Speakers
HOST: Jason Henricks

CO-HOSTS: Brett King, J.P. Nichols

GUESTS:

Dara Tarkowski – Managing Partner, Actuate Law; Host, Tech on Reg

Alex Johnson – Creator, Fintech Takes

Kia Haslett – Financial Journalist; Former Editor, Bank Director

What Sparked Dodd-Frank in the First Place?
HOST (Jason Henricks):
2008’s financial crisis became the crucible for change, setting the stage for the Dodd-Frank Act, Congress’s largest financial reform since the Great Depression.
GUEST (Kia Haslett):
The law aimed to repair systemic weaknesses revealed by the crisis.

Introduced agencies like the CFPB, FSOC, and Orderly Liquidation Authority.

Implemented mechanisms like the Volcker Rule, DFAST, and CCAR to de-risk banking behavior.

Quote:
“Dodd-Frank was Congress’s seminal piece of legislation to address what they saw as financial system weaknesses.” – Kia Haslett

How Did Dodd-Frank Change the Regulatory Landscape?
GUEST (Dara Tarkowski):
Dodd-Frank created first-ever federal supervision for non-banks, fintechs, servicers, payday lenders.

Legal enforcement shifted from hands-off FTC to a multi-tiered regime of rulemaking, supervision, and enforcement.

Enforcement-by-surprise became common due to unpredictable shifts in regulatory priorities.

Quote:
“The enforcement priorities were a complete yo-yo for the past 15 years.” – Dara Tarkowski

What Happened to Lending and Capital Requirements?
GUEST (Alex Johnson):
Large banks were intentionally “de-funned.”

High capital standards made banking less profitable but safer.

Created incentives for non-banks and fintechs to take over formerly bank-owned functions.

GUEST (Kia Haslett):
Regulations made it more appealing for banks to fund non-banks like Rocket Mortgage rather than carry risk themselves.

Exercises like CCAR and DFAST shaped risk awareness and institutional discipline.

Operation Chokepoint: A Parallel Impact
GUEST (Dara Tarkowski):
The DOJ’s Operation Chokepoint labeled entire sectors “high-risk.”

Legal businesses were de-banked and de-platformed.

When combined with Dodd-Frank, this created massive collateral damage.

Fintech Fills the Void: Did Dodd-Frank Enable Innovation?
GUEST (Alex Johnson):
Ironically, Dodd-Frank helped give rise to banking-as-a-service and private credit markets.

Fintechs stepped into the gap left by banks.

Unbanked rates halved since 2010, showing non-banks did step up.

The Durbin Amendment’s Ripple Effect
HOST:
Did capping interchange reduce merchant costs? Spoiler alert: Nope.
Banks tried recouping losses with consumer fees (e.g., BofA’s failed $5 debit card fee).

Created a “Durbin Cliff” that shaped bank strategy around staying under $10B.

Drove smaller banks to chase reward products and complexity without regulatory oversight.

What Was the CFPB Supposed to Be?
GUEST (Alex Johnson):
Conceived as a “financial product safety commission.”

Envisioned to standardize consumer protections, like safety ratings on car seats.

Instead, it became deeply politicized, with wild pendulum swings in tone and mission.

GUEST (Dara Tarkowski):
Introduction of “abusive” under UDAAP gave the agency broad, undefined power.

Enforcement went beyond precedent, driven more by ideology than legal clarity.

Quote:
“You can’t just call something abusive because you think it’s abusive.” – Dara Tarkowski

Is the CFPB Being Dismantled?
Panel Consensus:
SCOTUS rulings and funding debates threaten its existence.

State AGs and private litigation will try to fill the gap.

AI regulation will likely be a patchwork at the state level.

The real loss may be national data collection and a centralized complaint portal.

Was Dodd-Frank a Success?
GUEST (Dara Tarkowski):
✔ Success: It made riskier players think twice.

✘ Failure: Created regulatory imbalance, penalizing smaller, well-meaning firms while larger players absorbed fines as cost of doing business.

GUEST (Alex Johnson):
Mixed legacy. Many wrong turns weren’t from the bill itself but from interpretive choices made over time.

GUEST (Kia Haslett):
Acknowledges capital stress-testing improved bank discipline.

Criticizes reliance on arbitrary asset thresholds that distorted the industry.

Will the Genius Act Be the Next Dodd-Frank?
GUEST (Kia Haslett):
More akin to interstate banking legislation, expands innovation, not reform.

Lacks clear definition of what a stablecoin even is.

GUEST (Alex Johnson):
Doesn’t address market structure like Dodd-Frank did.

It’s a permissive bill, not a corrective one.

Quote:
“It’s hard to be a transformational bill when you don’t define the thing the bill is about.” – Dara Tarkowski

Parting Thoughts: How Should We Approach Regulation?
Dara Tarkowski: Mandates without frameworks create legal chaos. Statutes must be drafted thoughtfully, especially in emerging areas like AI and digital assets.

Kia Haslett: Don’t forget the crisis that created Dodd-Frank. Are we fixing root causes or just pruning branches?

Alex Johnson: All regulation balances safety vs. competition. Pretending there’s no trade-off leads to bad policy.

Top Memorable Quotes
“Less consumer choice is bad for consumers.” – Dara Tarkowski
“Fintech filled the void that Dodd-Frank created.” – Alex Johnson
“The further we get from a crisis, the more its causes fade.” – Kia Haslett
“You can’t define a stablecoin by what it’s not.” – Dara Tarkowski
“Dodd-Frank was about deciding who gets protected and who doesn’t.” – Kia Haslett

Raw Transcript:
[Speaker 4]
Welcome to Breaking Banks, the number one global fintech radio show and podcast. I’m Brett King.

[Speaker 1]
And I’m Jason Henricks. Every week since 2013, we explore the personalities, startups, innovators, and industry players driving disruption in financial services. From incumbents to unicorns and from cutting edge technology to the people using it to help create a more innovative, inclusive, and healthy financial future.

[Speaker 4]
I’m J.P. Nichols, and this is Breaking Banks.

[Speaker 1]
Welcome to another episode of Breaking Banks. In today’s episode, we celebrate everyone’s favorite holiday, the anniversary of the passing of Dodd-Frank. Yes, this year is the 15th anniversary, and I’m sure you decorated the office and have a birthday cake just like we did, maybe even sang a little happy birthday, Dodd-Frank.

