Nov 18, 2021

By  John Heltman November 17, 2021 9:30 PM 32 Min Read Below is a lightly edited transcript of the podcast: HELTMAN: Alright here I am at the Money 20/20 conference in Las Vegas, Nevada. And I'm walking on the expo floor. There are many people here wearing masks. That's good. And a lot of companies here so looking around, I'm seeing something called Trustly, there's something called DriveWealth. Facefi, Cardtronics, Array, Callsign, unlim ... Unlimint. It's like a tech ... fintech paradise here. HELTMAN: Financial technology companies, or fintechs, have been around for a long time, and they do all sorts of different things. Some of those things are essentially providing services that banks can employ — hosting back-end services like customer onboarding or AI services for risk management, for example. But as I walked around the floor of the Money 20/20 conference last month, it seemed like a lot of these businesses were geared toward providing financial services directly to customers — and specifically low- and moderate-income customers. HELTMAN: What is DailyPay? DAILYPAY : DailyPay is an on demand pay provider. So have you Are you familiar with on demand pay? HELTMAN: Is this like earned wage access? DAILYPAY: Yes, essentially that that is the thing. So you typically get paid every two weeks or maybe once a month. But you've earned that pay, it just hasn't arrived in your bank account. So what DailyPay does is we partner with employers in order to make your pay available as you earn it. HELTMAN: Who's this for? I mean, what kind of consumers you think would best benefit from something like DailyPay? DAILYPAY: It's it's actually for primarily hourly workers and for those who are just starting out, maybe on a salary scale. It's a, it's about people who are juggling their budgeting and, and, and their finances and need this in order to manage their household. DRIVEWEALTH : Drivewealth is an API-based global brokerage infrastructure. So we work with over 100 different partners around the globe, from fintechs, to large brands, neobanks, super things like that, to embed our technology into their existing apps so that their customers can benefit from fractional investing. So instead of buying a whole share of Starbucks, they can buy $1. So we're really working to democratize investing globally, because, you know, investing in a share of Amazon can be a lot, you know, not everyone has $3,000, ready to invest. But now we're making it really easy to enter into the investing ecosystem, through our technology. TRUST SCIENCE : We're Trust Science. So we go by Credit Bureau 2.0. We help the, the lenders find what we call the invisible primes. So, the conventional credit bureaus are scoring people, often wrongly for the scores below 700, approximately 35 to 40% of those scores below 700 would actually be prime and super prime borrowers above 700. If you could act, you know, properly evaluate these people, and by these people, I mean young people, or immigrants, or self employed people and so on. And that's our expertise, we find that the invisible primes. HELTMAN: All of these companies and many others are using technology specifically to provide services to the sizeable portion of Americans who are unserved or underserved by the traditional financial system — people with lower incomes who might not qualify for affordable credit from banks or credit unions. That’s a noble goal, because, as James Baldwin famously observed , it is extremely expensive to be poor. But it is also true that lower-income Americans by definition have lower incomes, and that means they pose greater credit risks, at least in the aggregate. So are these claims legit? Have fintechs cracked some kind of code that makes them better able to provide the services lower-income households need? And if they have, can banks do the same thing — or should they? From American Banker, I’m John Heltman, and this is Bankshot, a podcast about banks, finance, and the world we live in. JENNIFER TESCHER: I just have to say, as someone who like you, like talks to a lot of people and gets interviewed or interviews, people, it's so refreshing to have a conversation with someone who's actually like, you know, thinking about something and has a thesis and an idea. As opposed to just, "Which is better, fintechs or banks?" HELTMAN: Yeah, right. Right. That's, that's the Bankshot difference. You know, like we ... TESCHER: There you go. TESCHER: I'm Jennifer Tescher. I'm the founder and CEO of the financial health network. HELTMAN: The Financial Health Network is a nonprofit group whose mission is to improve people’s financial health. And for many working people, financial health is not a straightforward thing to attain. TESCHER: We all kind of want the same things in life, right. And the way we think about financial health is having a day to day system that enables you to build resilience and pursue opportunity. Those are things we all need, we all need to be resilient in the face of challenge. And we all need the the capital and the systems behind us to be able to take risks in good times. If the pandemic has demonstrated anything, it's that the majority of Americans aren't set up to be financially healthy. And the pandemic has, in some cases made that even make people's financial health even more precarious. HELTMAN: Not having a lot of money in and of itself isn’t necessarily a problem if you can still make your rent and put food on the table and have some left over. But low- and moderate-income households are susceptible to a whole range of