WEBVTT - The OCC’s Michael Hsu on the Big Risks Facing Banking Businesses Right Now

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<v Speaker 1>Hello, and welcome to another episode of the All Thoughts Podcast.

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<v Speaker 1>I'm Tracy Alloway and I'm Joe. Why isn't thal so Joe.

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<v Speaker 2>We've had a busy few months.

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<v Speaker 3>Yeah, we really did. We were all over We crisscrossed

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<v Speaker 3>the country. We did all three coast East Coast California,

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<v Speaker 3>the third coast Texas. We went to California twice. Yep,

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<v Speaker 3>in about three weeks, I think. But we have a

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<v Speaker 3>nice little break now.

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<v Speaker 1>Yes, I for one am grateful to not be living

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<v Speaker 1>out of a suitcase for a while. But our last

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<v Speaker 1>stop in the Whirlwind America tour was in Las Vegas.

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<v Speaker 3>That was so fun. I loved going to Vegas. I

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<v Speaker 3>really loved you. I love Vegas. It was so cool

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<v Speaker 3>that I got the opportunity to join you in Las Vegas.

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<v Speaker 1>Okay, listeners, this is where we're going to get into

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<v Speaker 1>a little bit of an argument.

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<v Speaker 3>But you're going to We're going to hear Odd Lot's

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<v Speaker 3>co host air some dirty laundry.

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<v Speaker 1>The day before, No, the day he was supposed to

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<v Speaker 1>actually fly out to Las Vegas, Joe changed his mind.

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<v Speaker 1>You decided Vegas isn't for.

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<v Speaker 3>You, So, listeners, I love Vegas. It's one of my

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<v Speaker 3>favorite cities in the country. I like playing poker, I

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<v Speaker 3>love the strip, I love the lights, I love the

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<v Speaker 3>water consumption in the desert. I was really excited. And

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<v Speaker 3>then I got to the airport on this really.

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<v Speaker 2>Nice He wasn't feeling it.

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<v Speaker 3>No, it's not true. I got to the airport on

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<v Speaker 3>this really nice fall day, and about thirty minutes after

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<v Speaker 3>I got to the airport, my flight was pushed back

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<v Speaker 3>about five hours. And I was only going to be

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<v Speaker 3>in Vegas for twenty four hours as it was. And

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<v Speaker 3>I wasn't even sure that the flight was going to

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<v Speaker 3>take off when they said because actually who was the

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<v Speaker 3>second delay at the time. And I did have family

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<v Speaker 3>in town, which is also true, and Terracy was already

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<v Speaker 3>out there, and Racy is a very capable co host,

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<v Speaker 3>more than capable co host. Like a lot of excuse Joe,

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<v Speaker 3>and I said, please, Tracy, can you just do this?

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<v Speaker 3>Can you just do me a solid and do this

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<v Speaker 3>episode by yourself and Tracy without any complaint or frustration.

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<v Speaker 2>Well, at the time, I didn't complain.

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<v Speaker 1>I complained when I came.

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<v Speaker 3>No making me feel bad about myself obliged.

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<v Speaker 1>Let me just say the world's smallest microscope would not

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<v Speaker 1>be able to locate my sympathy for this argument. You

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<v Speaker 1>know what, No, Okay, let's leave it there. I just

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<v Speaker 1>never okay, listeners, let me say though, that you are

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<v Speaker 1>in for a treat, as is Joe, because he wasn't there,

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<v Speaker 1>so this is the first time he's going to hear

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<v Speaker 1>this interview. But we spoke, or I spoke with Michael Sue,

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<v Speaker 1>the Acting Comptroller of the Currency, and we had a

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<v Speaker 1>really interesting conversation. This was a live episode recorded on

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<v Speaker 1>stage at Money twenty twenty, which you might know as

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<v Speaker 1>the big sort of fintech gathering, and we talked a

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<v Speaker 1>lot about the intersection between banking and technology and Joe.

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<v Speaker 1>Here's where it gets kind of odd, lotsy. Michael has

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<v Speaker 1>been arguing for a while that a lot of what's

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<v Speaker 1>happening in banking right now, and particularly in payments, kind

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<v Speaker 1>of looks like a supply chain. So a lot of

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<v Speaker 1>banks are outsourcing different functions like payments to third party vendors,

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<v Speaker 1>and this presents a bunch of new and interesting problems

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<v Speaker 1>and risks and I guess also opportunities.

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<v Speaker 3>It's so interesting to think about finance in this realm,

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<v Speaker 3>and you can imagine how these things go in cycles,

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<v Speaker 3>because you could imagine at some point these functions were

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<v Speaker 3>very simple. It was all in how it's vertically horizontally

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<v Speaker 3>integrated and so forth. And then, like many other areas

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<v Speaker 3>of the economy, companies realized, okay, wait, what if we

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<v Speaker 3>have one specialty. Other companies then specialize in this specific thing.

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<v Speaker 3>I remember we did that episode about community banks and

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<v Speaker 3>how they had to outsource a lot of their own

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<v Speaker 3>functions about cybersecurity and so forth because they don't have

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<v Speaker 3>maybe the capacity of a JP Morgan. So it is

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<v Speaker 3>interesting to think about, like the supply chain of money

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<v Speaker 3>in that.

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<v Speaker 1>Rest Well, this is exactly it. So in one respect,

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<v Speaker 1>it's a sort of natural evolution of the economy. Everyone

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<v Speaker 1>becomes more specialized, everyone becomes more efficient, the business model

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<v Speaker 1>becomes more streamlined. But as Michael points out, there are

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<v Speaker 1>these sort of new problems that are potentially thrown up

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<v Speaker 1>by everyone outsourcing kind of critical functions in some respects. So,

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<v Speaker 1>without further ado, take a listen to this live episode

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<v Speaker 1>with Michael Sue recorded in Las Vegas, Sans Joe at

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<v Speaker 1>Money twenty twenty. Michael Sue, acting Controller of the OCC.

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<v Speaker 1>Thank you so much for coming on on.

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<v Speaker 4>Lots, Tracy, thanks so much for having me. Love the

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<v Speaker 4>show and it's through all honor to be here.

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<v Speaker 1>Oh, I appreciate that. So I'm sort of in a

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<v Speaker 1>reflective mood lately. And I used to be a banking correspondent.

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<v Speaker 1>I covered a lot of fintech back when people were

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<v Speaker 1>super excited about it. I feel like they're not as

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<v Speaker 1>excited about it anymore. This is a really embarrassing. First question,

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<v Speaker 1>what is the OCC do and like, how does it compare?

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<v Speaker 1>I feel like there are so many different banking regularly.

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<v Speaker 4>How much time do we have?

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<v Speaker 1>Yeah, well, there's the FDIC, there's the FED, there's the OCC.

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<v Speaker 1>Who's doing what? How often do you step on each

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<v Speaker 1>other's toes?

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<v Speaker 4>We coordinate a lot, let me put it that way.

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<v Speaker 4>So the OCC regulates and supervises nationally chartered banks and

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<v Speaker 4>federal savings associations. So, just to put some numbers on that,

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<v Speaker 4>it's about eleven hundred banks. Wow, Okay, now we've got forty.

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<v Speaker 4>We got over four thousand banks in the banking system,

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<v Speaker 4>but by assets, the largest banks tend to be nationally chartered.

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<v Speaker 4>You know your your JP Morgan chases and your cities

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<v Speaker 4>in the world. So by assets, the occ supervises and

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<v Speaker 4>regulates about two thirds of the banking assets. Oh, got

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<v Speaker 4>it in the system, right, So you get a little

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<v Speaker 4>bit of that eighty twenty year rule for nationally charter banks.

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<v Speaker 4>Banks can have state charters, and they can be members

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<v Speaker 4>or not members of the Federal Reserves. So we have

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<v Speaker 4>a complicated Actually your listeners might be interested in this,

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<v Speaker 4>but maybe we'll spare them for there.

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<v Speaker 2>Our listeners love detail.