I’m joined by Derek Parkowski, Managing Partner of Actuate Law and host of the Tech on Reg podcast, Alex Johnson of Fintech Tapes, and Kia Haslett, writer and former banking and fintech editor of Bank Director. Back to our birthday party, listen as we go through what worked, what hasn’t, and in the most significant piece of regulatory overhaul in the last century, Dodd-Frank, we close with a debate. Does the GENIUS Act have the same potential to overhaul the regulatory landscape?

This week on Breaking Banks, we trade in the hot sauce for a regulatory birthday cake and sweet takes on legislation. I’m your host, Jason Hendricks, and this is Breaking Banks. Happy anniversary, everyone.

It is the 15th year of the publication of everyone’s favorite book, all 838 pages of the illustriously titled Dodd-Frank. Now, what I found curious prepping for this, there are estimated to be 10,000 to 30,000 additional pages written around it of rules and guidance, and I know each one of us is internalized. Actually, I maybe should not admit this on air, but we were raising our Series B for Perk Street when the first draft of Dodd-Frank came out, so VCs were asking questions all the time.

So Dan and I literally each sat down with our own printed out copy and started annotating freaking Dodd-Frank. It was probably the first 72, worst 72 hours of my life doing that. But let’s set the context.

Context. This started because what happened in 2008 took, you know, two years to get put out, you know, another 15 years because we’re still in the process of getting it implemented and now dismantling. Kia, why don’t you set the stage for us?

What happened that Dodd-Frank was meant to actually fix in this massive omnibus fashion that it was trying to control for?

[Speaker 3]
Yeah. So the great financial crisis happened between 2007 and 2008 and it had a long tail, really long recovery. And the Dodd-Frank Act was Congress’s seminal piece of legislation to address what they saw as creating many of the financial weaknesses or addressing the incentives around what contributed to that crisis.

And it is probably the most significant piece of financial reform we’ve had, you know, in the modern era. It gave us many things and I was actually starting my career as a bank reporter in October 2011. So thank God I didn’t have to cover the financial crisis.

And I really didn’t actually have to cover the lawmaking, which like the torture of the stablecoin legislation really also shows me that that’s probably not where I was going to be really successful, but I was in that post-implementation era. So we saw the creation of the CFPB, the creation of FSOC, the Financial Stability Oversight Council, the creation of the Orderly Liquidation Authority. We saw the Volcker Rule, higher capital requirements, the Comprehensive Capital and Review Exercise, the Dodd-Frank Act Stress Test, DFAST. There are a number of pieces of rules, part of Dodd-Frank that still haven’t been implemented, including and I know we’ll talk a lot about the CFPB rules, but actually Section 956, which is the SEC’s clawback provision for incentive pay, still hasn’t been passed, but it has been proposed four times in 15 years. And so maybe, fingers crossed, 2025 might be its year, maybe 26.

[Speaker 1]
I love that we aren’t even done implementing all of this and we’re in the process of reshaping, recasting, and even removing some of this. You skipped over two of my favorite hot buttons in there, both Durbin and a subset of CFPB, 1033 and open banking. So, Dara, I know that Dodd-Frank is near and dear to your heart as the resident lawyer on this call.

Give us some context from the legal approach and the regulatory. How has this unfolded? It feels a little bit like the Austin Powers steamroller scene, right?

Like where you’re watching that thing go in slow motion.

[Speaker 2]
So it’s funny, when Dodd-Frank was first introduced, I had the fortune or misfortune, depending on what seat you’re sitting in, of actually watching and counseling clients during the lawmaking process and figuring out like, oh my God, is it going to happen? What’s going to happen? What is this going to mean?

And I sort of accidentally became my firm’s Dodd-Frank expert at the time. And I joke that- Wow, that’s quite the honor. Yeah.

Well, you know, in the moment, I don’t know if I really felt that way. But since then, I joke with my clients all the time that I should send Chris Dodd a fruit basket every year because he’s going to help put all three of my kids through college. So separate and apart from that, what was really meaningful from the regulatory perspective is that I know Breaking Banks covers all sorts of financial services companies, banks and non-banks, and banks have always had federal regulation for the most part, but non-banks really didn’t.

So something that was terribly important and meaningful, and like no offense to the Federal Trade Commission, like I know you technically like oversaw all of those people, but like you really didn’t. And no one was really concerned about you. So sorry, FTC.

[Speaker 1]
Dare I just interject, I think there are a number that were technically being overseen by the FTC that were not actually aware that they were being overseen by the FTC. That’s how hands off it was.

[Speaker 2]
It was it was very hands off. And part of the reason it was hands off is because there was no supervisory portion of what the FTC was empowered to do. They had enforcement authority under the FTC Act, but the FTC Act did not provide any mechanism for supervision.

So all of that was very, very, very, very new to non-bank financial services companies. And we’re talking about like fintechs and we’re talking about, you know, non-bank originators of debt. We’re talking about the servicers of those debt, payday lenders, all sorts of companies that had always been under state regulation with their licensed state bodies, but never had to answer to the feds in any meaningful way.

So that part was a huge shift, a huge change. And because of the structure of the bureau, from a lawyer’s perspective, it became we had our three sort of areas. We were looking at rulemaking.

We were looking at who was going to be subject to supervision. And then there was like the big, dark cloud of enforcement. So under supervision, you had these revenue thresholds.

You’re like, can I skate under? People were talking about like, what do I do with my balance sheets? Like how do I make sure I stay just under that threshold so that I wasn’t subject to supervision because who could afford it?

But on the enforcement side, everything was fair game. And the policy and watching the shifting waves of how supervision and enforcement was treated under the various directors, like originally starting with Cordray, and it’s just been a complete yo-yo. Like the strategies and the priorities have been a complete yo-yo for the past 15 years.

So every four years and sometimes every two years, we’re like, OK, where are their priorities going to shift? So from a counseling standpoint, it was maddening trying to figure out how to tell clients what to expect because nobody knew what to expect. And how unfortunate that election cycles were the primary dictator of what types of consumer protection priorities were going to be enforced, made rules on, prioritized.

Like, I don’t know. I think in a lot of ways, the way it all played out really undermined the true purpose of the bill to begin with.

[Speaker 1]
Well, Dara, Alex, we had a heyday with that at digital banking for digital banker down in Boca around who we would marry, who we would kill and who was good for the moment. We will come back to that. Let’s talk about asset size for a second in the enforcement.

Now, as someone who spent a lot of time on the non-bank lender side of this, right. And we’re seeing this bifurcation in Dodd-Frank that you hadn’t really before. Right.