financial difficulties when the landlord raises the rent, prices go up, hours get cut, someone gets sick, the car breaks down, or any other unforeseen expenses or circumstances arise. And this lack of financial resilience isn’t even necessarily confined to what we might think of an low- or moderate-income households. TESCHER: Our research demonstrates that there are plenty of people making over $100,000 a year who are in financially precarious positions. And there are some people who are making less than $30,000 a year who actually have excellent financial health. And so income is just not enough of a scalpel. And when we are trying to understand people's real financial lives, we have to get beyond the headline numbers. And we have to get beyond averages and annuals. So as an example, think about a family who if you looked at their tax return for the year, they'd be making about $52,000, that's about the median income in this country, a little shy. But if you looked at their, at their pay stubs, at at their cash flow over the course of a given month, you would see that they have lots of spikes and dips, both in the amount of income they're bringing in. And in their expenses. There's this myth that you know, expenses are largely fixed. That's not true. And their income is increasingly volatile. As people work multiple jobs, as people participate in the gig economy where there's not a set paycheck, as people are filling in with self employment. And income, volatility is increasing for everybody. It's not just a low income persons’ phenomenon. HELTMAN: But while financial resilience is not exclusively a low-income problem, financial access — that is, access to basic services like check cashing, money transfers and credit — tends to be something that low-income consumers lack. And that in many ways is because of choices that banks make about who to offer services to and under what terms. TERRY FRIEDLINE: I think, banks and financial institutions, set the terms in such a way that it is really expensive to do something that that seems even simple or for if it's, it's something that we already have access to, we probably take for granted. HELTMAN: This is Terry Friedline. FRIEDLINE: I'm Terry Friedline. I'm an Associate Professor of Social Work at the University of Michigan. And so my research areas in banking and finance broadly how how people get access to banking and finance, how the institutions, like banks, and lenders and fintech companies kind of create barriers that prevent people from accessing the things that they need to have, like dignified participation in our current economy. HELTMAN: According to the FDIC, there were roughly 7.1 million households in the United States that have no bank account in 2019 — that accounted for roughly 5% of all households. The FDIC conducts that survey every two years, and the number of unbanked households has been declining steadily over the last decade or so. That may not seem like good news, but keep in mind that those numbers are derived from surveys conducted by the Census Bureau, and surveys are by definition inexact — the true number could be higher. And the number one reason unbanked households give for not having a bank account is an inability to maintain a minimum balance or pay required fees. There are also millions more underbanked households — that is, households that perhaps have a checking account but also rely on check cashers, payday lenders and other nonbanks for financial services. The FDIC’s 2017 survey estimated that another 24 million households — or 18.5% of the population — fell into this category. FRIEDLINE: So you mentioned kind of the banked and underbanked, which is, you know, generally defined as having access to a checking account or some form of bank account. And, and that ends up to be really costly. So, so banks, make those expensive for folks. And so when we think of like the low- to moderate-income group, you know, that can't pay the costs, and the fees that are that are set for those products means that you have to like patch together, right kind of piecemeal, your your financial life in ways that can be really difficult. And, and I'll say that, like the low to moderate income group is most of the United States, right? So that's, that's a pretty significant chunk of our population in this country, given you know how income and wages have have stagnated over time. HELTMAN: All of this is to say there’s a pretty significant need for financial services among a significant segment of the population, and those needs are currently being met through services that are more costly and less favorable than what banks routinely offer qualified customers. And there are many different barriers to becoming a qualified bank customer — to getting the kinds of favorable interest rates and low-cost services that many of us take for granted. One of those barriers is just physical proximity to a bank. The number of bank branches per capita has been declining pretty steadily since the 2008 financial crisis, but those branches are disappearing most rapidly in rural areas and low-income neighborhoods in major cities. In cold economic terms there’s a logic to that pattern: if more people are doing their banking without a branch and you need to close branches, you’ll start with the ones that are least profitable. But just because a bank moves out doesn’t mean the need for financial services goes away. FRIEDLINE: So an example of this might be in rural Alabama. So rural Alabama, in particular counties, you know, have pretty high percentages of