The Role of Marketing and RESPA in a One-Stop Shop World

Consumers increasingly demand one-stop shop homeownership. How does RESPA evolve as this consumer demand mortgage gives rise to mortgage and real estate joint ventures, as well as mortgage firms integrating multiple homeownership services into one experience? Does RESPA actually keep consumer costs lower? Or is it making prices higher by requiring every provider to incur their own customer acquisition cost? Is there a place for responsible one-stop models in the modern housing market?

Transcription:

Kristin Messerli: (00:07)

All right. Thank you guys so much for joining us today. I am really excited about this panel, I have three incredible panelists here. We have Mitch Kider who I'm sure you all know. He is the chairman and managing partner at Weiner Brodsky Kider PC. We also have two incredible leaders represented from both midsize and large lenders, starting with Juan Rodas, recently named EVP of On Q and Bill Dallas, president of Finance of America. All three of these panelists are brilliant business leaders who have grown lender market share through creative and compliant marketing. So I am so happy to have you all here to share your expertise.

Kristin Messerli: (00:48)

So I want to kick us off first by having Mitch share a little bit of background. In looking at the growing trend to become a one stop shop, many mortgage companies are now offering multiple ancillary services under one roof, such as mortgage title, appraisal, real estate, et cetera. What is the interplay between the history of RESPA's affiliated business arrangement provision and a company's ability to provide multiple services and can all firms do this or just big firms?

Mitch Kider: (01:21)

Sure. So let me start off by thanking you, Kristen, for putting this panel together. This is a great panel. And the answer to your question goes along these particular lines, the debate about whether or not settlement services like a mortgage lender or real estate company, whether or not they can or should, be able to provide a one stop shop. That's a debate that's actually been going on for more than 40 years. It's been going on for just about as long as RESPA has been on the books. And RESPA has been on the books for almost 48 years now. It was enacted in 1974 and the problem comes along these lines. It's all about section 8 of RESPA. No one shall give, no one shall accept a thing of value in exchange for the referral to settlement services pursuant to an agreement. So when you think about that, the statute that was written in 74 would not allow one stopshopping.

Mitch Kider: (02:18)

You couldn't get it done because if you had an affiliated title company, if you had an affiliated mortgage company or an affiliated realtor, they could get nothing back from making a referral. And of course, they're going to get something back because if they're in the same corporate family, there's going to be a return on the ownership interest. So, you know, around 1980, there were a bunch of big real estate brokerage operations, ERA an old line real estate broker led the charge along these particular lines. And they said, you know, we want to get into the other businesses as well. It's not enough just be a real estate broker and just have my real estate agents over here. We think we need to get mortgage. We think we need to get title and other ancillary services that are settlement services. But the problem that they ran into is they couldn't do it because of section 8 of RESPA.

Mitch Kider: (03:10)

And that started this really big debate. Can you have one stop shopping? Can you affiliate with others, you know, in the industry itself. And there were two schools of thought in this debate and the debate went on for about three years to tell you the truth. And there were two schools of thought, one school of thought said, and this is all about what's best for the consumer. One school of thought said what's best for the consumer is you have to put each settlement provider, each industry group in a separate silo, okay? You have to let them compete for their own business, separate and apart from other settlement service business itself. And they believe that would keep costs lower. The other group said, no, absolutely not. Synergy. You want synergy there. It will create efficiency. So if you allow a corporate entity or an overall under a corporate umbrella, if you allow different settlement services to be provided under that corporate umbrella, you are going to get synergy.

Mitch Kider: (04:12)

It's going to create efficiency. And ultimately, ultimately the consumer is going to be the beneficiary cause it's going to be less expensive to produce the entire transaction itself. Congress in 1983, actually agreed with that position, said, no, one stop shopping is actually a good thing. It's a good thing. And we think consumers will benefit from that particular synergy. So they passed what was known at the time is the control business amendment. Now control businesses are known as affiliated businesses and they said, I'll tell you why. We're just going to put some restrictions here. Okay? You can have affiliated businesses. You can offer all the products, all the products in the world that your affiliates otherwise have and make referrals to them. As long as you give 'em a disclosure and you tell 'em the nature of your affiliation. You tell 'em that they're not required to use them.

