From the OCC's founding under Abraham Lincoln to its modern jousting with the opportunities and challenges of AI and fintech innovation, Acting Comptroller Michael Hsu covered a lot of ground at the 2023 Just Economy Conference.
NCRC Just Economy Conference 2023 — Recorded March 30, 2023
Acting Comptroller of the Currency Michael Hsu addresses 2023 Just Economy Conference.
Speakers: Michael Hsu, Acting Comptroller of the Currency; Jesse Van Tol, President & CEO, NCRC
NCRC video transcripts are produced by a third-party transcription service and may contain errors. They are lightly edited for style and clarity.
MICHAEL HSU: Thank you. I think that’s the first time I’ve walked out to Metallica. So I appreciate the walkup music, whoever picked that. That’s great. Takes me back to my high school days. So good morning. It’s bright and early. Thank you for inviting me to this year’s just economy conference. I’m really honored to be here to join you guys today to discuss what we are doing at the OCC to elevate fairness in banking.
First, though, I want and I need to say a few words about recent events. The OCC is focus is and continues to be the safety, soundness and fairness of the federal banking system. We are closely monitoring the market and conditions of the institutions we supervise. The banking system is sound and resilient, your money is safe. Banks have strong capital and liquidity. And the US government has the tools and the will to act to protect the system.
Given the events of the past several weeks, some might think it’s odd that as a bank regulator, I want to focus my remarks today on fairness. I do this with intention. Because it’s precisely during times like these, when the world is fixated on financial and systemic risks, that issues of fairness can get pushed to the bottom of the pile and ignored.
We saw this in response to the 2008 financial crisis. The deep prioritization of non financial risks, such as consumer protection, compliance and operational risk, delayed and may have worsened eventual reckonings, which took place years later, with great force and attention.
Those reckonings eroded trust in the banking system, much as the financial risks did earlier that year, we can learn from history and do better. We need to be able to walk and chew gum at the same time, maintain a laser focus on effective financial risk management and work to ensure fairness.
Today, I will share what we at the OCC are doing to meet our mission of not just ensuring a financially safe and sound federal banking system, but also ensuring that federally chartered banks provide fair access to financial services, treat customers fairly and comply with laws and regulations.
Since becoming Acting Comptroller in May of 2021, I’ve emphasized that persistent inequality can erode trust in banking because people who feel stuck or lack access to responsible affordable financial products and services may conclude that the banking service banking system is working against them rather than for them. This can compel consumers to turn to non banks, such as payday lenders, crypto platforms and fintechs, which often have less stringent safety and soundness requirements and Consumer Protection oversight and banks. Fairness is a core part of the OCCs mission and something I think about every day.
To some outsiders, it may seem like fairness sits in the shadow of financial safety and soundness, stepping out into the spotlight only during enforcement actions after high profile scandals when certain regulations are being adopted, but insiders know better. In 2016, then comptroller Tom curry established the compliance and Community Affairs Department, which built institutional muscle at the OCC to engage on fairness and compliance issues on equal terms to financial safety and soundness.
The legacy of that decision continues to be felt today with an OCC leadership. Tom Curry selected Grovetta Gardineer to head the department which includes compliance policy and compliance supervision functions. Grovetta today now serves as a senior deputy comptroller for bank supervision policy, which integrates fairness, compliance and safety and soundness policy. In addition, Beverly Cole, who then served as the Deputy comptroller for compliance supervision is now the senior deputy comptroller for midsize and community bank supervision, which oversees nearly 1000 banks. Today both Beverly and Grovetta serve as members of the OCC Executive Committee, which leads the agency fairness at the OCC is more about more than just people and leaders every five years, the OCC adopts and publishes an agency wide strategic plan.
The most recent strategic plan leans in on how financial services is evolving and prioritizes. Elevating fairness, noting as a goal that quote, the OCC has renewed focus on fairness, reinvigorates the agency’s mission and demonstrates leadership as the evolution of the banking system further integrates fairness with safety and soundness. Of course, actions matter most are people in our words must drive meaningful actions for us to have credibility and to be trusted on issues of fairness.
With this in mind, I’d like to share some examples that demonstrate the OCC is commitment to action and elevating and advancing fairness, especially for the financially vulnerable. Let me start with overdrafts. For the increasing number of people who feel like they’re living paycheck to paycheck. The maximum it’s expensive to before. It’s expensive to be poor, resonates. overdraft fees can be one of those expenses. Excuse me. At last year’s ABA annual meeting, I noticed that I was seeing a wide range of banks beginning to reexamine their overdraft practices, and that a significant number were contemplating are implementing meaningful pro consumer reforms.