black populations in the rural south, and in some of these counties, some of these communities, saw pretty large decreases in their bank branch population, and their, you know, bank branch kind of density over the last 10 years. So, you know, banks were closing their branches, presumably not profitable. But But payday lenders and check cashers were, you know, being retained in those same places, and even expanding, you know, increasing their physical storefronts. And so, and so that dynamic suggests that it's not that there's not profit there. But its profit that can be had in a way that I think can be exploitative. TESCHER: I think the biggest reason for that in terms of the incumbent institutions, we tend to think of as the financial system, right, banks and credit unions, their business model is such that they make more money when their customers have more money. I mean, it's that simple. Think about just the basic checking account. The basic checking account is predicated on the customer having a balance. So when you walk into the bank with a paycheck, and you want to cash that check, they're not really cashing that check, they're gonna give you essentially, what's available in your account right then and there. So you if you only have $100 in your account, but the check is for $500, they're only going to give you $100. And then they're going to wait a day or two, for that check to clear. So it's predicated on slack. And as we know, the majority of Americans don't have slack. So even just the basic banking account, and then we can certainly talk about the credit side of the house — banks make money between, you know, the spread, between what they charge for loans and, and what they pay people to keep their money in the bank. And we all know the challenges that lots of people have, either without ... who don't have any credit score, or whose credit isn't pristine. And traditional financial institutions have historically had a very hard time filling that need. HELTMAN: So there’s a need here that traditional finance isn’t meeting. And a lot of fintechs, as we saw earlier, see potential in meeting those needs and have actually been meeting this market for a while. DAN HENRY: So I'm Dan Henry, CEO of Green Dot. HELTMAN: And what's Green Dot? HENRY: Green Dot is a pioneer in the fintech space brand that's been in business for 20 years, we have served over 30 million customers, we really are the pioneer, if you will, of prepaid card space in the United States, and really the first to, to kind of to break the industry to provide an alternative to traditional bank accounts for the consumers here in the U.S. HELTMAN: Green Dot’s approach to offering services to lower-income consumers relies on reducing their overhead costs and making up for lower margins with higher volumes. So in other words, the profitability of any one Green Dot customer is relatively low, but if you have a large customer base, those small profits add up to an attractive business model. And they keep their overhead down by not having branches. HENRY: So through our partners such as WalMart, Walgreens, CVS, 7-11, Family Dollar, Dollar General, we distribute not only our, our, our plastic cards, but through those 90,000 locations, we have the Green Dot network. So customers can add those 90,000 retail locations, they can load or deposit cash into their Green Dot accounts. Or they can come in those locations and pull cash off of their accounts. We have more locations and all the bank branches in America combined. But we don't have the overhead of carrying those locations. So you think about the advantages that we have to serve the low- to moderate-income consumer, they come from the standpoint of initially, we don't have a large cost structure that we have to support. And we're focused on serving a customer who does not have access funds — So we don't ... our business model isn't about taking deposits and making loans. Our business model is about helping that consumer with a transaction device to be able to that they can get paid quickly, reliably, they can then pay their bills easily. They can have access to some short term credit if they need it. And that's that's our, our business. HELTMAN: And that kind of agility is being applied to other barriers facing lower-income consumers as well. Consumer credit reports have been a mainstay of credit risk for decades, and they famously track and weight certain kinds of payments over others. So if you pay your car loan or your mortgage on time every time, that leads you to having a great credit score and access to more credit. But if you pay your phone bill or rent every time on time, it doesn’t necessarily build your credit in the same way. JOSEPH BAYEN: The problem with those consumers who have a hard time getting access to credit, they are using debit cards, you know, and card to pay for the subscriptions, and debit cards don't do any credit. So what we're doing, we're basically enabling them to basically leverage their existing, you know, multi subscription payments to essentially up, you know, turn and turn them into a credit building opportunity. HELTMAN: This is Joe Bayen. BAYEN: Yes, my name is Joe Bayen, and I'm the CEO and founder at grow credit. We are a financial inclusion platform, we recently raised $106 million to expand nationwide, you know, we offer a limited usage, MasterCard, that is restricted to paying subscriptions, and cell phone bills. HELTMAN: GrowCredit is kind of like a widget that latches onto people’s existing buying patterns and helps build credit without