Mitch Kider: (05:06)

They can go elsewhere if they don't want to use those guys. And the only thing that they can get back is a return on their ownership interest. So they can't pay you a referral fee, but since you're in the same corporate family, if there are dividends that go up, you can get back a return on your ownership interest itself. So that was the earliest stage under RESPA, where a policy determination was made and it was made by Congress that said one stop shopping is actually a good thing. And what they did with the affiliated business provisions and amendment is they allowed that one stop shopping. Now, there were a lot of smaller players that didn't want that to happen at all because they figured they were going to go ahead and they were going to compete with big players that will push the prices down either they won't be able to afford it or otherwise not otherwise let them in the door.

Mitch Kider: (05:59)

Although there's something called packaging with other settlement service providers that could have worked for them as well, but they were very, very resistant to it. And the truth of the matter is if you ask who benefited most? Was it a large firm? Was it a small firm? The small firms that benefit most along these particular lines? It was really the large corporate families, the ones that had the ability to put together these different settlement service providers, that's who benefited the most. But the last thing I will say about that is smaller companies learned to deal with that. And they did it in the way of joint ventures. So they would find other title companies, they would find other insurance operations, and they would joint venture their own as well. The issue though, the issue is it's not the kind of one stop shopping that the industry is really looking for. It's not smooth, it's not efficient. And it's because RESPA really stands in the way

Kristin Messerli: (07:04)

Thank you. That brings me to my next question. That is from a consumer perspective, consumers really don't know or care about RESPA. What they care about is ease of use and efficiency. And like you said, cost, so I want to pass this over to hear from Juan and Bill. Let's start with you, Juan, other than mortgage, what services do consumers seem to want the most from you as a lender? And do you provide a one stop shop experience for your customers, even if all of those services are not under one roof?

Juan Rodas: (07:39)

Thank you for having me. So absolutely. So what the consumers are looking for ultimately is when they're dealing with a realtor, or when they're dealing with the builder or title company, that's definitely something that ultimately comes up. They find ourselves in an environment where they have to talk and communicate to different modes of communication, whether it's email or different portals. And so they're really looking for like a centralized experience. And a lot of interesting things that come up from consumers is ultimately while yes, they want the cheapest cost, if the cheapest cost is them having to research everything to the nth degree, ultimately what they're taking into consideration is their own time, basically, that they're wasting in doing this. Right. And so I think when you think of something like RESPA, it doesn't take that into consideration, right?

Juan Rodas: (08:27)

It's purely focused on what's the cheapest cost kind of one for one variable with consumers and doesn't take into consideration the weeks and energy that they have to spend in being able to get that. I think the other kind of issue that comes up with consumers is again, kind of the centralized location to access all of these services. Back when RESPA was put into place 40 plus years ago, they didn't have the technology that we have today. And I don't even think that that was contemplated. And so now, as we're headed more towards a digital experience, you start to be able to create somewhat of a commonality between different services, especially if you can control them from a joint venture perspective and you can put your own proprietary technology behind it. The one thing now that ultimately is going to remain as a challenge is anything that's like federally regulated or state regulated, where it doesn't matter whether we create a joint venture or not, there's certain technologies that we may not be able to tap into such as things with the insurers or something with individual counties.

Juan Rodas: (09:30)

Until those things start to be really have some commonality between them, we're going to continue to have those types of junk.

Kristin Messerli: (09:39)

Well, that's great. Bill, I know you have a lot to say on this, so I'll pass it to you.

Bill Dallas: (09:45)

Yeah. I mean, our model's different at Finance of America a bit, you know, we believe you have to meet the customer where the customer really rolls, how and where they roll. I think what Juan's saying is exactly right with respect to the products and services that are inside the mortgage business and Mitch and I have been doing this since the RESPA. So we sort of watched all this happen and we call it physical today. This is sort of physical and digital. So we believe that you have to have human touch and you have to meet the consumer with a little bit of a digital experience, but I'm going to expand it a bit. It is very difficult for an independent mortgage bank, given the compliance rules, to be compliant in marketing, the opt in, opt out, whether it's text, no matter how you contact the customer.

Bill Dallas: (10:35)

And, with compensation rules that came out of RESPA as a result of how you compliantly pay loan officers and people who are connecting, I will say this, that the consumer, I mean, we have a list of 34 products and services at Finance of America that we could offer, right? And none of title and escrow and those things aren't even on that list, right? We offer those, it's a lifetime value loan, personal loan and purchase. It's a student loan, it's insurance, a credit card, a guaranteed purchase go down to the stuff at the bottom, right? Home maintenance record, appliance warranties, home search, maintenance fund. I can tell you this as a consumer buying a home, when I move into that house, I want a one stop shop helper because it's a pain in the app to actually get the, from the electric.