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<v Speaker 4>So there's a different kind of landscape. But we coordinate

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<v Speaker 4>quite a bit at the federal level on all the

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<v Speaker 4>major rulemakings because we want a level system. We want

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<v Speaker 4>a level banking system. Now, I think it was really

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<v Speaker 4>interesting about the occ IS historically. So we were founded

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<v Speaker 4>in eighteen sixty three during the Civil War. Wow, and

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<v Speaker 4>before the OCC you had free banking. And this is

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<v Speaker 4>relevant for stable coins because that system. But they all

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<v Speaker 4>issued their own currency, yes, I remember this. So you

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<v Speaker 4>had the Bank of Tracy, and you had the Bank

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<v Speaker 4>of Mike and the Bank of Joe, and each bank

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<v Speaker 4>would issue its own dollar, different size, different color, but

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<v Speaker 4>it would be a dollar. And so people are walking

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<v Speaker 4>around with all these different notes and in theory they

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<v Speaker 4>could go back to the Bank of Tracy and say,

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<v Speaker 4>I want a dollar's worth of gold right specie, And

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<v Speaker 4>sometimes you had it and sometimes you didn't, and so

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<v Speaker 4>there would be discount rates on these dollars, and so

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<v Speaker 4>it was a mess. And you imagine like there's panics

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<v Speaker 4>all the time. There's a lot of fraud, and there

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<v Speaker 4>were money men. People would walk go around with bags

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<v Speaker 4>full of money from town to town to exchange these

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<v Speaker 4>dollars because you know, if you're a farmer, you want

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<v Speaker 4>to be able to do your business. So during the

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<v Speaker 4>Civil War, Sam and Chase is like, hey, we got

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<v Speaker 4>to fund the war and we got to bring the

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<v Speaker 4>union together. So they've got they passed a series of laws.

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<v Speaker 4>They've got now a green back, unified dollar, and they

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<v Speaker 4>create national banks to basically both issue those and then

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<v Speaker 4>take deposits and basically buy treasury bonds which funds the war.

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<v Speaker 2>That's crazy.

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<v Speaker 1>So the occ was around even before the fest yes,

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<v Speaker 1>way before.

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<v Speaker 2>So you have one up on them so well, and.

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<v Speaker 4>All we do is supervision. It's a we are a

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<v Speaker 4>very supervisory focused agency. And so we've got a long

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<v Speaker 4>deep history and you know, the stable coin debates. You know,

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<v Speaker 4>this is less relevant now, but a lot of times

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<v Speaker 4>folks were saying, well, why don't we want more? Don't

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<v Speaker 4>we want stable coins? And it's like the stable coin

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<v Speaker 4>landscape now looks a lot like free banking because each

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<v Speaker 4>of these issuers is different and they try differently. I mean,

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<v Speaker 4>if you go on the and you look these things

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<v Speaker 4>up and it's not a long term sustainable system.

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<v Speaker 1>Well, since we're on the topic of stable coins, as

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<v Speaker 1>our Bloomberg opinion columnist Matt Levine says, often it does

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<v Speaker 1>seem like a lot of crypto and maybe some aspects

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<v Speaker 1>of fintech are learning the lessons of the financial system

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<v Speaker 1>development sort of in real time. And on the topic

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<v Speaker 1>of stable coins, you know, we did have a big

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<v Speaker 1>collapse last.

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<v Speaker 2>Year with Tara Luna.

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<v Speaker 1>You at the OCC have always taken a sort of

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<v Speaker 1>cautious approach to stable coins. What was it that kind

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<v Speaker 1>of worried you about their development? What was it that

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<v Speaker 1>you saw that made you think, wait a second? And

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<v Speaker 1>in some respects it's kind of surprising because stable coins

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<v Speaker 1>were supposed to be the safest aspect of the crypto

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<v Speaker 1>system and then turned out to be very problematic. Although

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<v Speaker 1>I guess you can say that about a lot of

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<v Speaker 1>financial history. The safest assets often turn out to be

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<v Speaker 1>the problematic ones. But yes, what was it that made

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<v Speaker 1>you take that cautious approach?

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<v Speaker 4>So if we back up a little bit and you know,

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<v Speaker 4>just the rise of crypto. So I became Acting Comptroller

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<v Speaker 4>in May of twenty twenty one, and that year alone,

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<v Speaker 4>crypto was just on a.

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<v Speaker 2>That was a big that was a big year of

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<v Speaker 2>growth for.

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<v Speaker 4>Crypto in general and stable coins, and so there's a

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<v Speaker 4>lot of hype, a lot of fomo, and it felt

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<v Speaker 4>familiar to me because it felt a lot like derivatives

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<v Speaker 4>and structured finance circa two thousand and four to two

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<v Speaker 4>thousand and six.

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<v Speaker 1>Right, you pool all this stuff and then you trade

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<v Speaker 1>it as well, one for one.

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<v Speaker 4>And so there's Julian Ted got this great book, Fools Gold,

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<v Speaker 4>and I recommend it to everybody because chapter one innovation,

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<v Speaker 4>Chapter two, perversion, Chapter three crisis, and so this cycle

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<v Speaker 4>happens over. The first innovations for credit to fault swaps

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<v Speaker 4>were really really good. They solved problems, it was amazing,

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<v Speaker 4>it's great, and then people are just innovating for innovation's sake,

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<v Speaker 4>and then you have the high priests who understands this. Oh,

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<v Speaker 4>only the p HD with you know, who understand you know,

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<v Speaker 4>nuclear physics can actually explain the stuff, and that leads

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<v Speaker 4>to it creates an environment where it can just kind

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<v Speaker 4>of eat itself. And so I had a feeling within

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<v Speaker 4>crypto maybe that's what's happening. And so of course I

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<v Speaker 4>think we do what we do best in government. We

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<v Speaker 4>dig in, what are the facts, let's like crack the

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<v Speaker 4>thing open and try to understand this best we can.

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<v Speaker 4>And the more we looked, the more worrying signs of like, hmm,

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<v Speaker 4>this is not all it's cracked up to be. And

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<v Speaker 4>especially with stable coins, there was a big gap between

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<v Speaker 4>the talk and the reality, and so that just sets

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<v Speaker 4>a whole bunch of flags up. And so, yeah, you're

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<v Speaker 4>trying to telegraph very clearly to banks like, look, if

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<v Speaker 4>you're going to get into crypto, it's got to be safe,

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<v Speaker 4>sound and fair. Do your homework, you know, make sure

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<v Speaker 4>you have those controls in place. And so for the

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<v Speaker 4>banks that were, you know, like I call them crypto curious,

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<v Speaker 4>and there were a lot at the time, they lost

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<v Speaker 4>interest because I think they recognized, oh that that takes

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<v Speaker 4>an awful lot of work, and then once the crypto

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<v Speaker 4>winter happened, you know, a lot of that, there was

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<v Speaker 4>a big pull.

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<v Speaker 1>Back from that, right Well, the one other thing I

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<v Speaker 1>want to ask is stable coins aside. You know, we

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<v Speaker 1>did see a little bit of contagion from the crypto

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<v Speaker 1>turmoil of twenty twenty two into the banking system. So

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<v Speaker 1>notably we saw Silvergate collapse, and I guess we can

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<v Speaker 1>debate how much of that was due to pure crypto

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<v Speaker 1>or other dynamics with deposit outflows and things like that.

0:11:23.720 --> 0:11:26.280
<v Speaker 1>But does it feel to you looking at the US

0:11:26.280 --> 0:11:29.360
<v Speaker 1>banking landscape now in twenty twenty three, that there's enough

0:11:29.520 --> 0:11:33.920
<v Speaker 1>of a barrier between regulated banks and crypto, there's enough

0:11:33.960 --> 0:11:35.839
<v Speaker 1>of a sort of insulation there.

0:11:35.960 --> 0:11:37.880
<v Speaker 4>So I'm going to knock on I'm not sure if

0:11:37.880 --> 0:11:39.480
<v Speaker 4>this would I'm want to knock on it.

0:11:39.679 --> 0:11:42.760
<v Speaker 1>Our producer Carmen's going to kill you for making ambient

0:11:42.840 --> 0:11:44.160
<v Speaker 1>noise during the podcast.