putting them or the company at any significant risk of loss. So if you have a Netflix account and you pay that $17 bill every month, you can sign up with GrowCredit and they will extend you a line of credit for Netflix — $204 per year. Your bill comes due, they pay Netflix, and you pay them. Everything is the same, except the consumer’s credit improves. BAYEN: Consumers with no credit whatsoever, you know, ended up with scores ranging from 620 to 719 over a nine month span. Basically the platform is effective, and it's delivering on the mission of helping consumers become credit visible in the United States. HELTMAN: And like Green Dot, they make a profit from this service through volume. Each transaction brings a small transaction fee to them, much the way Visa or Mastercard charge a service fee when you use their networks to settle payments. And they also offer the consumer more credit to cover higher-ticket subscriptions for a small fee — so instead of your Netflix account, you can also pay your cell phone bill through the same mechanism, giving your credit report that much more positive payment history. And fintechs are finding ways to meet the needs of other corners of the market that banks and credit unions have historically neglected, including small business lending. Building a business is one of the main ways people develop wealth and financial independence, and historically banks have had a hard time offering loans that smaller companies can really use. KATHRYN PETRALIA: Historically, banks have focused on larger businesses — not because they're bad people, they just can't they don't have the tools and the technology to automate that process. And it costs as much money for them to make a $50,000 loan as it does a $5 million loan, because it's all manual. So they focus on the $5 million loans. And small businesses are more volatile. They they're, you know, they just are. I'm Katherine Petralia, the co founder of Kabbage. HELTMAN: Kabbage is another name you know — they hung their shingle as a nonbank small business lender in 2011. Banks in many ways see the same problems with lending to small businesses that they see in lending to lower-income consumers: the risks are high and the rewards relatively low. But, as with lower-income consumers, donut shops and plumbers still needs to handle payments and manage payroll and make capital investments. Kabbage found a way to extend credit while managing its risk by tying its loans to a business’ cash flow. PETRALIA: We started Kabbage, because there was this API that was launched by eBay that gave third parties access to seller- and transaction-level data. And my co founder, Rob was like, “Huh, that's really cool data. I wonder if you could use that to make a loan to a small business selling on eBay.” And I mean, at the time, imagine, like 12 years ago, walking into a bank and saying, "Hey, I'm an eBay seller. I sell Pez dispensers, don't you want to make me a small business loan?" Hell no! No one's gonna make that loan. So you know, we didn't start the business to improve on what was already there. We wanted to use this technology to do something interesting and unique and, you know, serve businesses. HELTMAN: So if fintechs are finding ways to use technology, data, lower overhead and agile business models to reach lower-income consumers, why haven’t banks thought of that first? Or if they haven’t thought of it first, why haven’t they just copied those models and done it themselves? More on that after this quick break. HELTMAN: We’ve heard a lot from fintechs about fintechs, but how do banks feel about fintechs? WILLIAMS: I think when early on people said fintech, you know, the banking community was extremely nervous, like, you know, we're gonna, we're gonna lose to the fintechs. HELTMAN: This is Darrin Williams. WILLIAMS: Darrin Williams, CEO, Southern Bancorp. We're now evolving as an industry away from fintechs are taking our customers, our competitors, and some, in some senses, they are competitors. Now you're saying, like fintechs have learned, there's power in the bank charter, right. And you get to have a bank charter, something powerful about that. It's something you can or can't, you can't do without that. And so now, these fintechs are saying, we .. and the banks are saying, “We need a partner.” HELTMAN: Southern Bancorp is a Community Development Financial Institution, or CDFI, whose mission is to serve low- and moderate-income customers that traditional finance has left behind, but it’s also a bank and approaches these problems as a bank. And the reason banks haven’t been able to be as agile as fintechs in thinking through how to reach lower-income customers is because many of them — particularly small banks — are constrained to an extent by their core service providers. WILLIAMS: As a small bank, community bank, you just don't have much leverage with your core processor. There are four or five big legacy processors that really control how banks and So if I want something I call them up. And if I'm, you know, small bank, I wait a year and they call me back. I mean, it's just it's just the model right you get the very limited attention. All these core processors, these legacy processors, are built in an era where there was no internet. They were built ... they're built on IBM mainframes right there. I mean, no matter what they tell you, they're built on old systems. And you're trying to marry that with this open architecture of today's technology. It might seem to work well on the outside, but behind it's kind of held together