Bill Dallas: (11:29)

You know, you want somebody, whether it's your realtor or somebody else to help you try to bring together all these things as you set up your new household or as you move. So I think maybe the thing, Juan and I were talking a little bit before, I mean, compensation. People do what they're compensated to do. And one of the challenges is really how do you drive compensation for other products and services through an industry that really thinks it offers one, a mortgage loan, right? So my view is that, and when you call those 34 products and services down, we came out with really a couple big ones that, we sort of said, the consumer wants best solution. They want a digital home. They want to know, they want to be guided and informed because you could go down the path of loyalty rewards or other things that you really wanted to do.

Bill Dallas: (12:26)

But matching products and services to a consumer is difficult. And so at Finance of America, we actually have synthetically created this by, we have a renovation business called FOHI Finance of America Home Improvement. We have Faco, which is, what I would call LLCs and flipping that we finance. You have forward, right, which is the standard that's where Juan and I sort of spend most of our time, we have reverse, which is a whole separate product line and an almost separate company. And then we have Incenter, which provides fulfillment services and bringing that together, even that with all those things is complex.

Kristin Messerli: (13:12)

Yeah. That's huge. I recently bought a home and was desperate wanting all of these services under one roof, but, and I want to get into the role of technology here in just a second, but before I do, I want to pass it back to Mitch, and just hear your perspective on in our current regulatory environment is a one-stop shop experience even advisable if all services aren't an one roof? And in your opinion, is it an obstacle to one stop shopping?

Mitch Kider: (13:42)

So is it advisable? And, you know, I would say that one stop shop is advisable. Okay. Because it's what consumers want. I'm not sure it's what regulators want. In fact, I think regulators probably don't want it today. But it's what consumers want and it can be done, even if you're using outside parties to make this a one stop shop. It's called packaging, you package together with other settlement service providers, you provide discounts. And I think the consumer ultimately will benefit from that. Juan had mentioned that the goal of RESPA, and he's correct is to get the cheapest cost to the consumer itself. But there is a big outstanding question as to whether or not RESPA really is getting the cheapest costs. And my guess is it's doing just the opposite quite frankly, for a number of different reasons, different settlement service providers having their own acquisition costs and, things along those particular lines.

Mitch Kider: (14:41)

So, can you do a one stop shop? Is it advisable? Yes. Is it a good idea to do it through packaging? Yes, but it's really difficult. And it's really difficult because of RESPA and RESPA gives you a lot of difficulties. There are a lot of hoops, a lot of obstacles. You've got to jump around to make something like this happen. And to add insult to injury, RESPA is somewhat ambiguous in this particular area. We haven't had guidance in a very, very long time. So it poses risks and lenders and other settlement service providers don't know what to make of those risks. It's hard to quantify those risks. You havea lack of guidance, you have some enforcement, but somewhat sporadic, but that doesn't mean that you can't be the next one that gets examined along those particular lines. Packaging together involves referrals. And Section 8 of RESPA is an anti referral fee provision. So RESPA is absolutely an obstacle to a smooth and efficient system for one stop shopping, which is what consumers want. And if I had to bet, I think it's what consumers would get the best price on as well.

Bill Dallas: (16:06)

I would say I'm going to jump into, I said, I mean, we believe, and Juan and I came together, we believe that consumers really deserve access to innovative, flexible lending solutions. It makes sense for a modern type borrower, right. And not one size fits all. Also with the movement that you've got to front, I think in the world, which is great about removing racial bias and removing bias and lending and all those, you could innovate appraisals, you could innovate underwriting, you could innovate things that are, have been around for a long time to offer solutions that really mix education, innovation, products. All of that drives, I think the consumer and plays well. All of our consumers say the same thing and they want to deal with somebody who they trust. Right. Generally like Kristen, when you're talking about it, you're talking about right when you buy a home or you own a home, it's your realtor, it's your loan officer, generally speaking, right? And then it becomes this host of cast of characters who invade your property and look at things and want to try to do stuff. And, you really need a quarterback or you need somebody who's there to help you make informed decisions about the mortgage that you're borrowing. And it's the most important decision that people make. So I think Juan, I throw it back to you. I mean, for you and I, we live in this environment every day. It sort of makes me mad, you know, when I have other competitors coming from other industries, not as regulated. Right. And they sort of said, ah, casually, come get a mortgage. Cause I can give you a student loan too, or I did this. Not even possible. Right. Cause when you move into our world, you better strap on your ,compliant pants and bring it on because it's a tough deal every day.