0:11:44.840 --> 0:11:47.840
<v Speaker 4>The short answer is, I think so. And that's in

0:11:47.920 --> 0:11:51.600
<v Speaker 4>part because across all the federal banking agencies, we've been

0:11:51.720 --> 0:11:54.880
<v Speaker 4>very clear and unified about how we feel and what

0:11:54.920 --> 0:11:59.160
<v Speaker 4>our expectations are about banks engaging in risky activities such

0:11:59.160 --> 0:12:03.679
<v Speaker 4>as crypto those risks out, you provide an interagency guidance. Again,

0:12:03.720 --> 0:12:06.200
<v Speaker 4>it's not to say that banks can't do it, but

0:12:06.320 --> 0:12:08.520
<v Speaker 4>if a bank is going to do it, whatever it is,

0:12:09.160 --> 0:12:11.679
<v Speaker 4>it's got to be safe, sound, and fair, and they

0:12:11.679 --> 0:12:13.800
<v Speaker 4>have to prove that to us. We feel that that's

0:12:13.920 --> 0:12:17.960
<v Speaker 4>very appropriate given what's taking place in the crypto space. Again,

0:12:18.040 --> 0:12:20.360
<v Speaker 4>if you go back, I think the stats are about

0:12:20.400 --> 0:12:22.880
<v Speaker 4>a billion dollars of fraud, two billion dollars of scams,

0:12:22.880 --> 0:12:25.120
<v Speaker 4>and three billion dollars of hacks last year. Like that's

0:12:25.600 --> 0:12:28.360
<v Speaker 4>that's a risky space. That's not to say everybody's bad,

0:12:28.840 --> 0:12:31.160
<v Speaker 4>because that's not true. There are good players in that space,

0:12:31.200 --> 0:12:33.720
<v Speaker 4>but it's a risky space, and so we expect banks

0:12:33.760 --> 0:12:37.200
<v Speaker 4>to do that work. And I think most banks either

0:12:37.200 --> 0:12:40.760
<v Speaker 4>they're doing that work or they're decided it's just not

0:12:40.840 --> 0:12:41.439
<v Speaker 4>really worth it.

0:12:42.080 --> 0:12:44.839
<v Speaker 2>So crypto is by no means a monolith.

0:12:44.960 --> 0:12:47.720
<v Speaker 1>And even though you've taken a cautious approach to stable coins,

0:12:48.240 --> 0:12:50.160
<v Speaker 1>I get the sense that you're a little bit more

0:12:50.200 --> 0:12:55.040
<v Speaker 1>interested in another aspect of crypto, tokenization. You're holding a

0:12:55.040 --> 0:12:58.800
<v Speaker 1>big tokenization conference, right, what's the draw there?

0:12:59.640 --> 0:13:03.760
<v Speaker 4>So is hosting a tokenization symposium on February eighth, Market

0:13:03.840 --> 0:13:07.079
<v Speaker 4>calendars open to the public. Our keynote is going to

0:13:07.160 --> 0:13:09.800
<v Speaker 4>be Hyon Sugtion from the BIS. I know you enjoyed

0:13:10.920 --> 0:13:15.240
<v Speaker 4>one of our favorites. Yeah, and and Hun is fantastic

0:13:15.320 --> 0:13:21.079
<v Speaker 4>because he's got a very broad perspective across both monetary policy, research, banking,

0:13:21.559 --> 0:13:25.160
<v Speaker 4>and all things kind of crypto digital assets related. Because

0:13:25.160 --> 0:13:27.400
<v Speaker 4>that the BIS, I've got the innovation hub, and there's

0:13:27.400 --> 0:13:29.720
<v Speaker 4>a lot of intersection between you know, his research and

0:13:29.720 --> 0:13:32.319
<v Speaker 4>what they've been doing. In a word, there's been a

0:13:32.400 --> 0:13:37.200
<v Speaker 4>growing divide between crypto and tokenization and tokenization of real

0:13:37.240 --> 0:13:41.400
<v Speaker 4>world assets and liabilities. Most crypto is not backed by

0:13:41.440 --> 0:13:44.960
<v Speaker 4>anything bitcoin, ether, et cetera, or if yes or stable coins.

0:13:45.240 --> 0:13:48.800
<v Speaker 4>Tokenization is a different game, you know crypto's it's retail

0:13:48.840 --> 0:13:52.480
<v Speaker 4>focused and most of the interest in those coins is

0:13:52.640 --> 0:13:56.920
<v Speaker 4>based on hope for speculative gain. Tokenization is about solving

0:13:57.120 --> 0:14:01.400
<v Speaker 4>a settlement problem. And this is real for your listeners.

0:14:02.040 --> 0:14:05.400
<v Speaker 4>Now we're in the plumbing of the system and for

0:14:05.400 --> 0:14:07.360
<v Speaker 4>those who know, like when you buy a share of stock,

0:14:07.920 --> 0:14:10.120
<v Speaker 4>there's all this stuff that happens in the background. It

0:14:10.160 --> 0:14:13.680
<v Speaker 4>involves multiple players, there's different handoffs, there's risk that gets

0:14:13.760 --> 0:14:18.840
<v Speaker 4>transformed into different ways. It's complicated, and it's it creates frictions,

0:14:18.840 --> 0:14:21.360
<v Speaker 4>and it creates costs. So if there's a way to

0:14:22.040 --> 0:14:26.400
<v Speaker 4>make that settlement process better, why not. And I think

0:14:26.400 --> 0:14:29.360
<v Speaker 4>that's the that's the promise of tokenization, is that some

0:14:29.400 --> 0:14:31.840
<v Speaker 4>of those risks and frictions can be addressed by basically

0:14:31.880 --> 0:14:33.800
<v Speaker 4>taking messaging and settlement and combining that.

0:14:35.800 --> 0:14:37.680
<v Speaker 1>And can you explain that a little bit further Because

0:14:37.720 --> 0:14:40.520
<v Speaker 1>when I think I think tokenization, I think, like, I

0:14:40.600 --> 0:14:45.480
<v Speaker 1>presume these are centralized databases, and then I think, well,

0:14:45.600 --> 0:14:50.320
<v Speaker 1>what's the difference between a tokenized central database versus an

0:14:50.320 --> 0:14:54.960
<v Speaker 1>Excel spreadsheet? Right that's password protected? Yes, Like what is

0:14:55.000 --> 0:14:56.400
<v Speaker 1>the innovation here? Right?

0:14:56.640 --> 0:15:00.040
<v Speaker 4>So this is a very important point blockchain. I I

0:15:00.040 --> 0:15:00.520
<v Speaker 4>didn't say.

0:15:00.440 --> 0:15:02.640
<v Speaker 2>Blockchain, No you didn't, okay, And I think that's a.

0:15:02.680 --> 0:15:04.920
<v Speaker 4>Very important distinction, right. I think there's been a little

0:15:04.920 --> 0:15:07.160
<v Speaker 4>bit of a how should I what's the best way

0:15:07.200 --> 0:15:08.800
<v Speaker 4>to put it? It's almost like a raw shot test,

0:15:09.520 --> 0:15:12.160
<v Speaker 4>you know, you say blockchain, and some folks that, oh,

0:15:12.400 --> 0:15:15.680
<v Speaker 4>that's the next big thing, whether they understand it or not, like, oh,

0:15:15.680 --> 0:15:18.960
<v Speaker 4>it's super efficient and fast. It's not super efficient or fast.

0:15:18.960 --> 0:15:21.080
<v Speaker 1>I mean, I remember that the years when we were

0:15:21.080 --> 0:15:24.480
<v Speaker 1>going to put everything on the blockchain, like groceries or

0:15:24.640 --> 0:15:27.760
<v Speaker 1>like balsamic vinegar was going to be traceable on the

0:15:27.800 --> 0:15:30.680
<v Speaker 1>blockchain to make sure it came from a specific region

0:15:30.720 --> 0:15:31.680
<v Speaker 1>and things like that.

0:15:31.560 --> 0:15:35.280
<v Speaker 4>Right, and so the design of public blockchains was there

0:15:35.280 --> 0:15:38.240
<v Speaker 4>were certain reasons for doing it. If you go back

0:15:38.240 --> 0:15:42.880
<v Speaker 4>to the the Satoshi Nakamoto white paper, that paper is

0:15:42.920 --> 0:15:45.560
<v Speaker 4>pretty fascinating and it's a really interesting paper, and it

0:15:45.600 --> 0:15:47.600
<v Speaker 4>makes the case for why you should do something that way.

0:15:48.520 --> 0:15:51.680
<v Speaker 4>But to your point, Tracy, if the problem you're trying

0:15:51.720 --> 0:15:55.760
<v Speaker 4>to solve is settlement frictions, you don't need that, and

0:15:55.840 --> 0:15:59.000
<v Speaker 4>in fact, that probably just slows things down and gums

0:15:59.000 --> 0:16:01.520
<v Speaker 4>things up. They're better to do that. Now, what's the

0:16:01.600 --> 0:16:04.200
<v Speaker 4>what's the innovation? That's your question. What's the innovation? It's

0:16:04.560 --> 0:16:08.680
<v Speaker 4>basically taking messaging and settlement and combining it. That's different

0:16:08.720 --> 0:16:10.920
<v Speaker 4>because right now, when you again we'll use the example,

0:16:10.920 --> 0:16:13.840
<v Speaker 4>when you buy a share of stock, you're sending a

0:16:13.880 --> 0:16:17.480
<v Speaker 4>message to buy, you know, a share of Tesla or something,

0:16:18.160 --> 0:16:19.880
<v Speaker 4>and then that message goes and then a bunch of

0:16:20.000 --> 0:16:23.080
<v Speaker 4>other things have to happen before that thing actually settles.