My message to bankers was clear. Quote, you don’t want to be the last bank to update your overdraft program. This message was one that I repeated in other public settings as well as in private conversations with bankers. OCC examiner’s echoed that message and encourage bank management to review their existing overdraft programs to consider pro consumer reforms they might want to consider every bank is different and OCC examiner’s are uniquely positioned to combine in depth bank specific knowledge with a broader national perspective on leading and lagging practices. overdrafts can present a variety of risks including compliance operational reputational risks.
An important risk is the risk of engaging in unfair or deceptive acts and practices commonly known as UDAAP, which is prohibited by section five of the FTC Act. Under that law, a practice may be deceptive. If there is a representation, omission, act or practice that is likely to mislead. It is deceptive from the perspective of a reasonable consumer and its material. Practice may be unfair, if it causes substantial cause consumer injury that is not outweighed by benefits to the consumer or competition. And, importantly, the injury cannot be reasonably avoided.
More than a decade ago, the Dodd Frank act at a new authority that reinforces these legal requirements while also adding a prohibition on abusive acts or practices. Last year, the CFPB which has rulemaking authority over you that cited unfair, deceptive and abusive practices associated with so called surprise overdraft phase. In addition, the Federal Reserve and FDIC have noted the risk of violating udev in connection with certain overdraft practices. Importantly, not all overdraft practices are equally risky, so some precision here is warranted. From a bank regulators perspective, we’ve identified two practices in particular, that present heightened risk, authorize positive, settle negative, a PSN and represent the phrase authorized positive settled negative refers to the practice of assessing overdraft fees on debit card transactions that are authorized when consumers available balance is positive, but later post to the account when the available balance is negative.
So this happens, for example, when customers swipe their debit card after checking their balance on their banking app, which indicates that they have enough money for the transaction. However, when the bank deducts the amount of that transaction from the customer’s balance, the bank does not actually reserve the funds to use for settlement. So subsequently, different transactions in the customer’s account may be authorized or may settle. So when the initial debit card transaction finally settles, there are no longer sufficient funds in the bank assesses an overdraft fee.
With APs and transactions, consumers believe they have enough money in their account to pay for something only to find out later that they don’t and that are charged a fee. Hence the surprise. The compliance risk with APS and transactions is elevated, especially as it relates to you dab. For example, even when disclosures accurately describe the circumstances under which consumers may incur such fees. The fees may be unfair if consumers are unable to reasonably avoid injury, and the facts support other factors to establish unfairness.
Many banks have already eliminated APs and related overdraft fees and are in the process or are in the process of doing so. However, some community banks have noted that a third party service provider does their core processing has not offered a technical solution to avoid the APS and transactions. When possible. I encourage those portrait processors to address their client bank requests for technical adjustments to eliminate APs and related overdraft fees. Re presentment fees are distinct from a PSN but also pose significant UDAAP risks when a bank receives a check or ACH transaction that is presented for payment from a customer’s deposit account. And the account has insufficient funds to cover the transaction And the bank may decline to pay and then will charge the customer and NSSP.
Banks may also assess an additional fee, each time a third party usually a merchant resubmits the same transaction for payment, thus resulting in multiple fees for the same transaction. Through ongoing supervision, the OCC has found representment fee practices that pose UDAAP risk. For example, disclosures may be deceptive if they do not clearly explain that multiple or additional fees may result from multiple re presentment of the same transaction. Even when customer disclosures explained that a single check or ACH transaction may result in more than one fee. A bank’s practice of assessing fees on each re presentment may also be unfair, if consumers cannot reasonably avoid the harm, and the other factors for establishing unfairness are met. Consumers typically have no control over when a returned ACH transaction or cheque will be presented again and lack knowledge as to whether an intervening deposit will be sufficient to cover the transaction related phase which may result in substantial harm. No Limits.