Like, so we’ve pulled some into the net of oversight in a way that hadn’t been in the supervision, as Dara said. Then we also see within banking a bifurcation of how this plays out. Let’s talk about lending for a second, because that actually had a really big part of what instigated Dodd-Frank and people getting into trouble with their lending and the oversight.

Yeah, I mean, there was a real strong focus on obviously like systemically important financial institutions, right, which sort of entered the lexicon around this time. And there’s been some changes over the last 15 years in terms of what size banks are considered systemically important and some pushback on sort of how do we tailor that to make sure we’re adequately adjusting it to the risk. But yeah, the basic idea was that there are a set of these institutions that we want to and the way I’ve always thought about Dodd-Frank is like we want to make banking less fun for these banks is how I think about it.

Right. And so everything from the Volcker rule, which prohibits you from doing certain types of proprietary trading to higher levels of liquidity and capital ratios to restrictions on certain types of businesses. I mean, all of it is really designed for those banks to make banking more boring, less fun, more stable with the recognition that there are a certain set of banks that are systemically important to the global economy and we have to treat them different.

And I think, you know, if you listen to bank executives talk about Dodd-Frank, particularly large bank executives, they’ll talk about it almost as if they’re sort of like bemoaning the loss of their golden years in a way, because I think it did have the effect of making banking much less fun and to a certain degree, much less profitable for those banks. Right. I mean, Jamie Dimon talks all the time about how, you know, the private credit industry, which has been exploding over the last 15 years, really grew out of the fact that banks just weren’t allowed to hold certain types of assets on their balance sheet without a lot more capital to offset the risk of those assets.

Kia, I know you have a whole song and dance you want to do about the way in which we maybe have sort of unintentionally restructured the demographics of banking and which size banks kind of make the most sense. But I think that was the intention behind it was let’s make banking less boring or more boring and less fun for large banks that got us into this trouble in the first place. Well, let’s talk about where the fun got pushed to, Kia, like in this fundamental restructuring and the stratification, what were the impacts of the banks of the various sizes?

And let’s get into the non-banks.

[Speaker 3]
So and this is everyone’s going to forgive me because a bunch of things are happening at the same time under Dodd-Frank and I think maybe in conjunction with Basel, although Dodd-Frank didn’t do Basel. That’s like a whole separate thing. Banks, the largest banks have to hold more capital.

They hold more capital in a variety of ways. One are just like capital taxes like they’re just surcharges. Two is that they have to have more, as Alex was saying, they have to set aside all the risk-weighted assets have a weighting assigned to it.

And so if you make a mortgage loan, that might be 100 percent risk-weighted asset that you would have to hold. And if you make a loan to a hedge fund, that might only be 50 percent. So we see like the incentive around the types of loans you would want to make and the types of loans you wouldn’t want to make.

And at the same time, there had been non-bank mortgage lenders for years. So why not just make why not make a line of credit to Rocket Mortgage and Rocket Mortgage can make the loan and then sell it and deal with that rather than us hold the loan and or sell the loan and have to set aside 100 percent risk-weighted assets against it. And then separately, the CCAR exercises, especially in their earliest days, these were hard, especially because banks were still dealing with figuring out their credit risk, processing credit risk.

We saw hundreds of banks failing in 2010 and 2011. And so the CCAR exercise was a nine quarter future looking exercise designed to try to break your bank while also understanding exactly what kind of counterparty risk you might have or what kind of documentation you might have and collateral values if stuff happened. And in the first couple of years, we see banks fail this exercise.

They fail it because both because they will go under credit or the capital minimums and because the Federal Reserve doesn’t think that they’re showing their work really well. They don’t think their processes are kind of grounded in fact or will be reliable under stress. And I think it’s been really interesting to think about CCAR as an exercise becoming like easier and easier and easier because maybe the bank because it did what it was to do it.

Maybe it raised capital ratios. Maybe it really tightened up a lot of the data or a lot of the underwriting that made address some of the critiques and the criticisms that regulators would have had for these institutions. And then also like it made them think about capital for nine quarters.

And I think we saw some really interesting things around big bank M&A because if you can prove that you have enough capital for nine quarters and the regulators, it’s been five, ten years, the regulators might allow you to do big bank M&A. And I think that’s been a really interesting unintended consequence of CCAR is the capital stack that they now have to deploy. But that’s not the biggest thing.

There’s some really fun stuff happening at the smallest banks, too.

[Speaker 1]
Well, I mean, let’s pull on that thread of unintended consequences. Derrick, it sounded like you were ready to chime in.

[Speaker 2]
I think like I love everything Kia just said, but I think it’s really difficult to look at just the statutes in a vacuum without also looking what was happening at the Department of Justice during the exact same time period. Does anyone remember Operation Chokepoint? Because all of that was happening, right?

All of that was happening in parallel, in parallel to all of these regulatory and statutory initiatives, which can’t be ignored because each one of those regulatory bodies all had memorandums of understanding with the Department of Justice. So there was also this underlying theme that the Department of Justice was targeting all of these high-risk businesses. So from a lending perspective, there were a lot of unintended consequences, particularly when you look at it, because when you say it objectively, it all makes sense.

But when you look at it from the combination of the regulatory regime plus Operation Chokepoint, there were lots of very legitimate businesses within the financial services ecosystem that got caught up in the crossfires and could not get access to credit, couldn’t get access to payment services, and were de facto being essentially put out of business because they couldn’t access banking services because they were being lumped in with all of these high-risk activities.

And there was lawsuits that resulted from Operation Chokepoint. There was all sorts of things. But I think you’ve got to look at both sides of it to understand how it all played out, the way it played out, and why.

[Speaker 1]
Well, let’s dig into that for a second, because while all of the crypto listeners are cheering wildly saying, yes, Operation Chokepoint, there were legitimate reasons that Operation Chokepoint came into being, not just an anti-crypto sentiment. So, Dara, I don’t know if you want to start there. And, Alex, I know you have some opinions about that as well.

[Speaker 2]
I mean, look, the Department of Justice, rightfully, was worried about businesses that were more apt to facilitate money laundering than other businesses. And those are the ones that were deemed high risk. We were talking about ammunition sales and coin dealers, credit repair services.

[Speaker 1]
Payday loans, yeah.

[Speaker 2]
Payday loans, drug paraphernalia, gambling sites, things that were sort of known to be part of other criminal enterprises that the DOJ had investigated. The problem is, is that not every money transfer network is facilitating money laundering. And, you know, pushing money to those that would threaten national security and traffic humans and do all sorts of terrible things.