0:16:23.160 --> 0:16:25.000
<v Speaker 4>Your money gets transferred, you get a share of stock,

0:16:25.080 --> 0:16:28.360
<v Speaker 4>and that's held somewhere, and you have everyone's fully aware

0:16:28.400 --> 0:16:32.400
<v Speaker 4>that that has happened. With tokenization, you actually collapse a

0:16:32.400 --> 0:16:34.560
<v Speaker 4>lot of those steps into into a single thing.

0:16:34.680 --> 0:16:37.720
<v Speaker 1>Oh, I see, So multiple processes can exist as sort

0:16:37.760 --> 0:16:40.000
<v Speaker 1>of like one thing exactly that can then move through

0:16:40.040 --> 0:16:41.800
<v Speaker 1>the system and be verified exactly.

0:16:41.960 --> 0:16:44.200
<v Speaker 4>And you know, for again, for the for the for

0:16:44.240 --> 0:16:46.760
<v Speaker 4>the banking nerds and the payment nerds out there, this

0:16:46.920 --> 0:16:50.760
<v Speaker 4>is exciting. Now it's hard to tell this story to

0:16:50.840 --> 0:16:54.720
<v Speaker 4>a retail because it's hard to see that difference. But

0:16:54.760 --> 0:16:57.040
<v Speaker 4>those costs and those frictions add up, and there's quite

0:16:57.040 --> 0:17:02.200
<v Speaker 4>a bit of time and effort that gets put into identifying, addressing, assessing,

0:17:02.600 --> 0:17:05.679
<v Speaker 4>managing those risks and frictions. And so you know that

0:17:06.880 --> 0:17:10.119
<v Speaker 4>in the for the regulators in the central banks that

0:17:10.160 --> 0:17:13.160
<v Speaker 4>had been kind of interested in this space, a lot

0:17:13.200 --> 0:17:17.679
<v Speaker 4>of the the more of the excitement going forward is

0:17:17.720 --> 0:17:20.080
<v Speaker 4>really in this kind of tokenization space rather than in

0:17:20.160 --> 0:17:23.480
<v Speaker 4>kind of the retail space, which I think is been

0:17:23.520 --> 0:17:25.720
<v Speaker 4>colored by a lot of the recent of vicaild accent.

0:17:40.720 --> 0:17:44.239
<v Speaker 1>Well, since we're on the topic of financial innovation and

0:17:44.359 --> 0:17:47.119
<v Speaker 1>we are essentially at a fintech conference. We're at Money

0:17:47.119 --> 0:17:50.439
<v Speaker 1>twenty twenty. I want to ask you about a recent

0:17:50.680 --> 0:17:54.320
<v Speaker 1>publication from the OCC. It's the inter Agency has a

0:17:54.400 --> 0:17:59.520
<v Speaker 1>very catchy name, the inter Agency Kidance on Third Party Relationships.

0:18:00.240 --> 0:18:02.800
<v Speaker 1>Is that just basically a way of saying that you're

0:18:02.840 --> 0:18:05.600
<v Speaker 1>worried about fintech partnerships with the banks.

0:18:06.160 --> 0:18:09.000
<v Speaker 4>So the guidance is broader than just that, but you're

0:18:09.040 --> 0:18:10.800
<v Speaker 4>onto something. So let me let me just zoom out

0:18:10.800 --> 0:18:15.160
<v Speaker 4>for a second. That guidance is geared towards banks relationships

0:18:15.200 --> 0:18:17.600
<v Speaker 4>with any vendors, any third parties.

0:18:17.680 --> 0:18:19.399
<v Speaker 2>Okay, so payments as well and things like.

0:18:19.400 --> 0:18:21.720
<v Speaker 4>That, but a bunch of others as well. And so

0:18:21.800 --> 0:18:23.840
<v Speaker 4>you know, the story I like to tell is your

0:18:23.840 --> 0:18:27.240
<v Speaker 4>way back in the beginning, all of banking was done

0:18:27.280 --> 0:18:29.480
<v Speaker 4>by banks, and so you can imagine like there's like

0:18:29.480 --> 0:18:32.040
<v Speaker 4>a box and you can label that banks and banking

0:18:32.080 --> 0:18:34.800
<v Speaker 4>ills the same box. They did everything by themselves, and

0:18:34.840 --> 0:18:37.720
<v Speaker 4>then over time they had to rely on others to

0:18:37.760 --> 0:18:40.720
<v Speaker 4>do certain things. And you know, probably the clearest example

0:18:40.840 --> 0:18:42.840
<v Speaker 4>is like with the core processors. A lot of banks

0:18:42.880 --> 0:18:46.440
<v Speaker 4>rely on the core processors to do certain processing accounting,

0:18:46.520 --> 0:18:50.120
<v Speaker 4>you know, reconciliations, et cetera. And so that's now there's

0:18:50.160 --> 0:18:53.440
<v Speaker 4>a dependency. And so as a regulator, you say, how

0:18:53.480 --> 0:18:57.520
<v Speaker 4>do I ensure that everything that that bank does is safe,

0:18:57.560 --> 0:18:59.840
<v Speaker 4>sound and fair. Oh, I need to make sure that

0:19:00.000 --> 0:19:03.360
<v Speaker 4>what they've done with that third party is up to snuff. Right,

0:19:03.400 --> 0:19:06.760
<v Speaker 4>If it's slipshot, if it's done sloppily, things can break

0:19:06.800 --> 0:19:08.600
<v Speaker 4>and then the bank will say, oh, that wasn't my fault,

0:19:08.880 --> 0:19:10.159
<v Speaker 4>and they'll blame it on someone else. But at the

0:19:10.240 --> 0:19:11.879
<v Speaker 4>end of the day, the bank itself is not going

0:19:11.960 --> 0:19:14.359
<v Speaker 4>to be safe. We don't have a safe and sound system.

0:19:14.400 --> 0:19:16.840
<v Speaker 4>So we want to make sure that that standard kind

0:19:16.840 --> 0:19:18.920
<v Speaker 4>of carries through. It's almost like an extension of the bank,

0:19:18.960 --> 0:19:21.840
<v Speaker 4>if you will. Okay, that's one on one. Now we

0:19:21.920 --> 0:19:26.040
<v Speaker 4>fast forward to today. Now it's way more complicated because

0:19:26.160 --> 0:19:28.359
<v Speaker 4>not only do you have lots of different kinds of vendors,

0:19:28.359 --> 0:19:30.960
<v Speaker 4>Like a lot of banks are now saying, hey, why

0:19:30.960 --> 0:19:32.840
<v Speaker 4>stop with cores. We can do this with a lot

0:19:32.880 --> 0:19:36.280
<v Speaker 4>of because our comparative vantage is different than a lot

0:19:36.280 --> 0:19:38.280
<v Speaker 4>of the technology that's out there. There's a whole bunch

0:19:38.280 --> 0:19:41.320
<v Speaker 4>of different use cases in terms of vendors. Now the

0:19:41.320 --> 0:19:43.520
<v Speaker 4>tables are being turned. Now you've got some FinTechs that

0:19:43.520 --> 0:19:46.320
<v Speaker 4>are going to customers say we will be the interface

0:19:46.359 --> 0:19:48.680
<v Speaker 4>with you to take a deposit and make a loan,

0:19:48.680 --> 0:19:51.600
<v Speaker 4>et cetera. But we need a bank to actually do that,

0:19:52.680 --> 0:19:54.439
<v Speaker 4>and so then they go to the bank. So in

0:19:54.440 --> 0:19:57.240
<v Speaker 4>the sense the bank is the is the provider. That's

0:19:57.240 --> 0:20:01.640
<v Speaker 4>why it's banking as a service, the bank providing that service.

0:20:02.320 --> 0:20:04.040
<v Speaker 4>But the dependency is flipped around.

