica or all these other
things the states have been, youknow, doing so it's a whole

(31:20):
nother podcast we, it's a wholepodcast.
but the point is like, if thecfpb does absolutely nothing,
which is not my view of theworld or my hope for the CFPB we
have much bigger problems.

Phil Goldfeder (31:36):
I absolutely agree.
In the absence or perceivedabsence of regulatory structure
at the federal level, you'regoing to find banking regulators
and state attorneys general whoare going to step in to try and
fill that void as aggressivelyas they determine they need to
for their one specific state,which is going to put the
industry in a whole differentlevel of turmoil.

Rachel Morrissey (31:55):
I guess that's actually what I was getting at
is.
I was like I was wondering,like, because there is so much
question around the nature ofthe CFPB itself and the nature
of federal versus state, thenature of federal versus state,

(32:16):
I just I'm really curious as towhere this is going to go and
where the industry is going toactually prefer the, or will
they actually prefer the clarityof one, whether they like all
of the constraints or not, orwill they prefer the other side,
which has a lot less claritybut perhaps has a lot more
leeway state to state?
And so you just yeah, phil isshaking his head at me like

(32:39):
going no, they want clarity.
And I'm like, okay, fair enough.

Alexandra Barrage (32:45):
I agree with Phil Fair enough.
You want to build, you want toscale.
You need to know what the rulesof the road are.
You need to know that they'reof the road are.
You need to know that they'rethe same well.

Rachel Morrissey (32:52):
Thank you so much for joining us on the
podcast today.
That's all the time that wehave.
It's my pleasure, it's a lot offun it looks like we're gonna
have to have like three more uhto really dig into all of the
different elements that we endedup and all the questions we
ended up asking here.
Um, so I really appreciate youjoining us and, phil, we're so
glad that you were able toco-host with me.

(33:13):
I appreciate it.

Phil Goldfeder (33:14):
Are you kidding?
We're just forever grateful forour partnership with Money 2020
and you, rachel, so thank you.

Rachel Morrissey (33:21):
We're so glad to have you guys.
So that's it for this episodeof the Money Pod.
Please go ahead and find uswherever you listen to your
podcasts.
Please leave us a review.
It helps other people find us,and we look forward to
continuing these conversationsin the next short while.
Have a great one.