So because these businesses, rather than having like sort of fact-based risk analysis, they were automatically being lumped in with bad actors. I applaud the sentiment, right? I am glad the Department of Justice was trying to keep people safe.

But at the same time, if you are not one of those bad actors, those initiatives put a lot of people out of business, particularly in the money transmission space and in the payment space.

[Speaker 1]
Yeah. And I think just to add to that, I mean, again, it’s part of this like large scale response to the great financial crisis, which is like we just need to de-risk banking across the board. And to Dara’s point, like it definitely caught up a bunch of legitimate businesses that deserved more access to banking or easier access to banking.

And it had like a negative effect on them. That was, I think, to a degree, just like the consequence of this large scale effort to de-risk banking. I think the thing, Hendrix, that was maybe not totally anticipated, but financial services finds a way no matter what you do to stop it, is FinTech filled the void that Dodd-Frank created, right?

And there are sort of very obvious, specific ways in which it did. We can talk about the Durbin Amendment. There are more sort of subtle ways that it did with private credit, sort of starting to fund FinTech lending that was existing off of banks’ balance sheets.

But I think it’s been interesting listening to kind of the discussion around Dodd-Frank over the years, because I think in general, the market has really adjusted to and filled in a lot of the gaps that were left behind by banks, right? There’s really interesting research that’s been done on what was the sort of effect of Dodd-Frank on American households and causing them to become more unbanked, right? And to a degree, that did happen, right?

Because banking services became more expensive to offer to consumers. Obviously, the Durbin Amendment capped debit interchange, except for exempt institutions. And that probably did raise fees and sort of drive some folks out of the banking industry.

That’s been demonstrated in research. However, if you look at the overall rate of unbanked households in the U.S. since Dodd-Frank was passed, it’s actually dropped by about half from where it was in 2010. And I think a large part of that is due to the fact that non-banks and FinTech companies and others have sort of filled in the gap.

So I think that’s the other half of the story with Dodd-Frank is it created this massive wave of de-risking that sort of swept across all the banking, but it also sort of opened the door in a lot of ways for FinTech to step in. Well, and let’s talk about one of my favorite, least favorite unintended consequences, which really does come down to Durbin. And let’s just show of hands, who by capping interchange on both credit and debit has seen that your cost at the merchant has gone down?

Right, exactly no one.

[Speaker 3]
But I will say Chase launches the Sapphire card in 2009, changing my life, like personally benefiting me.

[Speaker 1]
Kia, your rewards obsession is an entirely separate episode. But let’s go into now we took complexity, which was largely caught up in the systemically important and too big to fail institutions, which had been correlated to asset size. When we cap interchange, we inadvertently push complexity to those that are the exempted institutions, e.g. below $10 billion, which I think in and of itself had a ripple effect of unintended consequences.

[Speaker 3]
Who wants to do that one?

[Speaker 1]
Yeah, who was that directed to? Well, I was about to say, who wants to pick that one up? Because there’s so much to talk about and not to pick on.

[Speaker 2]
I can.

[Speaker 1]
Okay, go for it.

[Speaker 2]
Yeah, so we’ll start with, you know, our favorite agency. But when we talk about, right, these otherwise less sophisticated players who are filling these voids for these services, right, there were also thresholds for supervision within the Bureau. Oftentimes, those institutions also fell below that supervision threshold.

So all you had later was enforcement. Enforcement only happens when something bad happens and things go boom, right? So these entities were not being supervised in the way you would want them to be supervised had they had nothing changed.

So that in and of itself, we can just go ahead. Design flaw, right? Like that’s a design flaw.

And it was difficult because that is one of many reasons why I think we shifted into the regulation by enforcement regime, which sort of like characterized, I think, much of the last 15 years of Dodd-Frank. When supervisors couldn’t do what they needed to do because they couldn’t really have access to the institutions that they needed to supervise, rulemaking got stalled up a lot through the whole, like rulemaking just took absolutely forever. So the only easy mechanism that they had was enforcement.

You’re not supposed to regulate by enforcement, but that is de facto what ended up happening. And I think that’s a direct result of, Jason, exactly what you just said. Although I feel like I have to start calling you Hendrix now because everyone’s calling you Hendrix and I always call you Jason.

Oh, man. Makula, I blame you for this.

[Speaker 1]
Well, go ahead, Gia.

[Speaker 3]
I was just going to say, you know, we all take it for granted now, but the creation of the Durbin Amendment that put a price cap on this transaction that like, and I don’t, I kind of remember a world with free checking and I guess my debit cards, and I remember checking rewards and that this was, and I was kind of like, I’m wondering, like, it seemed to have been added to the Senate version of the bill and it wasn’t in the House version and then it kind of got passed.

And obviously it’s pitted retailers against banks and, you know, I guess retailers won this one in part because I think that there was just this idea that banks just shouldn’t make this much money. And so being a bank reporter, when this goes into effect, a number of things happen. So we all remember that Bank of America tried to put on a monthly fee and people really rebelled against this because they felt like this was a free product.

It had always been a free product. How dare you charge me for me running my account? And I really think banks struggled to kind of explain, no, no, no, this is like, we made money on the back end to give you this thing for free.

And it was kind of a symbiotic relationship. And now we need to revisit those, like that relationship. At the same time, people still are very upset about the big bank bailouts.

So they think that like, they think that Bank of America is screwing them over, whereas Bank of America feels screwed over by this amendment. The other thing, too, is like, it sets off, obviously, a series of chain reactions. We can talk about it from BAS, and I’m sure we will.

But I see that it’s completely reshaped the landscape of the banking industry in a way that I don’t think everyone fully appreciates why we have X number of big banks and Y number of small banks. But it is really creating this $10 billion, more than I would say the $50 billion threshold or $250 billion now, is really shaping incentives around how banks grow and how they manage for their future.

[Speaker 1]
I have to comment on the B of A piece of this, because I do not have any problems with a bank getting paid that, hey, we had this symbiotic relationship. You just didn’t realize how you were paying, right? If you don’t know who is paying, you are actually, in fact, the product in this case.

The problem I have with it, like getting paid for the service they provide, I actually love the level of transparency if I can see the fee attached to it. The problem I had is if you had a B of A credit card, you got it for free, which is actually a sleight of hand to say, hey, we know we’re going to make more money if you have a credit card with us.