So in addition, bank overdraft programs that have no limits on the cumulative fees that may be assessed can lower some customers into high cost debt traps. And this heightened compliance and reputational risks. A high limit with a lack of a limit on the number of overdraft and NSF fees that can be charged in a single day has contributed to to determinations that banks overdraft protection programs as a whole are unfair. Lower fee amounts are limits on the number of fees that can be accumulated over a period of time can reduce or even effectively mitigate this risk. Stepping back. The good news is that in 2022, we saw OCC supervised banks of all sizes adopt pro consumer reforms that decreased their reliance on overdraft fees. The CFPB found that overdraft fees overall were 33% lower in the first three quarters of 2022.
Then in the same period in 2019 pre pandemic also reported that overdraft fees have trended downward and each quarter since the fourth quarter of 2021. I want to be clear, most of the bankers I’ve spoken with have embraced this conversation on overdose and reform possibilities. They understand the importance of treating their customers fairly. We have been open to learning about best practices. These bankers are committed to being there for their customers and providing them with short term small dollar liquidity when it is needed most. Many customers tell their banks as well as other groups that this banking service helps them to meet payments when they come do.
What we’re all trying to do here is to improve the fairness of these programs by making them more pro consumer not to eliminate them. More fairness means more financially healthy communities, which means more trust in banking. Let me turn to discrimination and bias to treat customers fairly. Bank products, services and practices must be free of discrimination and bias.
Here I’d like to highlight three areas of focus at the OCC lending, appraisals and artificial intelligence. So discriminatory lending practices are illegal, exacerbate inequality and erode trust in banking. To help combat these illegal practices, the OCC is taking steps to strengthen our supervisory processes and resources devoted to compliance with fair lending laws.
In January, we published a comprehensive update to our fair lending booklet was just part of the comptroller handbook. This booklet, which had last been revised in 2010 now guides our fair lending examinations. The updated version provides transparency into how we approach fair lending exams, including new details on exam scenarios also includes clarified and expanded risk factors, new explanations of risk management and third party controls and additional details about applicable legal standards. We’ve also updated our annual process for screening, mortgage lending activities to leverage the new Honda data fields and to enhance the redlining screens by incorporating updated peer analysis and evaluation of assessment areas. So these updates together strengthen how we risk focus our fair lending examinations support more effective fair lending exam strategies and allow us to better deploy resources and to define identify weaknesses or potential discriminatory practices. With Russia appraisal bias, bias in the appraisal of home values exacerbates and perpetuates inequality. It’s noted in the recent paper report.
Perhaps the biggest drivers of the racial and ethnic wealth gap today are the racial and ethnic disparities and rates of homeownership and the financial returns associated with owning a home you SEC is taking an active role in the paved Task Force to evaluate the causes, extent and consequences of appraisal bias. We’re also developing enhancing our supervisory methods for identifying discrimination and appraisals, taking steps to ensure that consumers know of their rights regarding appraisals, and supporting research that may lead to new ways to address the undervaluation of Housing and Communities of Color.
Finally, let me say a few words about AI in the context of discrimination and bias. In 2021, the OCC joined with other federal banking agencies in issuing a request for information on the use of AI and machine learning. The core concerns remain salient today. The unexplained ability of model outputs the limits of training data, and risks from updates involving little to no human interaction.
Unless we proceed carefully, AI adoption may inadvertently reinforce or exacerbate old biases and discriminatory practices from the past and prevent growth and progress toward a fairer system. Fortunately, there’s a keen awareness of the so called alignment problem among AI researchers. How can we ensure that AI and AI models do what we want them to do?
Bankers have generally taken a prudent approach to AI adoption, and some community organizations have begun to survey best practices related to AI controls and risk management.
However, my sense today is that we are all soon going to be struggling to keep up with the accelerating speed of AI development. Institutions may soon face strong pressure to rapidly adopt and deploy AI technologies to avoid being left behind. The recent release of chat GPT in Microsoft’s integration of it into its products has accelerated the race to make AI accessible and deployable across a wide range of domains and risks.
Although several large banks announced limits on employee use of such technologies, the promise of greater efficiency through chat bots and CO pilots for compliance and underwriting will make it difficult for bank management teams and boards of directors to ignore. When that happens. Will the controls be in place for banks and regulators to be able to detect when an algorithm may be reinforcing or introducing discrimination and bias?
In 2015, Google released automated captioning and it’s Google Photos app. Some of you guys may remember this.
Unbeknownst to its engineers, it ended up labeling pictures of certain individuals and highly inappropriate and racist ways. Once notified, Google quickly shut it down.