0:20:04.200 --> 0:20:06.560
<v Speaker 1>Yeah, it's almost like, you know, we used to talk

0:20:06.600 --> 0:20:10.600
<v Speaker 1>about the disintermediation of banks, and someone brought this up

0:20:10.600 --> 0:20:13.760
<v Speaker 1>in our discord recently. Apparently I wrote an article which

0:20:13.760 --> 0:20:17.199
<v Speaker 1>I'd forgotten, but all the time, Yeah, when there was

0:20:17.200 --> 0:20:20.960
<v Speaker 1>all that excitement about peer to peer lending or direct lending. Yeah,

0:20:21.080 --> 0:20:24.680
<v Speaker 1>Wells Fargo apparently like put out a notice to its

0:20:24.680 --> 0:20:27.960
<v Speaker 1>employees saying, please do not invest in peer to peer

0:20:28.000 --> 0:20:30.639
<v Speaker 1>lending because they're a direct competitor to us. Right, the

0:20:30.680 --> 0:20:33.200
<v Speaker 1>whole idea was cut out the banks and people could

0:20:33.240 --> 0:20:36.960
<v Speaker 1>make loans to each other. But now it's almost like disaggregation.

0:20:37.160 --> 0:20:39.520
<v Speaker 1>It's we're disaggregating the banks. We're sort of like taking

0:20:39.560 --> 0:20:43.520
<v Speaker 1>pieces away, or like there are new players, new companies

0:20:43.520 --> 0:20:46.239
<v Speaker 1>that are tapping the banks for specific pieces it's all

0:20:46.359 --> 0:20:47.040
<v Speaker 1>very confusing.

0:20:47.240 --> 0:20:49.880
<v Speaker 4>Well it's confusing, but there's there's a logic to it.

0:20:50.160 --> 0:20:52.679
<v Speaker 4>And so the analogy I like to draw is if

0:20:52.720 --> 0:20:56.680
<v Speaker 4>you go back to pre two thousand and eight capital

0:20:56.720 --> 0:21:00.520
<v Speaker 4>markets disintermediated banking, and it was really the the lending

0:21:00.520 --> 0:21:02.840
<v Speaker 4>and the deposit taking right. Money funds took deposit taking,

0:21:02.920 --> 0:21:04.520
<v Speaker 4>and securitization took blending.

0:21:04.640 --> 0:21:06.320
<v Speaker 1>By the way, this is how you get a financial

0:21:06.359 --> 0:21:09.200
<v Speaker 1>journalists attention. When you say here's a pre two thousand

0:21:09.240 --> 0:21:12.480
<v Speaker 1>and eight analogy, I'm all ears, I'm like, yes, tell

0:21:12.560 --> 0:21:13.480
<v Speaker 1>me so.

0:21:13.680 --> 0:21:16.040
<v Speaker 4>If you drew a picture and one of my favorite

0:21:16.040 --> 0:21:21.160
<v Speaker 4>pictures of this Zultan pos Aar, who is another favorite,

0:21:21.280 --> 0:21:24.080
<v Speaker 4>He drew this map, his famous map.

0:21:23.880 --> 0:21:25.600
<v Speaker 1>That he had pinned on the wall of the New

0:21:25.640 --> 0:21:27.280
<v Speaker 1>York Fast more than I mean a bunch of a

0:21:27.320 --> 0:21:28.159
<v Speaker 1>bunch of folks had this.

0:21:28.600 --> 0:21:31.960
<v Speaker 4>It was a gigantic map, and uh, you know again

0:21:32.000 --> 0:21:34.480
<v Speaker 4>for the nerds on the podcast, it was it's basically

0:21:34.560 --> 0:21:39.280
<v Speaker 4>t accounts, assets, liabilities, equity, but for different points of

0:21:39.280 --> 0:21:42.720
<v Speaker 4>a system. And it did what any good financial follow

0:21:42.760 --> 0:21:44.960
<v Speaker 4>the money right. You just follow the money.

0:21:44.720 --> 0:21:47.080
<v Speaker 1>Right, how it's moving through the banking system and the

0:21:47.119 --> 0:21:48.119
<v Speaker 1>shadow banking system and.

0:21:48.119 --> 0:21:50.159
<v Speaker 4>That so Zultan and then Adam Ashcraft was a co

0:21:50.200 --> 0:21:53.000
<v Speaker 4>author on the Shadow Banking paper, which basically said what

0:21:53.080 --> 0:21:55.679
<v Speaker 4>banks used to do as lenders has now been broken

0:21:55.760 --> 0:21:59.040
<v Speaker 4>up into six pieces or multiple pieces, and each piece

0:21:59.119 --> 0:22:02.040
<v Speaker 4>is being done by a differnt group. So origination, remember

0:22:02.119 --> 0:22:04.719
<v Speaker 4>new century, and option to one. They would do originations

0:22:04.720 --> 0:22:07.920
<v Speaker 4>for mortgages, warehouse lenning, someone else would do warehouse lending.

0:22:08.200 --> 0:22:11.240
<v Speaker 4>Distributions someone else would do. So you and you look

0:22:11.280 --> 0:22:13.719
<v Speaker 4>at that and say, well does that make sense? Well,

0:22:13.720 --> 0:22:18.120
<v Speaker 4>there's like a specialty there, okay, and maybe they're particularly

0:22:18.119 --> 0:22:20.000
<v Speaker 4>good at that, and there's economies of scale.

0:22:20.040 --> 0:22:21.959
<v Speaker 2>Yeah, they would argue efficiency.

0:22:21.560 --> 0:22:25.520
<v Speaker 4>Right, efficiencies, and so you'd say that that logic in

0:22:25.560 --> 0:22:28.640
<v Speaker 4>and of itself on a micro scale made sense. It's

0:22:28.680 --> 0:22:30.800
<v Speaker 4>only when you zoomed out and you looked at the

0:22:30.840 --> 0:22:34.760
<v Speaker 4>whole thing that you said, oh, oh does this hold?

0:22:34.840 --> 0:22:39.280
<v Speaker 4>And I think the real the insight from the you know,

0:22:39.320 --> 0:22:42.960
<v Speaker 4>the Posar Ashcraft work was all the FED facilities matched

0:22:43.040 --> 0:22:45.080
<v Speaker 4>up to each of those points. So it's almost like

0:22:45.119 --> 0:22:48.720
<v Speaker 4>the discount window was recreated for what had been disintermediated,

0:22:49.240 --> 0:22:52.840
<v Speaker 4>which is quite intuitive actually. So it gets back to

0:22:52.920 --> 0:22:55.639
<v Speaker 4>this idea I have, which which I think others have

0:22:55.680 --> 0:22:59.879
<v Speaker 4>talked about it's like you've got the conservation of matter.

0:23:00.359 --> 0:23:03.119
<v Speaker 4>Like risk is neither created nor destroyed. It just it

0:23:03.160 --> 0:23:06.439
<v Speaker 4>can transform and be chopped up and reallocated. But it

0:23:06.480 --> 0:23:09.240
<v Speaker 4>all adds up to the same thing. And so now

0:23:09.480 --> 0:23:12.399
<v Speaker 4>we fast forward to today and this is what's happening

0:23:12.400 --> 0:23:14.959
<v Speaker 4>with payments. And if you talk to the payments companies,

0:23:14.960 --> 0:23:17.399
<v Speaker 4>they say, it doesn't make any sense to basically have

0:23:17.480 --> 0:23:19.359
<v Speaker 4>a full system like front to back on this, like

0:23:19.720 --> 0:23:22.440
<v Speaker 4>you want to slice it up, because different companies do

0:23:22.480 --> 0:23:25.720
<v Speaker 4>a different job on things where they're better at it.

0:23:26.040 --> 0:23:29.480
<v Speaker 4>So it's very similar logic to the capital markets systant mediation.

0:23:29.680 --> 0:23:31.719
<v Speaker 4>And again each point makes sense when you do it

0:23:31.720 --> 0:23:33.919
<v Speaker 4>one by one, when you zoom out, what does it

0:23:33.960 --> 0:23:37.359
<v Speaker 4>look like and what's the risk reward and who's bearing

0:23:37.359 --> 0:23:37.800
<v Speaker 4>what risk?

0:23:38.119 --> 0:23:40.080
<v Speaker 1>Well, okay, so just on this point, I mean, maybe

0:23:40.080 --> 0:23:42.520
<v Speaker 1>I'm reading too much into the two thousand and eight analogy,

0:23:42.600 --> 0:23:44.920
<v Speaker 1>but like one of the reasons it all went off

0:23:44.960 --> 0:23:48.520
<v Speaker 1>the rails is because as you had all these different

0:23:48.760 --> 0:23:51.919
<v Speaker 1>entities doing different things, there was kind of less and

0:23:52.000 --> 0:23:54.520
<v Speaker 1>less return for all of them, and so the temptation

0:23:54.800 --> 0:23:57.800
<v Speaker 1>was to start levering it up and try to amplify

0:23:58.000 --> 0:24:01.640
<v Speaker 1>whatever yields you could get. Is that the risk here

0:24:01.800 --> 0:24:04.000
<v Speaker 1>or I guess talk to us concretely about the risks.