[Speaker 3]
That’s fine. That’s fine.

[Speaker 1]
That got on the watch. No one gets into credit trouble if they’re trying to use a debit card to spend responsibly.

[Speaker 3]
I mean, that’s what they’re trying to do now. They want your debit card. They want your deposit and they want your credit card.

Sorry, Dar.

[Speaker 2]
I mean, no, I was just going to say that particularly during the era of two particular administrations, it wasn’t just about like banks shouldn’t be making any money or they shouldn’t be making too much money. Like nobody should be making too much money.

[Speaker 3]
No one should get paid for anything. I will agree with that.

[Speaker 2]
Yeah. That’s all. That was that was that was my two cents on that topic.

[Speaker 1]
Hi, this is Rob Tercik from The Futurist podcast, which is part of the Provoked Media Network. I’m excited to tell you about some news. The Futurist is expanding into the real world.

We’re doing a live event in Dubai. Now, folks who listen to The Futurist podcast, you’re going to be familiar with the fact that my co-host Brett King has been working very hard in Dubai and other parts of the Middle East for a long time. And for more than a year, he’s been putting together this event.

And now with the help and support of MasterCard and Emirates, MBD and many other partners, we are putting together the world’s largest Futurist meeting in Dubai. It will take place at the fabulous Jumeirah Beach Hotel in Dubai, and it’ll be on the September 22nd and 23rd this year. So just a few weeks from now, the speakers are going to include some of the world’s leading Futurists and forecasters and future thinkers, people like Brian Cox and astronaut Scott Kelly.

Of course, Brett and I will be there to conduct interviews and introduce some of the other folks. We’ve got speakers from around the world. And if you’re interested in meeting Futurists in person and participating in an event that attracts the future-minded, please join us on the 22nd and 23rd of September.

You can learn more about it at FuturistEvent.com. That’s Futurist, singular, Event.com. It’s all one word.

FuturistEvent.com. And that’ll tell you all about the event. I sure hope to see you there in Dubai on the 22nd and 23rd of September.

Thanks. Well, I mean, I think that naturally brings us to everyone’s favorite agencies. You talked about the CFPB that, you know, talk about reshaping.

You know, we bring in for the first time an agency whose purpose, like the only agency in financial services that has consumer in the title and has a pretty big badge to be the new sheriff in town that I think also had a whole lot of unintended consequences in terms of how it was set up. And Alex, I’d love to tee that up to you because you’ve written quite a bit about the CFPB, not just as of late, but over time and the role it played. Yeah, I mean, the thing that’s interesting about the CFPB is, as you’re saying, like it’s the first agency that’s created that sort of centralizes all of the consumer protection laws and oversight and kind of regulations in financial services into one single agency.

So we’re not going to split these things out. We’re going to have the CFPB lead on this. And, you know, the roots of it were very, I would say, technocratic, right?

I went back and read a bunch of old stuff that was written, actually, a lot of it by Elizabeth Warren, who was sort of the architect of creating the CFPB back when she was a professor at Harvard. And, you know, she talked about it in the context of, she described it as like a financial product safety commission, right? So the idea was that it would promote the benefits of free markets by making sure that consumers could enter the financial market with confidence and that the products they were buying had these minimum safety standards.

So in the same way that we don’t expect consumers to be able to vet out the engineering behind a toaster or a car seat, we shouldn’t expect them to have like the financial engineering expertise to understand these products. And if they were safe or not, there should be some minimum level of guaranteed safety. And I can tell you, having talked to a bunch of people who were there in the early days of the CFPB, like they were very cognizant of not having too much overreach that would cause a backlash, right?

They actually, a lot of the folks that they talked to when they were setting up the CFPB were like old timers who worked at the FTC back when they got slapped around by Congress for overreaching on advertising for kids’ television and a bunch of stuff that happened in like the 70s. And so they were very aware of like, we need to set up an agency that’s technocratic, that doesn’t really take sides, that’s pro-consumer, pro-competition, and we need to focus on like building an institution that will last. That has not happened, right?

Like I think the history of the CFPB over the last 15 years, and we can talk about why, is it’s become an incredibly politicized agency. It has really sort of seesawed back and forth, depending on who’s in power in the executive branch, between being very sort of pro-markets or even sort of pro-incumbents to a degree, to being very, very like outrageously pro-competition, to being very sort of, I would say in the last couple of years, almost sort of anti-capitalist in a way. So it really has swung back and forth in a bunch of different directions.

And I think the problem, as we sort of know, just with regulation generally is, when institutions don’t have a sense of what the rules of the road are and that they won’t change too frequently, it makes it really, really difficult for responsible actors. And it sort of opens the door for irresponsible actors, right? And everything we’ve seen in Bass and other places is, as Dara was saying, if there’s not going to be any supervision, we’re not really going to pay attention to this space.

If something blows up, we’ll get involved in it. And that’s just, that’s a recipe for consumers getting hurt, which is the opposite of what the CFPB was set up to do. Well, you tend to wait until something really bad happens.

And the problem is that those course corrections, right? It’s like having a two-year-old, if you wait until you’re having the absolute meltdown laying on the floor, kicking and screaming, as opposed to intervening earlier when things are getting off track, right? Like they have very different implications for how things are going to go down.

[Speaker 2]
I would also say that it’s really important, Alex, you mentioned sort of like the old-timers at the FTC who were there. A lot of, we haven’t really talked about UDAP yet, but you can’t really talk about the CFPB without talking about UDAP, which was right there, big, bad, broad, very broad.

[Speaker 1]
Adding a second A broad to UDAP.

[Speaker 2]
Adding a second A broad. And the reason that that’s really important is because, so UDAP, for those who don’t know what it stands for, it’s Unfair, Deceptive, and Abusive Acts and Practices. The FTC Act, which was sort of like the precursor to that, only had definitions for what was unfair or deceptive.

The concept of abusiveness is brand new with UDAP. That was not something that had been litigated, interpreted, anything of the sort. So now you have a new agency with new rules.

And while I appreciate that those who were there sort of like early on with the agency maybe didn’t want to go too far, the Cordray era of enforcement was just very zealous, right? Like they were very, very zealous consumer advocates.

[Speaker 3]
But that makes sense if we think about it in the context of the financial crisis, right?

[Speaker 2]
Who weren’t, but their job isn’t to define a term that doesn’t have a definition. And that is the problem that I have as a lawyer. You can’t just call something abusive because you think it’s abusive.