by duct tape and twine. It just doesn't work. HELTMAN: Southern partnered with Smiley Technologies, Inc. — of which Southern is a minority owner — to build their own core. That decision paid off when Southern wanted to try something new and different, for example when they wanted to create a program for bank employees to get a 12-month no-interest loan against their future earnings. WILLIAMS: It's no underwriting, right, there's no human hand touching that. And we give it 12 months to pay it back. And it's automatically withdrawn from your, from your from your account. So you'll go from having to pay back in two weeks to pay it back in 12 months, or as soon as you want to where you have that access. That's, I could only do that through technology. So now human hand and have to touch that I can replicate that. And I can and that that that's an example, you know, of the positive technology can play. HENRY: There's countless examples of the entrenched player didn't innovate, you know, and didn't didn't change their DNA fast enough, and they missed out on an opportunity. HELTMAN: Blockbuster. HENRY: Yeah. Netflix is one of my favorite companies of how they've been able to, like evolve over time, and stay ahead of things. But there's countless examples of that. But there's also countless examples of well, Netflix is a great example — they evolved. They went from mailing DVDs to streaming. So there's no reason why our established financial institutions shouldn't be able to evolve and compete with quote, unquote, all the new fintechs that are out there. So it's, you know, God bless a free market. So I, the, but because we're moving money, you know, the role for banks and bank regulators is critical. HELTMAN: Part of the reason disrupting finance isn’t as straightforward as disrupting television or taxicabs or newspapers is because everything in the economy depends on an orderly, fair and accountable financial system. That means it requires rules and regulations — and, to some extent, barriers to entry — to ensure that everything is working as it should and is on the level. But is that regulatory oversight keeping banks from engaging in the kinds of innovation that could bring more customers into the financial system and enjoy the convenience and low costs that come with that? JELENA MCWILLIAMS: When you really look at the type of credit that these fintechs are able to provide to these segments of population, you you realize it's actually it's probably some of the cheapest form of credit available to those consumers. And fintechs, you know, you identified some of the reasons that they're able to do so. HELTMAN: This is Jelena McWilliams. MCWILLIAMS: I'm Jelena McWilliams, the 21st, Chairman of the Federal Deposit Insurance Corporation. So these fintechs will look at alternative data, they will use their proprietary algorithms to analyze the the creditworthiness in quotation marks of potential customers, and are able to actually produce the underwriting models that even for unsecured credit, produce a very low loss rate. And so when you look at that, banks are not able to be in that space. And here's why they have regulatory expectations that they will produce good quality credit underwrite … based on the underwriting requirements, and if they want to play in that space, if they would like to go below 620 credit scores, and, and no credit history, etc, etc, they have to substantiate to regulators why that's the case and why they're lost modeling can actually account for potential losses, and they can mitigate that risk. In a lot in a lot of cases, banks are not they don't have the requisite agility. HELTMAN: But if banks lack the requisite agility, bank regulators really lack the requisite agility to determine whether alternative credit assessments or credit products are good for the consumer and safe for the bank. MCWILLIAMS: I will say that the regulators, in particular, our regulatory framework for banks, is not as agile as you would want want it to be, given how quickly the technology develops. So if if a bank is going to be, you know, we're actually issued guidance on alternative data use to basically allow banks ... to give them a green light to play in that space. But it takes two years for a bank to develop a product that they would offer to consumers. And then they want to test it with the regulators and say, Hey, what do you think about this? HELTMAN: Well, you're not the only regulator. MCWILLIAMS: And we're not the only regulator, if it's a large bank, they will also have the CFPB. For a lot of the banks were not the primary supervisor. So a lot of these large banks that really have the resources to develop a new product or service. You know, the big banks that have the money are usually not regulated by the FDIC, we only have a handful of really large banks. And then you're looking at smaller banks, which don't have the resources. And they're not going to spend several hundred thousand dollars to develop a product that the regulars may not look favorably upon. So it's a far more complex ecosystem for banks to succeed in that space, versus the fintechs that are more agile, they don't have the same type of restriction. They're regulated on a state-based ... on a state level. And so yes, we have tried to do a number of things. We have issued guidance on how banks can partner up with fintechs, third party partnerships. We have told bank, we get issued guidance on artificial learning and artificial intelligence and machine learning. But all of these things are, you know, you issue guidance