Juan Rodas: (18:07)

Absolutely. I mean I couldn't agree more. I mean, look, I think the reasoning behind all the rules that have been created over the many years, including fair lending and UDAAP and LO compensational the kind of the whole package of that with RESPA is kind of what creates ultimately the challenges and for consumers. they just, they don't know, or again, care is probably a strong word, but they're ultimately looking for the experience and they're looking for the cost. And when you put together these types of regulations and it's kind of a one size fits all, you know, that's what creates the challenges and to talk about kind of like what Bill was touching on, in other industries, I mean, I was just shopping recently online yesterday for, Christmas gifts and I consistently in multiple different websites, it would be, you know, here's the price, but here's the price if you get it online but if you were to go to the store, you're paying substantially more.

Juan Rodas: (19:05)

And, if you were to ask a consumer, Hey, do you want to pay a thousand dollars more to just because you're gonna come into an office to deliver a form or talk to a sales rep. I highly doubt that that's what they want to do, but they don't understand that there's a difference in how the compensation works out, whether it's through a consumer direct or distributed retail, and it doesn't allow for that flexibility. And again, when you align that with RESPA issues, et cetera, you just kind of, it's just like an overwhelming challenge that ends up being created for the consumer and to take it a step further, once you go down the digital path of doing things, we can go down as far as we want on digital. But ultimately, if these, all these rules are not reevaluated, there will be a limit on what can be done. And then the question becomes, are the lenders going to invest and continue to invest in all of these technologies if at some point, no matter what you do, you continue to be heavily regulated. So now not only are you now bearing the cost of additional for technology. You're continuing the bear to cost of compliance risk.

Mitch Kider: (20:12)

Yeah. Well, look, this law RESPA was passed in 1974. Clearly, clearly it needs to be revised. It actually needed to be revised for a very long time. The act of purchasing a home is very stressful for most people in this country. It's a very tough thing go through. And yet I think the law makes it more stressful than it otherwise needs to be. I think that's the problem. What a consumer really wants is they want a point of contact and then they want to say, gimme everything. Okay. They don't want to be ripped off. They want to get the best cost. That's absolutely right. But I would actually even put above that, okay, ease of transaction. Okay. Leave me at peace over here. So I know everything's smooth and I'm closing on this and there aren't going to be problems or issues along those particular lines.

Mitch Kider: (21:08)

Don't make me go chase all these various settlement services providers around most of whom I don't even understand what they do or why they're doing it in this transaction. And that's what RESPA makes you do today. Okay. And so it's got to change along those particular lines and technology is going to change it. Quite frankly, it's going to change it dramatically and you can see it happening. For a long time, RESPA has been antiquated for a very long time and it's been stagnant. You haven't seen very many changes to it at all, but technology really has changed. And there are reasons why it took time for technology to catch up to this particular industry. Not the least is what happened in 2007, 2008. I mean, everything just got set backwards quite frankly, and the regulatory scheme took effect and nothing was gonna happen by way of technology. But it's happening now, and it's there now. And that's why we're talking about this right now. We've got all of these different players utilizing both people, it's physical, both people and technology in ways that were never possibly contemplated back in 1974. So there's got to be some revision that has to take place.

Juan Rodas: (22:28)

Do you think, real quick Mitch, do you think that the reasoning that this is coming up so much today is because we're going digital. Like, let's just say we never technology remained the way it was 40 years ago. Do you think that this conversation would be coming back up or is it more...

Mitch Kider: (22:43)

I think technology has a lot to do with it because technology really levels and smooths that transaction. It enables you to go through without any bumps in the roads. So I think technology is a primary driver of that. And why we're talking about this now.

Bill Dallas: (23:07)

I think too, one, I mean, so what we see in the personal loan business, right, or renovation business is there's really very little underwriting that sort of goes on. I think if we could apply the same disciplines that we apply in the mortgage business to other products, I think the customer would be better served because I look at it as an escalator where when I started in the business, the customer sort of talked about wanting a one stop shop and a relationship and all of that. And you had S&Ls and you had banks that were offering portfolio services and portfolio loans, and it seemed to work. Then there became this best of breed. So they started going down the other side of the escalator, wanting products and services that weren't just from their, beholden S&L or their relationship, they wanted to go out and explore.