You’re four years out of law school. You’ve never tried a case. You don’t get to on the fly, make up the law and put people out of business as a result of your own personal interpretation, which is exactly what was happening.

[Speaker 1]
And I think one thing to add to that, just because I think it is really important context that Dara is kind of hinting at is like the CFPB was like the new fund agency to join at the time. Right. And so like when you talk to folks who were there, it had its roots in this like technocratic, like we’re going to bring in people from outside.

We’re going to bring in people from industry. We’re going to recruit a whole bunch of younger people in almost sort of a startup environment. And like, we’re going to try to do this thing.

And I think, I mean, I can tell you, having talked to a bunch of people who were there, there were debates like, I mean, the Cordray era more than anything from what I’ve heard was characterized by almost an academic vibe of like, we will debate the shit out of every single thing that we’re doing over and over and over and everyone will get a say. And what was interesting kind of to Dara’s point is there were these cases and you can ask them about it, like, you know, with the benefit of hindsight, like which cases kind of defined the culture of the CFPB. There are these cases where they’re like, should we go this far?

Should we do this thing? Should we make this penalty this amount? And they were debated heavily.

But Dara, to your point, they, I think, ended up in a lot of cases defaulting towards a pro consumer. We want to set an example here. We want to discourage the market from doing this.

And a lot of that was novel. A lot of it was going too far. Some of it was subject to significant legislative or sort of legal pushback.

And that kind of started, I think, the cycle of there’s this famous case where one of the judges who ruled against the CFPB was Brett Kavanaugh, who ended up on the Supreme Court and then was ruling on questions about the constitutional structure of the CFPB. So it did start this cycle of we’re going to try this. We’re going to get pushback.

We’re going to respond to that pushback. And I think that kind of paints a picture of where the CFPB is now. And I think more than any agency, one, the politicization of it.

But two, Derek, to something you had called out, like the whiplash. And I think one of the problems, Alex, is you had said, and let’s delve into this a little bit, the good actors don’t like uncertainty. So they tend to hang back.

And the, let’s call it not necessarily bad actors, but those who are less risk averse, right? I’m a startup. I need to go find product, market, fit and scale before I run out of money.

Or I have a large- I’m thinking about 10 years from now, those kind of companies. Yeah. In the big companies, right, where a couple tens of millions dollar fine is the cost of doing business.

And I’m willing to navigate gray areas to be opportunistic in this regard. If we roll forward now, I don’t think we have to describe for any listeners, the CFPB has been effectively gutted and people are wondering what’s happening there. Let’s roll forward.

15 years from now, what do we think we’re going to be talking about? Because we’re going to have, at the very least, an era of four years with no CFPB.

[Speaker 2]
I think that those who have always wanted to do the right thing and have always just wanted a comprehensive set of rules to follow are likely going to stay the course. State AGs still have enforcement authority under UDAP and their own laws, obviously. So for those legitimate organizations that want to keep doing business, I think they’re going to breathe a little bit because they’re going to be less worried about a massive CID hitting them and them having to spend millions of dollars responding to it.

But I don’t think that they’re going to say, okay, it’s a free-for-all, we can do whatever we want, and consumer protection statutes go out the window. The laws on the books are still the laws on the books. All the interpretive guidance, that’s getting flushed down the toilet, but SCOTUS did that for us, right?

Like Loper Bright did that for us. We don’t even have to worry about the CFPB. So I think that there is the possibility of those more aggressive, quasi, I don’t want to say bad actors, but more those prone to risk-taking.

Yeah, we’re going to see some gnarly products again. That’s what’s going to happen, especially when we talk about the passage of Genius Act 2. There’s going to be a lot of really gnarly products on the market, and consumers are going to get excited about stablecoins, and there’s going to be legitimate businesses that offer them.

I’m not talking about, no offense, Jamie, I’m not talking about the JP Morgans right now, but there’s going to be other people who start to offer that through whatever wallet is going to be in the consumer’s phone at the time. And yeah, I think we’re going to be sort of back to where we were, but the legitimate businesses are going to stay the course.

[Speaker 3]
We never deviated off of it. I mean, I think what will happen in part with what we’ve seen with banking as a service and some of the practices and consumer harm that has come from that is actually we’ll live in the world where we have the financial regulation or financial innovation, but we won’t have the consumer protections that really needed to govern those things, right? And so I was joking with some friends about the Delta using AI to determine price for tickets, and I was like, man, if there’s only a consumer financial protection agency that could, or a bureau that could govern and could look at how they’re using pricing, AI pricing and models.

And we think about AI being used throughout all sorts of financial services models or marketing that might have unintended consequences when it comes to discrimination and credit availability or marketing of credit products and even potentially pricing of those products, right? If only we had a consumer financial protection agency that was interested in addressing some of the practices we see at banks and at non-banks.

[Speaker 2]
Well, Kia, just on that topic, there have been many, many states, and I think there are going to be many, many more states that are introducing AI-specific bills specifically for financial products requiring the disclosure. So I do think that in a lot of ways, the states are trying to fill the void there. It’s not comprehensive yet, but just like we don’t have a National Privacy Act, we’re not going to have national AI legislation.

It’s back to 50-state patchwork.

[Speaker 3]
It worked so well in 2006, no thing to be worried about.

[Speaker 2]
Well, mortgages and military, I think those are the things that the CFPB are still going to pay attention to.

[Speaker 3]
Only because they got forced to. Someone pointed out the CFPB calculates a rate, and so you need to have someone at the CFPB doing that spreadsheet every day.

[Speaker 1]
Well, I mean, that’s the I think that’s the other thing that’s kind of interesting about what’s happening with the Bureau right now is there’s kind of this interesting question of like, what is the minimally viable form of the Bureau look like and how many employees and how much money do they actually require for that? You know, $5 million going to Russ Vought’s security is sort of its own separate topic on that front. But I mean, I think that there is this question of, you know, like what?

We’re not going to talk about that. How much how much like how much can you really cut down the CFPB and still have it be effective? And how much can you cut it down and still have it sort of facilitate its congressionally mandated sort of required jobs that it has to do?

And, you know, a lot of it, a lot of the slack is going to get picked up by the states, as Dara is saying. A lot of it is also going to, I think, end up in private litigation. Right.

Some of these statutes actually allow for that as well. And so we’re going to see again, you know, the financial industry finds a way like there will be ways that we address some of these concerns. But I don’t know.