0:24:04.000 --> 0:24:07.520
<v Speaker 1>And then secondly, is there enough for return to actually

0:24:07.520 --> 0:24:08.080
<v Speaker 1>go around?

0:24:08.200 --> 0:24:09.680
<v Speaker 2>Because when I look at all.

0:24:09.520 --> 0:24:13.680
<v Speaker 1>These different little pieces of banking services, it feels like

0:24:13.760 --> 0:24:18.320
<v Speaker 1>there are so many players all kind of offering similar things.

0:24:18.400 --> 0:24:20.679
<v Speaker 4>So I think that's a very very valid question. And

0:24:20.720 --> 0:24:23.439
<v Speaker 4>I know there have some both fintech and bank analysts

0:24:23.440 --> 0:24:25.280
<v Speaker 4>who have kind of looked into this, and they're raising

0:24:25.400 --> 0:24:27.280
<v Speaker 4>very similar questions like is there enough to go around

0:24:27.280 --> 0:24:30.920
<v Speaker 4>to support such a complex ecosystem. But let's take a

0:24:30.920 --> 0:24:32.840
<v Speaker 4>step back. Let's go back to banking as a service.

0:24:33.160 --> 0:24:35.920
<v Speaker 4>With banking as a service, there's a spectrum, and at

0:24:35.920 --> 0:24:38.680
<v Speaker 4>one end of the spectrum, you'll have what I think

0:24:38.720 --> 0:24:42.200
<v Speaker 4>of something that's relatively simple. You've got a fintech, you've

0:24:42.200 --> 0:24:45.280
<v Speaker 4>got a really cool app targeted at a population that

0:24:45.280 --> 0:24:47.640
<v Speaker 4>they're really familiar with, they know it's going to work,

0:24:47.680 --> 0:24:50.680
<v Speaker 4>and you've got a bank who traditionally doesn't know how

0:24:50.720 --> 0:24:54.639
<v Speaker 4>to engage to acquire that customer. So they partner together

0:24:54.680 --> 0:24:56.760
<v Speaker 4>and they said, let's go get that customer together, and

0:24:56.760 --> 0:24:59.160
<v Speaker 4>the bank says that customer is my customer as much

0:24:59.160 --> 0:25:01.920
<v Speaker 4>as it is yours, and they apply all the KYC

0:25:02.400 --> 0:25:05.400
<v Speaker 4>and the compliance and all of the bells and whistles

0:25:05.400 --> 0:25:07.600
<v Speaker 4>that they would provide to any other customer is apply

0:25:07.640 --> 0:25:13.080
<v Speaker 4>to that customer. Very simple, hard to scale, but relatively simple, straightforward,

0:25:13.119 --> 0:25:15.840
<v Speaker 4>and then they you know, what's the rev split between

0:25:15.840 --> 0:25:18.680
<v Speaker 4>those two and they can negotiate that. At the other

0:25:18.760 --> 0:25:22.000
<v Speaker 4>end of the spectrum, you've got banks, who then who

0:25:22.040 --> 0:25:23.959
<v Speaker 4>do they deal with. They're like, this is too complicated.

0:25:24.680 --> 0:25:27.399
<v Speaker 4>We just want to provide the banking as a service,

0:25:28.560 --> 0:25:31.879
<v Speaker 4>but we want to do it at scale and low. Behold.

0:25:31.920 --> 0:25:33.840
<v Speaker 4>There's some companies out there. This is what they do.

0:25:34.040 --> 0:25:36.600
<v Speaker 4>So you know, often they're referred to as middleware and

0:25:36.600 --> 0:25:38.280
<v Speaker 4>they'll say, well, if you come to us, we have

0:25:38.359 --> 0:25:40.639
<v Speaker 4>partnerships with lots of FinTechs and we have partner and

0:25:40.640 --> 0:25:42.560
<v Speaker 4>they tell the FinTechs we have partnership with lots of banks.

0:25:42.560 --> 0:25:43.040
<v Speaker 2>It's funny.

0:25:43.040 --> 0:25:45.040
<v Speaker 1>It's like there's wear all the way down.

0:25:45.200 --> 0:25:46.840
<v Speaker 2>Yes, yeah, so funny.

0:25:46.600 --> 0:25:48.840
<v Speaker 4>And so they go to them and again there I

0:25:48.840 --> 0:25:50.639
<v Speaker 4>don't want to paint all of them with Abroad, there

0:25:50.680 --> 0:25:52.639
<v Speaker 4>is a there is a spectrum on this, and some

0:25:52.720 --> 0:25:54.760
<v Speaker 4>of it is done in a way that I think

0:25:55.040 --> 0:25:58.200
<v Speaker 4>can be safe, sound and fair, and others we've seen

0:25:58.560 --> 0:26:02.320
<v Speaker 4>that's not the case. And so in those instances, the

0:26:02.359 --> 0:26:05.639
<v Speaker 4>bank has no idea who the real customer is and

0:26:05.680 --> 0:26:08.359
<v Speaker 4>the fintech is like, look, we don't do compliance, we

0:26:08.359 --> 0:26:10.679
<v Speaker 4>don't do ky. See, someone else shall handle that. And

0:26:10.720 --> 0:26:13.400
<v Speaker 4>so we're right back to this picture of each slice

0:26:13.480 --> 0:26:16.879
<v Speaker 4>is doing something slightly different. And you know, in my

0:26:16.960 --> 0:26:19.760
<v Speaker 4>experience where that happens unless there's a lot of clarity

0:26:19.800 --> 0:26:23.800
<v Speaker 4>about who's bearing what responsibility when bad things happen, everyone's

0:26:23.800 --> 0:26:27.080
<v Speaker 4>pointing at each other and that that's a mess. And

0:26:27.119 --> 0:26:29.480
<v Speaker 4>we don't want that. And so, you know, it's really

0:26:29.520 --> 0:26:33.199
<v Speaker 4>important for us as this ecosystem evolves, and we've got

0:26:33.240 --> 0:26:35.720
<v Speaker 4>an eye on that and we guide it towards, you know,

0:26:35.880 --> 0:26:38.120
<v Speaker 4>things that are healthy, because there is good innovation out

0:26:38.119 --> 0:26:41.320
<v Speaker 4>there that can be paired, that can be incorporated to

0:26:41.440 --> 0:26:44.000
<v Speaker 4>the banking system. But we want to make sure that

0:26:44.040 --> 0:26:47.320
<v Speaker 4>we don't end up with this kind of patchworky you know, disintermediated,

0:26:47.560 --> 0:27:03.840
<v Speaker 4>disaggregated mess.

0:27:03.880 --> 0:27:07.080
<v Speaker 1>Since you are the oldest banking regulator in the US,

0:27:07.119 --> 0:27:08.840
<v Speaker 1>I want to ask you a little bit about the

0:27:08.880 --> 0:27:13.000
<v Speaker 1>banking landscape post SVB, And one thing that it feels

0:27:13.000 --> 0:27:15.560
<v Speaker 1>to me that regulators are still sort of grappling with

0:27:15.880 --> 0:27:19.200
<v Speaker 1>is what they want the banking system to look like. Yes,

0:27:19.480 --> 0:27:22.120
<v Speaker 1>do you want a sort of Canadian style system where

0:27:22.160 --> 0:27:25.240
<v Speaker 1>you have like six megabanks and everyone banks with them

0:27:25.359 --> 0:27:28.879
<v Speaker 1>and they're highly highly regulated. Or do you want the

0:27:28.920 --> 0:27:33.480
<v Speaker 1>sort of vibrant, it's a wonderful life style banking system

0:27:33.520 --> 0:27:37.320
<v Speaker 1>where there's local banks everywhere and everyone knows you, and

0:27:37.560 --> 0:27:40.199
<v Speaker 1>you know your banker will personally extend you alone and

0:27:40.240 --> 0:27:44.280
<v Speaker 1>things like that. Where does occ fall on that debate?

0:27:44.359 --> 0:27:46.320
<v Speaker 2>Do you have a vision of what you want?