Bill Dallas: (24:03)

And if you think of about it, we're sort of back on the other escalator again, where you sort of want bundled services. If you knew that those services were fair, equal, better priced because of the complexity of what you're trying to do. Yeah. So I think, I think for us, it's a difference in, so the whole approach, we call it a transformation at Finance of America, because it's really, instead of being a product-led 30-year fixed government-oriented business, we are a proprietary business of products and services that we offer. And we can offer our guidelines, our services, and try to move to be more customer-centric. Right. Which I think because our customers' telling us that they want us to be involved in servicing. I think paying a mortgage monthly, is building a savings account.

Bill Dallas: (25:08)

And we have to teach our, we call our advisors equity advisors because I want them to spend a little bit more time helping the customer understand you can't just allow property appreciation to drive everything. You have to figure out how to use your equity wisely. And then how do you pay it differently, more aggressively to save interest, right? And do the other things that you want to do. But by unbundling this and allowing consumers to go to different providers for credit cards, pay now, pay later, consumer loan. I get a consumer loan over here. I get, I mean, I have got scads and you know this Juan, we've got scads of consumers. We've got piles of debt that comes to roost every time we underwrite them. Because we say, oh my God, how do you pay this? And then we consolidate that.

Bill Dallas: (26:03)

We send them on their way. And then what, within two years the recidivist is back and you've got, so it's almost like we need to put 'em in a 12 step program so that they can figure out that this is their money. This is their equity, and they have to spend it wisely, but I'm not so sure if I'm a regulator that by allowing them to go out and borrow all these different places that it's really sustainable and good for consumers because ultimately, you know, we sort of mortgage people, we sort of make it when you want to own a home, this debt has to go away. You have to be at this level. Right.

Juan Rodas: (26:42)

Yeah. I mean, they can

Mitch Kider: (26:44)

Go ahead.

Juan Rodas: (26:44)

I'm sorry. I was going to say they can sit there and get denied for a home loan and then turn around and go get a car loan within the same day for sometimes the cost of what a home is. And if they have bad credit, you know, substantially high rates, but essentially no regulation. And often times consumers are scratching their head. You know, why can I buy a $100,000, $150,000 car and walk out within the same day, but I can't buy a house that costs on or around the same, let's just say. And on top of that. I mean, sure. It's a 30 year mortgage, but realistically speaking, they're only staying on average in that house for call it eight years. Right. And, we have 6, 7, 8 year loans for cars. So it's just an interesting dynamic.

Bill Dallas: (27:28)

And I was going to even go, so Mitch and I, we could go probably down a whole different path right now. Let's go stay with regulation. What do we call ourselves? Cause if you call yourself a debt manager, can't do that. You're not really a debt manager. And if you call yourself a financial advisor, you're not really a financial advisor, you can't do that. So what are we?

Bill Dallas: (27:49)

We call ourselves equity advisors, right. Because that I think is compliant and I think it's probably fair. It might be exactly what we do.

Mitch Kider: (28:03)

I think it's the right description. It is exactly what you do. You are advising on equity. That is absolutely correct. That is

Kristin Messerli: (28:11)

I was just going to say, I recently did a study with the MBA and National MI of a thousand recent homebuyers. And these are in the next gen audience. And only one in three, said that they trusted lenders. So two in three, they distrusted lenders. And one in five said they didn't understand a single step in the home buying process. And these are people that are actually buying homes in our generation. And, so I feel like, and me recently going through this and having grown up in the industry, I should know, but I felt such extreme lack of confidence and total distrust for, and chaos, but I think that technology is a huge solution to that. And once I do find a lender that I trust then it makes all the difference in the world, but I want all of that to be under

Bill Dallas: (29:04)

Kristin, I have five millennials, right. And I saw, Nicole Friedman had a good article that I reposted yesterday from the Journal on this movement in millennials buying. And we find in our focus groups and with even my five kids buying houses, you'd think they grow up with a mortgage person that they'd understand what we do and anything else, they had zero knowledge of what they were doing. Right. And, oh, by the way, it's probably the maturation for a parent. It's probably the quickest maturation process when you have to figure out where the water shutoff valve is, and you have to go out and plow your own driveway. Totally. And I mean, it's like, it was like, perfect. But to your point, it is very difficult I think to understand this is a very complex and high, you have to, that's why we say our advisors have to really help people make informed decisions, but like you said, they have to trust us. And so trust is a two way street and they have to know they're getting a good deal. And there's scads of information that is available to people yet getting it pointed to help, you know, Kristen buy that house and make sure she got a good deal and all of that's really our job.