I mean, I from my perspective, one of the biggest things that we might be losing with the CFPB that I actually really valued is just data collection, right? Like consumer complaints. That was a brand new function on a federal level that didn’t really exist before.

And just the ability to have data and to understand what’s happening in the market. I always really valued the CFPB’s role in helping to try to understand how the industry is developing, where it’s going, how it’s impacting consumers. And there is going to be something that gets lost, though, that will be hard to rebuild.

[Speaker 2]
I will say I value the role. I don’t know that I value the data having had to respond to it. More of those portal complaints than I can possibly count.

But, you know, garbage in, garbage out. Well, it’s pros and cons, though, right?

[Speaker 1]
I remember Brian Armstrong, CEO of Coinbase, talking about, you know, we should be deleting the CFPB back a few months ago. And there are cases of Coinbase customers getting locked out of their accounts and then that problem being resolved due to complaints given to the CFPB. So it is one of those things where, as with anything, there can be too much and it can go in a bad direction.

But there was a value to doing that that I think we are going to miss. Well, hitting the balance is the key, right? Like making disputing a charge too easy leads to a whole lot of first-party fraud.

Making it too easy to make a complaint leads to a whole lot of garbage data in that lawyers like Dara need to be responding to. But there is a role in collecting data and being data-driven rather than either politically or ideologically driven in how we regulate. Now, before we run out, go ahead.

[Speaker 2]
No, I was just hat-tipping, that’s all.

[Speaker 1]
Yeah. We talk about how much this has reshaped the financial ecosystem. With the passage of the Genius Act, do you think we’re at the same set of like recarving the landscape that Dodd-Frank has?

Probably in anyone’s lifetime here, Dodd-Frank was the biggest force that has changed that landscape. Does the Genius Act have the same potential to do that?

[Speaker 3]
I think the Genius Act is closer to the interstate banking rule or law that was kind of a catalytic permissive structure for growth. I don’t think it’s like, and to be clear, I don’t think this is about or for banks per se, but it is going to be one of the bills that reshapes our financial landscape rather than what Dodd-Frank is, which was financial reform for a landscape that had been shaped by changes in interstate banking and the ability for commercial and investment banks to be acquired.

[Speaker 1]
Yeah, I mean, my two cents on it is kind of building on Kia’s point. I don’t think the Genius Act really concerns itself that much with market structure, right? Whereas Dodd-Frank was very much like, how do we structure different parts of the market?

How do we give different rules to different parts of the market? How do we make the market safer? I think the Genius Act is much more about enabling a new form of economic activity within the financial services landscape.

And candidly, I wish they had spent a little more time in drafting the Genius Act thinking about market structure and how it affects market structure, but I don’t really think they did. And I think it’s hard to say what impact it will have from that perspective.

[Speaker 2]
I think it’s really hard to be like a transformational bill when you don’t define what the actual thing that the bill is about actually is, right? So from a legal practitioner’s perspective, you can’t define something by defining what it’s not. And stable coins are not money.

Stable coins are not securities. But the Act doesn’t define what it actually is. It only defines it by what it’s not.

So I agree with everything that Kea and Alex just said. And also, it’s crappily drafted, and I don’t know what agency is going to make rules under it.

[Speaker 3]
When Alex and Dara were talking about the CPB a little bit ago, I was just really reflecting that Dodd-Frank was a bill about who is worth protecting and saving and preserving and who is not. And so how does Dodd-Frank interact with Chokepoint? How does Dodd-Frank interact with CFPB, right?

And how does Dodd-Frank change who gets loans from whom at what price? And who gets to collect money from debit interchange twice? And I don’t think the stable coin bill concerns itself with that question of who is in and who is out or who needs to be protected and what is the price of that protection.

But I do think, as we think about this reshaped landscape, this dismantling of the 15 years to build at Dodd-Frank, and then what will come in its place? And is that stable coin, question mark? Is it financial services finding a way, question mark?

It is really interesting to reflect on, did this bill do what it was supposed to do? Did it protect the right people at the right price? For me, did it stop bailouts, right?

Did it stop systemically important financial institutions from requiring taxpayer-funded bailouts, right? But yeah, sorry, Jason. I was just reflecting on this who’s in and who’s out nature of the bill.

[Speaker 1]
Well, I think that’s a really important way to think about this, because at its heart, I think part of what Dodd-Frank was really trying to solve for is to put some definition around that, right? Because too big to fail without definition created moral hazards. And so the idea of moving towards systemically important became a real key.

The idea of saying, hey, we need to be thoughtful about how much is made in interchange and what thresholds we apply more oversight became really important. I just wonder if the downfall of the bill wasn’t we tried to put too much in one thing. And I’m curious, as we come to a close here, would you say Dodd-Frank was successful?

And if you had to redo anything to say it was successful, what would you change about it?

[Speaker 2]
So here’s what I’ll say on that. I think in some respects, the bill was successful because it made people pause before they made certain choices. And I think that that pause because they were nervous about the size and impact of what enforcement could potentially look like.

I know for a fact that certain organizations made different choices than they otherwise would have made, but for the CFPB breathing down their neck, that being said, where I think it was unsuccessful, very unsuccessful, is that it had the natural consequences of picking winners and losers within the industry. And it absolutely did that because those that could afford a CID, those that could afford a fine, proceeded with business as usual. And legitimate businesses who were trying to do right just by, you know, being the size of what they are, were literally economically incapable of responding to an agency that was the 600 pound best funded gorilla in the room.

And I had the misfortune of watching many, many organizations who I worked with closely not being able to participate in the industry at all anymore. And that sucked because less consumer choice is bad for consumers. Yep.

[Speaker 1]
Yeah, I mean, I would say from my perspective, I would give it overall a passing grade in terms of it probably was on balance, probably a good thing for the industry for a lot of the reasons Dara just said. I do agree that there were these areas and the CFPB is probably the best example where it could have gone one way or the other based on some very specific choices that were made over the last 15 years. And some of those choices just didn’t work out.

And they led to a lot of the things that Dara specifically outlined that caused problems for the industry, lessened the amount of competition in the industry, picked winners and losers. And I don’t think it had to be that way. I don’t necessarily know that I blame Dodd-Frank the bill for that so much as just as a lot of things, when you’re implementing it, when you’re in the room, when you have to decide path A or path B, those choices can be difficult in the moment.

But with the benefit of hindsight, I do think it’s pretty clear that a lot of those were the wrong choices and kind of led to some of the things we’re seeing today.