0:27:46.480 --> 0:27:49.080
<v Speaker 4>I get this question a lot, and it's half a

0:27:49.119 --> 0:27:51.199
<v Speaker 4>loaf of a question. And the reason I say that

0:27:51.320 --> 0:27:55.159
<v Speaker 4>is because it's, just like you said, the instinct of

0:27:55.160 --> 0:27:57.720
<v Speaker 4>folks who are asking you are who are contemplating this

0:27:58.000 --> 0:28:00.440
<v Speaker 4>usually is to say there's too manyks, Like you know,

0:28:00.480 --> 0:28:03.119
<v Speaker 4>four thousand is too many, what's the right number? Or

0:28:03.200 --> 0:28:05.960
<v Speaker 4>to compare to other countries. And what it's missing is

0:28:06.320 --> 0:28:11.840
<v Speaker 4>banks exist to serve people in communities in the economy.

0:28:12.280 --> 0:28:14.199
<v Speaker 4>So what's missing from the question is, well, who are

0:28:14.200 --> 0:28:16.680
<v Speaker 4>the people communities in the economy that we're trying to support.

0:28:17.520 --> 0:28:21.280
<v Speaker 4>The US is very very different in Canada, right, We've

0:28:21.320 --> 0:28:24.560
<v Speaker 4>got three hundred and thirty million people, We've got a

0:28:24.720 --> 0:28:28.240
<v Speaker 4>very diverse economy, lots of different communities, and so that

0:28:28.440 --> 0:28:31.600
<v Speaker 4>argues that we need to have an equally diverse banking system.

0:28:31.960 --> 0:28:34.600
<v Speaker 4>So it's almost like, you know, regulators, we bank love

0:28:34.640 --> 0:28:36.800
<v Speaker 4>to think in terms of ratios. So the question of

0:28:36.840 --> 0:28:38.560
<v Speaker 4>like what should the banking system look like is the

0:28:38.640 --> 0:28:42.640
<v Speaker 4>numerit the denominator is what the economy looks like. And

0:28:42.800 --> 0:28:45.600
<v Speaker 4>as long as we have a really diverse economy, we

0:28:45.680 --> 0:28:48.240
<v Speaker 4>need a really diverse banking system because one size doesn't

0:28:48.240 --> 0:28:51.480
<v Speaker 4>fit all, Like the large megabanks can't serve don't want

0:28:51.520 --> 0:28:55.800
<v Speaker 4>to serve all those different you know, I've got this

0:28:56.920 --> 0:29:00.160
<v Speaker 4>debate yesterday with one of the participments about this long

0:29:00.240 --> 0:29:04.920
<v Speaker 4>tail of cases in the US economy. We have a

0:29:05.080 --> 0:29:09.800
<v Speaker 4>very long tail of different communities, whether they're geographic or otherwise,

0:29:10.360 --> 0:29:13.960
<v Speaker 4>and I think those are opportunities for banking. So then

0:29:14.000 --> 0:29:15.600
<v Speaker 4>the question is like what is the best way to

0:29:15.680 --> 0:29:18.600
<v Speaker 4>meet and empower all of them? That to me, that's

0:29:18.640 --> 0:29:21.560
<v Speaker 4>the real central question of merger policy. How do we

0:29:21.600 --> 0:29:26.200
<v Speaker 4>set up merger policy so that we're approving, we're considering

0:29:26.200 --> 0:29:28.440
<v Speaker 4>mergers that empower those communities.

0:29:28.520 --> 0:29:30.800
<v Speaker 1>Oh yes, so I believe there was some discussion of

0:29:30.920 --> 0:29:34.920
<v Speaker 1>updating the Merger Guidance post SVB to sort of get

0:29:35.000 --> 0:29:35.720
<v Speaker 1>at this question.

0:29:35.840 --> 0:29:36.840
<v Speaker 2>Is that still on the table.

0:29:36.920 --> 0:29:39.960
<v Speaker 4>Yes, absolutely, it's on the table and it's taking some time,

0:29:40.200 --> 0:29:43.160
<v Speaker 4>but it's because we want and we need to put

0:29:43.400 --> 0:29:46.600
<v Speaker 4>people communities at the center of that analysis. You know,

0:29:46.600 --> 0:29:48.800
<v Speaker 4>we've got statutory factors. We're kind of working through that,

0:29:48.880 --> 0:29:52.560
<v Speaker 4>and there's a lot of detail around that. But as

0:29:52.640 --> 0:29:54.960
<v Speaker 4>long as we have that long tail and as long

0:29:54.960 --> 0:29:57.480
<v Speaker 4>as the US economy keeps growing, you know, the banking

0:29:57.520 --> 0:30:00.479
<v Speaker 4>system has to grow with the US economy. So if

0:30:00.520 --> 0:30:02.560
<v Speaker 4>you were to just graph US GDP and the side

0:30:02.600 --> 0:30:05.120
<v Speaker 4>of the banking system, they pretty much match on top

0:30:05.160 --> 0:30:06.880
<v Speaker 4>of each other. So as long as the US economy

0:30:06.920 --> 0:30:10.120
<v Speaker 4>keeps growing and different parts of the economy grow, we

0:30:10.200 --> 0:30:12.320
<v Speaker 4>want and need the banking system to grow with that.

0:30:12.680 --> 0:30:14.880
<v Speaker 4>It's got to be safe, sound unfair. And this is

0:30:14.880 --> 0:30:17.400
<v Speaker 4>why I spend so much time on large banks, because

0:30:18.000 --> 0:30:21.520
<v Speaker 4>there are going to be more and more complex large

0:30:21.520 --> 0:30:24.080
<v Speaker 4>banks in the future. They need to be resilient, they

0:30:24.120 --> 0:30:26.720
<v Speaker 4>need to be resolvable and they need to be manageable,

0:30:27.160 --> 0:30:28.720
<v Speaker 4>and so we spend a lot of time like, let's

0:30:28.800 --> 0:30:31.320
<v Speaker 4>articulate that so we don't get back into the pre

0:30:31.440 --> 0:30:34.360
<v Speaker 4>two thousand and eight pickle where you've got large banks

0:30:34.360 --> 0:30:38.560
<v Speaker 4>that are not either resilient, resolvable, or manageable. That's not

0:30:38.600 --> 0:30:39.640
<v Speaker 4>a place that we can afford to be.

0:30:39.920 --> 0:30:43.520
<v Speaker 1>So, since we're talking sort of existential questions for the

0:30:43.600 --> 0:30:46.000
<v Speaker 1>US banking landscape, one of the things that's been on

0:30:46.040 --> 0:30:48.680
<v Speaker 1>my mind, especially in the context of fintech and I

0:30:48.680 --> 0:30:52.520
<v Speaker 1>guess payments, innovation and things like that, there is still

0:30:53.400 --> 0:30:57.719
<v Speaker 1>a difference in the US between commerce and banking, and

0:30:57.800 --> 0:31:00.320
<v Speaker 1>it's sort of like never the Twain show me. Every

0:31:00.360 --> 0:31:02.720
<v Speaker 1>once in a while there's a rumor that like Walmart

0:31:02.880 --> 0:31:04.760
<v Speaker 1>wants to start a bank or something, and then it

0:31:04.760 --> 0:31:08.040
<v Speaker 1>gets shot down because it's not allowed in the US.

0:31:08.480 --> 0:31:12.800
<v Speaker 1>But I kind of wonder, you know, post SVB, as

0:31:13.000 --> 0:31:17.200
<v Speaker 1>banks continue to be disrupted by new digital technology, there

0:31:17.240 --> 0:31:20.040
<v Speaker 1>are digital bank runs nowadays and things like that, would

0:31:20.040 --> 0:31:24.080
<v Speaker 1>there be room for a bank of Apple, for instance,

0:31:24.240 --> 0:31:26.160
<v Speaker 1>or a bank of Amazon, or even a bank of

0:31:26.160 --> 0:31:27.080
<v Speaker 1>Berkshire Hathaway.

0:31:27.080 --> 0:31:28.680
<v Speaker 2>I know it's not a tech company, but.

0:31:29.000 --> 0:31:32.280
<v Speaker 1>You know, these are companies with huge amounts of money.

0:31:32.640 --> 0:31:34.760
<v Speaker 1>Maybe it would be nice to have a really well

0:31:34.800 --> 0:31:37.560
<v Speaker 1>capitalized bank as interest rates are going up.

0:31:38.000 --> 0:31:41.680
<v Speaker 4>So this is probably you need an entire other podcast

0:31:41.680 --> 0:31:45.160
<v Speaker 4>to talk about this. It's a fascinating question. The history

0:31:45.400 --> 0:31:48.760
<v Speaker 4>of the blending of banking and commerce is not a

0:31:48.760 --> 0:31:51.320
<v Speaker 4>good one. In generally the history.

0:31:51.080 --> 0:31:54.560
<v Speaker 1>Is wasn't Well's Fargo as stagecoach operation that seemed to

0:31:54.560 --> 0:31:54.880
<v Speaker 1>work out?