The post mortem revealed that the problem was not the algorithm per se, but the training data, data that reflected an internet worth of discrimination and unconscious bias. Imagine making a mistake of this type when deciding whether to underwrite a small business loan, replacing a mortgage or offering a credit card. Getting governance and controls right ex ante is, I believe, critical to building the public’s trust with how the banking system uses AI.
Done right, the benefits are potentially enormous. As I’ve noted in other contexts, the better a car’s brakes, the faster one can safely drive it. Developing good controls for AI especially regarding discrimination and bias should be in the shared long term interests of banks and consumers.
Let me turn now to expanding inclusion and opportunity, ensuring the federally chartered banks provide fair access to federal services. Financial Services is the second fairness prong of the OCCs mission statement. Our country’s history of slavery and segregation. Of bouts of jingoism in a state sponsored redlining serve as an important backdrop to this expanding financial inclusion opportunity are not just feel good buzzwords, they are imperatives. A banking system that is financially safe and sound, but not fair and inclusive is a system at odds with trust, growth and democracy.
The OCC is focused on expanding inclusion opportunities are currently centered on strengthening and modernizing the CRA and betraying project reach. So, you guys, this audience is well aware of our efforts to work with the Federal Reserve and the FDIC on strengthening the CRA. The CRA is the key tool in the bank regulatory toolkit to expand financial inclusion and opportunity for all Americans, especially the underserved. I don’t need to belabor the point here. I’ll simply note that we’re working hard to incorporate and respond to feedback provided via comment letters to our NPR regarding project reach It’s rapidly approaching its third year anniversary.
Project Reach was initiated in 2020 following the murder of George Floyd. By serving as a convener of leaders across banking, civil rights technology and community organizations like NCRC. The OCC is helping to catalyze solutions to eliminating barriers to financial inclusion reaches notched a number of important successes, facilitating pilot programs to make those without credit scores visible to lenders, securing pledges from two dozen banks to revitalize and support NDIS promoting homeownership for the underserved, and those on tribal lands in supporting minority small businesses awareness of special purpose credit programs, and this is just a partial list.
Of course, the challenge for us going forward is building on reaches momentum and institutionalizing it building it into our DNA and processes, while maintaining the magic of bringing highly motivated individuals together to collaboratively and creatively break down key barriers to inclusion. Wonder reaches as one of reaches founding members NCRC has played an important role in guiding and supporting us to do more and to stay focused on outcomes. I look forward to continuing this work as reach enters its fourth year.
Finally, I want to highlight the importance of making banking accessible to all who want it. Approximately 6 million US households are unbanked and lack of bank account a much higher number nearly 19 million households have a bank account, but rely on non bank products and services, such as money orders and check cashers, pawn shops, auto title lenders to meet some of their banking needs, and thus our term are deemed underbanked.
Behind these statistics are people, immigrants, students, laborers, parents between jobs, citizens who live in banking deserts, fully including them in the banking system can help unlock their potential and help their communities grow. campaigns such as bank on and similar bank specific efforts to provide low or no costs, bank accounts can make a big difference in this regard.
So in conclusion, thanks for bearing with me this early in the morning. Fairness and banking matters as much as financial safety and soundness. This concept is inscribed in the OSI C’s mission statement, which calls on the OCC to quote ensure that national banks and Federal Savings associations operate in a safe and sound manner. Treat customers fairly, provide fair access to financial services and comply with applicable applicable laws and regulations. We are elevating fairness in our strategic plan with our people and processes and through our actions, some of which I’ve highlighted.
As a financial regulatory agency, the OCC has an extraordinarily strong culture, the strongest of any of the agencies I’ve been at. This is due to our people and our history.
The OCC’s founding dates to the Civil War, when the union needed in the national banking system to fund the war effort and bring the country together. Lincoln saw the abolition of slavery is not just a moral imperative, but also an economic one. In the July 4 addressed to Congress in 1861, he argued, quote, this is essentially a people’s contest on the side of the Union. It is a struggle for maintaining in the world that form and substance of government, whose leading project is to elevate the condition of men to lift artificial weights from all shoulders, to clear the path of laudable pursuit for all to afford all an unfettered start and a fair chance in the race of life.
Two years later, Lincoln would sign what’s known today as the National Banking Act, creating the federal banking system and the Office of the Comptroller of the Currency to oversee it. We carry this history proudly today. Thank you.