it takes some time for for interagency guidance, it takes six months at least to get it done ... HELTMAN: And its still a guidance. MCWILLIAMS: And it's still a guidance, and you still have to go to a regulator, not for a greenlight really, or permission, but at least a nod, like, Go ahead. And you know, regulators are not even willing to engage frankly, into, you know, what people call sandboxes. You know, give me an opportunity, a test pilot, you know, it just takes takes a while. And so if it takes you two years to develop a product that fintechs can offer in a month, then it's a long time and the efficiency is not there for you as a bank. HELTMAN: It’s also worth noting that just because some fintechs can offer quality services to lower-income consumers doesn’t mean they all do. There have been some spectacular cases of fintechs failing either because of compliance issues, problems with the technology, capitalization or any number of other problems. And even if a fintech is well-capitalized and passes regulatory muster doesn’t mean it’s necessarily good for consumers. This is Jennifer Tescher again. TESCHER: I think a lot of fintechs, particularly on the payment side of the house, the neobanking side of the house, are making money off of interchange. You know, that's an interesting that creates an interesting set of incentives. It's built into what the customer is paying. But, you know, when when and then when a fintech is offering an account for free. They're making money every time you swipe. And so they need you to swipe more. So, you know, I think it's, I think it's particularly business models, particularly challenging for no-credit-oriented fintechs. Now, I think the last thing I'll say is, you know, we went back in the very earliest days of fintech. I've been doing this a long time, before it was even called fintech — 2007, 2008. And then fintech got going on, there was all this, "Oh, my God, they're bad. They're gonna outcompete us." And then there was this era where banks and fintechs realized, "Hey, we need each other. We each do something different. There's real opportunities for interesting partnerships." And that era has passed. And we're now back to the the tension and the fighting, in part because of the valuations and of the customer share and banks starting to feel more threatened by fintechs. And so you hear these arguments about how, “Oh, well, fintechs aren't regulated.” The fact is, most of them are because we regulate in this country, by ... by product. But it is true that as a depository, as a chartered financial institution, you are supervised, and there is a much greater burden. PETRALIA: Jamie Dimon has talked multiple times about you know, the fintechs are gonna eat us alive. HELTMAN: That’s JPMorgan Chase CEO Jamie Dimon that she’s referring to. PETRALIA: And I think that they know that I think their risk that you run, what I will say about FinTech overall I think thirty years from now you're going to look back and say fintechs democratized access to the movement of money. I think it really all boils down to that at the end of the day. And so I think, you know, what you're seeing is banks are losing their connection with the customer, because fintechs are coming in and giving customers what they need when they need it. And banks aren't doing that yet. They just can't. And so what happens is banks run the risk of being utilities. And people think that fintechs are like the wild west from a regulatory perspective, but they're really not. They are licensed, they are have bank partners, they are banks, they're getting big charters. These are all regulated entities, they're just generally doing fewer things than a bank is a bank does a ton of stuff for the regulator for a ton of stuff. And fintechs, you know, move into it with one product, and then they add more products, but they're still controlled and regulated. And I think that's important to note. And that means that they can keep that customer relationship and banks are just utilities, just providing pipes that move money at the end of the day. HELTMAN: But is financial access in and of itself a good thing? In many cases when we talk about financial access, what we’re really talking about is access to debt, and debt can be good or debt can be bad depending on what you get for that debt. Student loans, for example, can put you on a career path that leads to higher earnings and more financial independence — that’s good — or they can not do that, in which case you just have more debt than you had before. Buying a home can be a wise investment, or it can be a nightmare that ends in foreclosure. And debt that can’t be repaid isn’t just bad for consumers, it’s bad for lenders as well. So how do we know that fintechs aren’t either putting consumers or themselves at risk of default? TESCHER: I think what fintechs excel at is being customer-centric. Right? Their entire design process is really focused on what's the customer need? Who is the customer? How can I solve a problem that they have? Forget about what the what my product suite is, right? And some of that's just it's not fintech. It's just we're new. We can we can we can think with a blank slate, I don't have legacy technology, I don't have decades of history, you know, let me start afresh. The fintech community has been particularly good at that. I think, the we have to be careful not to confuse customer centricity in product and experience design, with a focus on outcomes. So it's one thing to say, I've really thought about the customer, when I design with