0:31:54.920 --> 0:31:55.280
<v Speaker 2>Okay?

0:31:55.760 --> 0:31:57.680
<v Speaker 4>Where we have I mean, if you go back to

0:31:57.680 --> 0:31:58.440
<v Speaker 4>two thousand and eight.

0:31:58.400 --> 0:32:01.120
<v Speaker 2>Right, like you'd say, like the facetious but you're right, But.

0:32:01.040 --> 0:32:04.400
<v Speaker 4>There we have lots and lots of examples where we said, hey,

0:32:04.760 --> 0:32:06.959
<v Speaker 4>wouldn't it be great if we took these things and

0:32:07.000 --> 0:32:08.600
<v Speaker 4>like you take the best of each and it's like,

0:32:08.600 --> 0:32:09.920
<v Speaker 4>you know, the chocolate and the peanut buttery, you put

0:32:09.960 --> 0:32:12.680
<v Speaker 4>them together and we get something better. And in almost

0:32:12.680 --> 0:32:15.200
<v Speaker 4>every single case I can think of, it's ended quite badly.

0:32:15.920 --> 0:32:18.160
<v Speaker 4>And there's two problems that are associated with that which

0:32:18.200 --> 0:32:21.080
<v Speaker 4>we really have to be careful of. One is there

0:32:21.160 --> 0:32:25.040
<v Speaker 4>does become an unusually high concentration of power market power,

0:32:25.080 --> 0:32:28.000
<v Speaker 4>because they reinforce, the banking and the commerce reinforce each

0:32:28.000 --> 0:32:31.480
<v Speaker 4>other in the way that's quite unfair and that can

0:32:31.560 --> 0:32:33.360
<v Speaker 4>have you know, a lot of negative impacts. So that's

0:32:33.360 --> 0:32:36.080
<v Speaker 4>one thing to be attentive to. And the other is

0:32:36.480 --> 0:32:40.880
<v Speaker 4>the opportunities for problems go up because now how commerce

0:32:40.920 --> 0:32:44.120
<v Speaker 4>goes impacts banking. And again that's not a safety and

0:32:44.200 --> 0:32:47.320
<v Speaker 4>sound that's that's outside of the zone of how safety

0:32:47.320 --> 0:32:49.400
<v Speaker 4>and sound is a supervision a typical thing goes. So

0:32:49.440 --> 0:32:53.520
<v Speaker 4>that's that's why we've had this separation. I do think today,

0:32:54.120 --> 0:32:56.680
<v Speaker 4>going forward, this is going to become a bigger and

0:32:56.680 --> 0:33:01.600
<v Speaker 4>bigger question to deal with because payments by itself is commerce.

0:33:02.560 --> 0:33:05.000
<v Speaker 4>When you start to put it next to things that

0:33:05.040 --> 0:33:10.160
<v Speaker 4>are adjacent to payments, lending, credit deposits, savings, et cetera,

0:33:10.600 --> 0:33:14.160
<v Speaker 4>that's banking, and this is this is a very fluid

0:33:15.200 --> 0:33:16.880
<v Speaker 4>you know, rarely does the payments company say we're just

0:33:16.960 --> 0:33:18.840
<v Speaker 4>going to do payments and that's all we're gonna do forever.

0:33:18.960 --> 0:33:20.760
<v Speaker 4>At some point they say, hey, wouldn't it be great

0:33:20.800 --> 0:33:22.680
<v Speaker 4>if we just did a little bit of you know,

0:33:22.720 --> 0:33:24.240
<v Speaker 4>paid a little bit of yield on this on this

0:33:24.320 --> 0:33:26.080
<v Speaker 4>cash that's sitting with us. Wouldn't be great we did

0:33:26.240 --> 0:33:26.920
<v Speaker 4>did some lending.

0:33:27.520 --> 0:33:30.320
<v Speaker 1>It's a slippery slope to being a bank. Yes, happened

0:33:30.360 --> 0:33:30.840
<v Speaker 1>to everyone.

0:33:31.000 --> 0:33:33.760
<v Speaker 4>Yes, and so we want to be really really attentive

0:33:33.760 --> 0:33:35.720
<v Speaker 4>to that. And look, if there's a way to do

0:33:35.800 --> 0:33:37.800
<v Speaker 4>it that's going to be safe, sound and unfair without

0:33:37.800 --> 0:33:41.959
<v Speaker 4>financial stability concerns, I'm open, like, let's talk about that.

0:33:42.440 --> 0:33:44.080
<v Speaker 4>But history has proven that that's.

0:33:43.960 --> 0:33:46.440
<v Speaker 1>That's tough to do, all right, Michael Sue, thank you

0:33:46.520 --> 0:33:48.480
<v Speaker 1>so much for coming on atholet's really appreciate it.

0:33:48.520 --> 0:33:49.440
<v Speaker 4>Thanks so much for having me.

0:34:02.400 --> 0:34:05.880
<v Speaker 1>All right, Well, that was the live conversation recorded at

0:34:05.880 --> 0:34:10.239
<v Speaker 1>Money twenty twenty with the OCCS. Michael Sue, Joe, do

0:34:10.280 --> 0:34:12.080
<v Speaker 1>you regret not going Tracy?

0:34:12.160 --> 0:34:15.840
<v Speaker 3>You're so capable as a host, That is my conclusion.

0:34:15.880 --> 0:34:18.080
<v Speaker 3>You're so capable as a host you don't even need me.

0:34:18.160 --> 0:34:20.160
<v Speaker 3>And I think next year we're going to be sending

0:34:20.200 --> 0:34:22.160
<v Speaker 3>you on the road for a lot of solo trips

0:34:22.280 --> 0:34:23.279
<v Speaker 3>and I'll just hang back in.

0:34:23.280 --> 0:34:26.640
<v Speaker 1>Tweet you flatter me to make yourself feel less guilty.

0:34:26.760 --> 0:34:27.520
<v Speaker 2>But that's okay.

0:34:28.040 --> 0:34:31.120
<v Speaker 1>I thought it was a super interesting conversation. Michael's a

0:34:31.120 --> 0:34:34.040
<v Speaker 1>big All Thoughts fan, which was kind of fun, and

0:34:34.200 --> 0:34:37.239
<v Speaker 1>maybe we inspired him with the supply chain analogy.

0:34:37.280 --> 0:34:38.520
<v Speaker 2>I hope so me too.

0:34:38.520 --> 0:34:39.319
<v Speaker 4>I love it all right?

0:34:39.360 --> 0:34:40.040
<v Speaker 2>Shall we leave it there?

0:34:40.120 --> 0:34:40.799
<v Speaker 3>Let's leave it there.

0:34:41.080 --> 0:34:43.960
<v Speaker 1>This has been another episode of the All Thoughts podcast.

0:34:44.080 --> 0:34:47.000
<v Speaker 1>I'm Tracy Alloway. You can follow me at Tracy Alloway.

0:34:47.239 --> 0:34:50.120
<v Speaker 3>And I'm Joe Wisenthal. You can follow me at The Stalwart.

0:34:50.400 --> 0:34:54.000
<v Speaker 3>Follow our producer Carman Rodriguez at Carman armand dash Ol

0:34:54.000 --> 0:34:57.080
<v Speaker 3>Bennett at Dashbot and kel Brooks at kel Brooks. And

0:34:57.160 --> 0:35:00.760
<v Speaker 3>thank you to our producer Moses Ondam. From our Odlots content,

0:35:00.840 --> 0:35:03.480
<v Speaker 3>go to bloomberg dot com slash odd Lots, where we

0:35:03.520 --> 0:35:06.160
<v Speaker 3>have a blog, a transcript, and a weekly newsletter that

0:35:06.239 --> 0:35:09.440
<v Speaker 3>comes out every Friday. And check out the Odlogs Discord

0:35:09.480 --> 0:35:13.040
<v Speaker 3>Discord dot gg, slash odd Logs chat with fellow listeners

0:35:13.160 --> 0:35:14.160
<v Speaker 3>twenty four to seven.

0:35:14.200 --> 0:35:17.000
<v Speaker 1>And if you enjoy odd Lots, if you want us

0:35:17.120 --> 0:35:19.480
<v Speaker 1>both to go back to Las Vegas at some point,

0:35:19.680 --> 0:35:22.800
<v Speaker 1>then please leave us a positive review on your favorite

0:35:22.800 --> 0:35:23.880
<v Speaker 1>podcast platform.

0:35:23.960 --> 0:35:24.720
<v Speaker 2>Thanks for listening.