JESSE VAN TOL: Can everyone hear me? It’s Jesse. Good morning. You all know me. Well, well, I just wanted to start by saying because I didn’t get to give you a proper introduction. Mike Hsu is probably the most intellectually curious, open accessible Comptroller, maybe even bank regulator period that I’ve ever worked with and, and we thank you for that.
So obviously, the topic that I think is top of a lot of people’s mind, is the collapse of Silicon Valley Bank. Signature Bank, of course, silver gate Bank, which sort of evades notice in some ways. Um, and this is something Mike, that really you talked about you gave a speech before the collapse about sort of too big to manage. And in that speech, there was kind of a footnote. And that can happen at almost any size. And I’m paraphrasing, but so in a sense, you saw this coming, not perhaps the particular circumstance. But you were concerned about this. And it occurs to me, there’s capital, there’s a whole bunch of different issues at play with these collapses. But one of them is managerial competence. And how do you at the OCC, with regards to the banks, you regulate? You didn’t regulate any of those banks? Or Silicon Valley and signature? How do you think about managerial competence in a regulatory supervision context.
HSU: So to the bank regulator nerds in the room, this will be old hat, but supervisors spend, we spend our time rate assessing and rating banks on all sorts of dimensions. And you may have heard of camels, right? So camels is basically the the the shorthand for the things that we rate banks on capital, asset quality, and in camels is management. And that is one of the key components, which examiner’s spend some time trying to suss out, can is management capable to do what this bank says it’s going to do, it can do it in a safe sound, and fairway. So that’s really critical, I would add to that capability is one thing. You’ve got ability and willingness, ability is really important. The willingness part, when times are good, complacency can set. And we’ve seen this again, and again, just becoming good at something doesn’t mean that you’re always going to be good at it. In fact, the longer you’re good at it, the easier it is to become complacent to feel like we’re great at this, nothing can go wrong. And that’s usually when things go wrong. So that’s why as supervisors we put a lot of attention on not being complacent, you know, a fair amount of healthy paranoia about what things what things can go wrong is really good. And where that’s not there, you see things can go wrong.
VAN TOL: So back in February, you held a symposium on bank mergers. And the FDIC has issued an RFI on bank mergers. You know, we’ve really seen the history of the banking industry, at least at least for the past 20 years is really a history of consolidation. And I do wonder if in the current moment, we will see a hastening of consolidation, especially at the smaller level, in light of and in the wake of Silicon Valley Bank. You know, one of our big concerns, of course, is that this component of a public benefit, which is really written in the banking law, the component of fairness, as you mentioned, in your speech, sort of gets, you know, pushed to the bottom of the list. How do you think about public benefit in the context of bank mergers, what ought to be the bar and the standard.
HSU: So under the bank merger act, there’s a number of factors statutory factors that we have to follow. And so these are all laid out in a number of these are, the ones that get the most attention tend to do with competition, financial stability, that’s gotten a lot of attention. There is a prong on the convenience and needs of the community. And, Jesse, to your point, I think this one often there’s a bit of hand waving that goes along with that. And one thing that I and my colleagues have identified is that we update how we evaluate all this. Are these working for communities like banks don’t exist for themselves, they exist to serve communities. And we want to make sure if that is properly taken to an account, when we assess mergers, when we do our supervisory activities, etc. We held a symposium recently, as Jesse mentioned, and we took each of these prongs. And we brought together folks, different perspectives like how do we improve upon this? And it was it was really good to just get those different perspectives. And again, we want to make this centered on banks serving those their communities.
VAN TOL: And one of the things of course, we have done with a lot of banking institutions, the formation of community benefits plans, and we understand sort of traditionally the regulatory stance on that has been, what’s a third party agreement? It’s non governmental. However, these are public statements that banks make in the context of seeking merger approval. They’re affirmations made often to the regulators submitted to the regulators. How do you think about the and yet we’ve also seen that sort of some of these commitments or plans, particularly those absent, made absent working with a community based organization? It never seems to really be the kind of follow through, right, that might be desirable. How do you think about the enforceability of those statements? These are part of the representations made in the process of a merger, should they be enforceable?
HSU: So linking back to my first point, what we want, overall is that banks are really intuiting. And understanding what the needs of the community are doing what they need to do to meet that that’s the that’s the bar. That’s where we want that at all times, not just when there’s a merger, where there’s a potential merger, we want that all of the time. And so I think if you look at the tool set, CRA that’s a big tool, right. And so we’re working really to modernize that raise that bar and NCRC has been very, very involved in providing ideas on how to how to do that, in the merger context. There’s two things that I think have helped in that we’re in terms of ensuring that there’s that responsiveness. One has a lot of discussion on public meetings. I know NCRC, has also been an advocate for more public meetings.