this product, and here's all the ways in which that's, that manifests, it's another to say, oh, and as a result, my product actually helps people more, right, or help them at all. And so, I do think that fintech has wrapped itself in the, in the flag of inclusion, and access, and I would say all of the technology world has done the same. It's all about democratization and access, and we can serve more people. And I would say that that's a yes, but and that we have to interrogate that at the company level at the product and experience level, because not all fintechs are created alike. And they have very different outcomes for customers. So it gets back to financial health as an outcome, and are you designing for that outcome? WILLIAMS: I say all the time, wealthy people have Wealth Advisors, right? It's low wealth, people who actually probably need Wealth Advisors. And so what, what technology is allowing you to do and allowing us to do is to use the tool to provide the financial education and financial services to people at in ways and at times, and in places that are just much much more accessible. And so we believe through, you know, through bots and all these other ... chat, there are a lot of things you can do from a financial education standpoint, again, fintechs are not good or bad, just depends on the intention. So you can use those channels and technology to reach people in positive ways. HENRY: The same technology that basically allows all these financial services that we've taken for granted for years to put it that allows them to all be within reach and affordable now, for the masses — that same technology is what prevents my opinion, bad operators from ever getting out of the gate. So I don't know if you were around however many years ago when the Kardashian card got launched. But in the prepaid space, the Kardashians launched the Kardashian card. And it was met with, “Oh my gosh, this thing has too many fees.” And nobody liked the Kardashians at the time. And so I don't know how much you want to put in there, but ... But I mean, it was in the media for months. They issued 12 cards. HELTMAN: Fact check: It was actually more like 250 cards , but the point stands. HENRY: And that's like eight years ago, 10 years ago, okay. So nowadays, where you rate your Uber driver, and vice versa, Okay? You and consumers are trained to go online and check the reviews. So if you are egregious player, in any industry, especially financial services, I don't think you get out of the gate. Because we now have with technology, you know, word of mouth, spreads at the speed of light. And so if you are taking advantage of a consumer, those consumers get online, they speak up, and you're out of business. HELTMAN: As I was reporting this story, this image popped in my head of a castle with a high wall. Inside the castle are creditworthy borrowers, and for them financial life is straightforward and credit is cheap and readily available. Outside the walls, credit is more expensive and scarce. And the walls of the castle are where they are to protect the castle itself — they are designed to ensure that only creditworthy borrowers are inside the walls even if some creditworthy borrowers are outside. It’s a system designed to protect lenders even if it is not ideal for consumers outside the walls. Fintechs are finding ways to smuggle out some of the services inside the walls to people outside, or help them climb the walls, but the walls are still there, and perhaps it’s worth asking the broader question of how we assign credit and services in the first place. FRIEDLINE: What is the goal, I think, is a good question. And for me, I mean, I want to a fundamental kind of revisioning of what the financial system is, and does and who it works for. And so that's a, that's a long term goal, though, I don't think that, you know, we should have to wait kind of decades and centuries to kind of realize that, given that, I think, you know, we all could benefit from and there are folks now that, that need that revisioning to happen more quickly. And at the same time, I think that there are steps on the path to ... to getting there that we can attend to so if one of the goals is to ensure that everyone who wants one can afford a bank account, then that's a goal that we can work toward, I think through a variety of means. But if that's one of the goals is for everybody who wants a bank account, to be able to have one and afford one, then, you know, banks can lower their costs fintechs can make their products available, the United States Postal Service can offer postal banking, we can offer regulation and policy guidance that that, you know, requires establishes some of these accounts for free, so that the Fed accounts proposal is is on the table. And those are, those are all real steps that I think can happen kind of simultaneously to achieve that goal. And so I think there's always a series of goals that we are working toward, because once once we address kind of one concern, there will be others that arise and so I think that requires us I'm kind of being planful and having foresight and not sitting back once a change has made because we need to pay attention to kind of what new what, what new practices, what new opportunities and what what new potential for discrimination will arise after we've made this change. And then going about the same process again, right with that next step, and working, you know, working across those goals, toward that re-visioning of a financial system that that works, and is built for everybody.