Mitch Kider: (30:27)

And let's bring that back to one stop shopping. Isn't it easier to educate? Isn't it easier to learn if you have that mentor, if you have that individual you are working with and walking you through all of those various products

Bill Dallas: (30:40)

That's yeah.

Mitch Kider: (30:41)

I mean,

Bill Dallas: (30:43)

Yeah. Do you really think online means like online learning? I have a private school that I started in California, a big time private school. COVID is very difficult. Students, some students learn online well, most students want a physical teacher to actually help them with the process. So that they could learn. And I think it's still proven that the combination of those two probably work, right?

Mitch Kider: (31:13)

Yeah. Yeah.

Kristin Messerli: (31:15)

To close this out here, I want to think about where we're headed and Mitch, do you think that the, and anyone can jump in here, but with under the current CFPB leadership, will that advance or slow the modernization of RESPA?

Bill Dallas: (31:34)

But Mitch's answering that

Mitch Kider: (31:35)

Yeah. I mean, listen, listen, I don't want to bash the current leadership, but the answer is it's going to slow It, it absolutely is going slower. At the end of the Kraninger administration at the CFPB, she called together a task force of many interested players to say what should happen with RESPA. And that task force at the beginning of this year, finally concluded and issued its report. And basically it's report is all about one stop shopping. It's about packaging, it's about bundling together. And, this CFPB has no interest in that, none whatsoever. And so, you know, I would be hopeful that they would listen, that they would learn and they'd understand that, you know, this is an industry that's changing, but products are changing, the dynamics are changing, the people. The consumers are changing as well. And so the regulatory environment needs to change along with that. Hopefully they'll get there. But if I had to guess just based on what I've seen today, I don't think so. I don't think it's going to happen.

Kristin Messerli: (32:42)

Well, I know that we could talk about this for hours and it's been really interesting hearing you guys talk even leading up to the panel. But I want to close this out. Any last words that you guys want to share or thoughts on kind of the future of marketing in the digital environment under RESPA

Bill Dallas: (33:02)

Juan I'll let you go first.

Juan Rodas: (33:04)

Yeah. I mean, look, I guess I'll just reinforce what I've kind of said before. I think finding the commonality, especially in technologies and whether it's open marketplaces or whatever it is, that's going to be kind of the path to the future in my opinion as the digital process continues, that will challenge the rules that we have today. And I wholeheartedly believe that it's holding us back for sure.

Bill Dallas: (33:31)

And I think we're about to pivot, right? The industry is in, you know, we've had a period of, I mean, I've been in it long enough to watch a mortgage business where interest rates drop. We've never been at the nadir of what is the lowest point of interest rates? I started, it was 20; today, it's probably bottomed out at two right? Now rates are going to potentially go up. That will cause change in the marketplace. We've actually at Finance of America this year. The whole thing is dedicated on pivot, right? And I think you're going to have to pivot to products and services and bundling and figure stuff out. And I think we've had great success, we've had an incredible run and with great success, I think comes great responsibility. And I think our industry, which is coming off what Mitch said, the heels of 07 and 08 where trust.

Bill Dallas: (34:28)

You know there was all kinds of mistrust coming out of that. Today you're looking at an industry that has created, I think, a asset for American people that is really important. And you watch the time that it's given on media and you watch how people are treating it. it is probably the most important asset class. And the No. 1 Issue I think going forward is going to be affordable housing. It's the biggest social issue, we have to solve it and we have to do more. So, it'll be a big pivot because you're not going to have refinances at the volume to just sit down and relax on. You're going to have to actually work. So it's going to be interesting.

Kristin Messerli: (35:13)

Definitely. Any last words, Mitch?

Mitch Kider: (35:16)

So I agree with all of that. I guess what I would say is despite regulatory inaction and despite the regulatory hurdles that are there, we are in this industry in a period of transition and it's not going to move backwards. It may not move forward as quickly as it would with some regulatory assistance or regulatory relief, but it's going to move forward. And I think that you're going to see more and more of one stop shopping concepts coming up, people are going to crack the code. They're going to do what they can. They're going to be in compliance with the regulations. They're going to have to do up through a lot of hoops. It's still going to be more expensive and ultimately more expensive to the consumer than it otherwise needs to be. But I don't think we're going back this the year. I think it's been stagnant for a while and I think we're moving forward. And this is a transitory period right now. Things are going to change.

Kristin Messerli: (36:16)

Definitely. Okay. Well, thank you so much everyone for attending and thank you panelists for contributing really amazing thoughts.

Bill Dallas: (36:25)

Thank you. Happy holidays, everybody happy.