We have adopted a policy that bank mergers above a certain threshold 100 billion dollars, we should default to saying there should be a public meeting, like that is of sufficient enough consequence that, you know, we don’t think that the arguments for not having a public meeting are that compelling. There should be a public meetings, and those are an excellent venue to say, bring the community together, say, what do you need? Are we being responsive to that? And then with community benefits agreements, it’s a it’s a great innovation, I think of it as an innovation as to say, Well, what, now that we’ve had a meeting, how do you turn that into something that’s actionable? We’re reviewing that as part of our process, right. Currently, as you pointed out, that’s an agreement between community groups and banks, we’re not we as a regulator are not party to that. So we have to think really hard about how exactly all of this interacts into our assessment process. It certainly has a lot of informational value, there has a lot of benefits for communities, we’re still working through exactly how to put all these pieces together into a formal assessment process.
VAN TOL: Well, one of the things, things that seem to be a point of consensus at the symposium was sort of a question of whether the current standards for measuring competitiveness, really, really adequately, excess, and I’m gonna wrap it in sort of a second question here, you know, when you when you see in a competitive context, you know, banks continuing to charge overdraft fees that are maybe disproportionate to the actual risk they’re taking or something like overdraft protection was really no cost to the bank. And all they’re doing is charging a fee for moving money amongst your accounts, because you forgot to do it. How do you think about, you know, what some regulators have called junk fees, or fees and practices, products that don’t really add value to the consumer, in the context of, of competitive effect? Because one would think in a competitive world, some banks would stop offering those fees, and other banks, you know, and compete with other banks. And yet we’ve seen now a sea change in terms of overdraft, but it’s been very slow to develop.
HSU: Yeah. So I totally agree it’s way overdue, right? The overdraft changes are way overdue. It has accelerated over the past year. And I think that that’s promising, I think us coming out and kind of highlighting where the there is that whether those huge app risks will help even more generally, I think what you’re highlighting is we’ve got a competition issue. We’ve got consumer protection issues. And we’ve got you DAP unfairness, deceptive practice issues, where you have to work on all three at the same time. I think the traditional approach has been, we’re going to have a group over here focusing on competition, and they’re kind of an economist HHI perspective, a group over here that does consumer protection. You got to think about all of them together. And to figure out where are those? How does it come together to protect consumers to put communities first, and that’s what we’re trying to do as we contemplate kind of elevating fairness and putting people first
VAN TOL: Last question, I’d be remiss if I didn’t ask about CRA, and we don’t have a final rule yet. So I know there are limits to what you can say, Comptroller, but first, first of all, what is the current timeline for CRN And then secondarily, you know, we’ve really pushed for the consideration of race and CRA, of course, the history of CRA was really about redlining, which was racialized discrimination and one of the biggest critiques of it CRA is what hasn’t really been effective in solving for racial economic inequality, the racial wealth divide, because it wasn’t designed that way. And yet there are some real constitutional questions and issues, concerns about subjecting CRA to an affirmative action type attack with with the courts. You know, what are the ways in which you think the new CRA could and should address issues of racial economic inequality.
HSU: So I make three points, I’m going to reiterate the point you made, because I think this is very, very important to recognize the historical roots of CRA, are born out of a long period of state sanctioned redlining. That is we have to recognize that and CRA was adopted as part of the Civil Rights package of of bill. So that has those roots, which are very, very important. Second, we have to meet both the spirit and the letter of the law with regards to CRA. And I think what we’re working on with now within the the three agencies who, you know, some some folks are here have been working around the clock to get that done. There’s been a couple events recently we may have heard of, which may impact some timing, but there’s we’re moving with all deliberate speed on that package. And you know, that that is it’s hard to understate and we see this as a historic opportunity to really raise the bar, strengthen and modernize the CRA because we recognize like this is this is the racial wealth gap has gotten worse. And that is not an acceptable place for us to be that’s not an acceptable place for the banking system to be. There’s recognition of that. We need to we’re going to work towards with that in mind, sir. Important.
VAN TOL: Great. Thank you so much comptroller Hsu — a hearty round of applause.
HSU: Thanks for having me.