[Speaker 3]
And from the banking perspective, I guess I’ll be, I guess, represent chartered financial institutions. I think it was net good that banks should hold more capital. And we can argue about those levels today.

But in 2007, they were not high enough. I think the stress tests are good exercises. I think banks should do them.

I don’t know if they were always perfect under CCAR. And so, you know, the process itself. But and I also think that the work to comply with a stress test is a good exercise for banking.

And we didn’t even talk about the data that would be used and the modeling that would be used to comply with this. And if you think about making those investments 15 years ago in response to DFAST and CCAR, and the way you’re able to use your data today because a regulator made you have good data to pass, and whether or not, again, they needed to do the full Monte, but the fact that banks were forced to do this work, I think, is something that banks are benefiting from today. And I think you can actually really see this from the really the legacy, the 50 billions that have been doing this work for 15 years.

I think it’s also really useful that the Fed would kind of like non object to how much capital you need to keep and then how much capital they have not objected to you distributing. That’s very useful, I think, for modeling. I think the asset thresholds was a really lazy way to think about banking.

And I think it was a mistake to make these fixed. I think we had no concept of what is a big bank. And so 10 billion is inappropriate probably for Durbin and 50 billion was probably too low for CCAR.

And I don’t think there was an appreciation of exactly what that was going to mean for banks managing around that threshold and what that meant for what kind of a banking industry we want to see. So but I will say like for I think for and then the other thing, too, is like, I don’t know if banks when they complain about the risk weighted assets or when they complain about these capital ratios, if they’re really like, OK, if you didn’t have the role, would you be making all these mortgage loans and then at like 3 percent and selling them? You know, like I so that’s kind of hard to argue.

And I know banks always want to argue. And I do for the first 10 years of my career, first five, 10 years of my career, banks were defined by like, everyone hates you. Like, remember, you almost destroyed the whole economy.

Everyone kind of is still mad at you. You probably shouldn’t complain too much because we saved all of you, you know?

[Speaker 1]
Yeah. Building on that, Kia, one of the things I think that I will ultimately say was successful about it is this idea of let’s acknowledge that there are these third party relationships, right? The rise of banking as a service, the use of non-bank originators, right?

Let’s be more inclusive of how we think about this. Now, I think was it implemented well, you know, over the last 15 years? Not really.

Is it beginning to get better? I hope so. At least some strides have been made, but at least there’s some transparency around it.

And I think as we look forward and hopefully we’re not doing this 15 years from now, you know, doing a look back on is Dodd-Frank, you know, still good? I think it’s important for us to, you know, continually revisit regulation rather than waiting for really bad things to happen or forcing outside of regulation and regulating by enforcement, as Dara pointed out. You’re also not the right way to approach this.

As we come to a close, each of you, parting shot, what do you want people to be thinking about when it comes to this idea of, like, as we regulate, whether it be things like Dodd-Frank and Durbin below that, how 1033 is implemented to the Genius Act? How do we need to be rethinking both the role and mechanism of regulation?

[Speaker 2]
I’ll start. I think one area sort of like philosophically that is sort of plagued Congress and plagued a lot of these acts, 1033 is actually a great example, is that it’s hard for industry to comply with a mandate as opposed to complying with a framework. So as we move forward and if we want to pass laws and if we want to shape markets and protect consumers and like broaden our financial ecosystem, mandates aren’t going to do it.

Mandates aren’t going to do it, especially when you don’t have regulators to implement frameworks. So they have to go hand in hand. And I don’t think that they work otherwise.

That’s how we end up in courts fighting over rules. That’s how everything gets stalled. We are a litigious nation.

We love to fight. We love to fight about everything. So Congress, rather than giving us mandates, like actually do try to give us some frameworks, especially when you have a lot of green space.

It’s not that you have to defer to the SEC on this thing because of all of this precedent. When you have green space, just be more thoughtful in your statutory drafting. That’s what I think.

[Speaker 3]
Yeah. I’ll cite Michael, Governor Michael Barr, who gave a speech at Brookings on July 16th. And his speech was about like cycles, boom and bust and the regulatory cycle.

So you asked about Dodd-Frank, but Dodd-Frank is in reaction to something else that happened. And he was talking about kind of what he’s seeing as the dismantling of Dodd-Frank and observes that the further we get from a crisis, the more its causes fade. Specifically, and over time, the financial service sector will lobby to weaken the regulation that it wants to forget why it exists.

And so when I think about, when we think about Dodd-Frank, I think it’s useful to think about what was this in response to? And if we want to critique Dodd-Frank or the enactment of the Dodd-Frank, have we actually addressed what the thing it was supposed to fix? Have we addressed its root or are we pruning its branches, right?

And so, you know, I think, you know, one thing about being a writer is you have to kind of see the cycle and you have to see the risks. And you also kind of have to understand play stupid games, win stupid prizes, right? Like if you want to criticize Dodd-Frank and all of its many tack on unintended consequences, well, did we fix the thing it was trying to fix?

And if no, let’s start there because then we’ve just created a new risk alongside our old risk.

[Speaker 1]
I love that first principles approach, Kia. Alex, bring us home. I think the central tension in any regulation or policy in financial services is between safety and soundness and competition.

And I think pretending like there’s not trade-offs to be made between competition and safety and soundness is naive and doesn’t get us anywhere. And so going back to Dara’s earlier point about picking winners and losers, I think that always needs to be the central tension that we’re being thoughtful about with any regulation and any response to the different crises that Kia was outlining. You’re always to a degree pushing on one or pulling back from the other.

And I think, you know, Dodd-Frank in a lot of ways was about restricting the ability for banks to compete and opening up competition for others. And as we go into new eras of regulation, just being thoughtful about the trade-offs between safety and soundness and competition is really important. Fantastic.

Well, thank you all for joining and keeping it less than the 838 pages and another couple tens of thousands of guidance and rulemaking. But look forward to future discussions, because Breaking Down the Genius Act coming up shortly.

[Speaker 2]
Thanks, Jason.

[Speaker 4]
Thank you.

[Speaker 2]
Thanks, Henrikx.

[Speaker 4]
That’s it for another week of the world’s number one fintech podcast and radio show, Breaking Banks. This episode was produced by our U.S.-based production team, including producer Lisbeth Severins, audio engineer Kevin Hirsham. If you like this episode, don’t forget to tweet it out or post it on your favorite social media, or leave us a five-star review on iTunes, Google Podcasts, Facebook, or wherever it is that you listen to our show.

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