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Cannabis & Digital Assets With Expert Josh Herman Of SRM

WFC 109 | Cannabis Banking

Josh Herman is a Director on the Digital Assets Advisory Services team at SRM (Strategic Resource Management), an independent firm that helps financial institutions identify cost savings and new revenue potential. In this episode, Josh explains the risks in the financial industry and the role of cannabis banking and digital assets in credit unions. He also identifies some risks in the industry and the efforts credit unions made to mitigate those risks. Delve into this episode to see the value of cannabis banking and digital assets in the financial industry.


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Cannabis & Digital Assets With Expert Josh Herman Of SRM

I'm excited to have Josh Herman with me. Josh, how are you doing?

Great to be here, Mark. Thanks for having me.

You got it. I've known Josh quite a while. He's got a great resume that I'm going to rattle off here. Josh is a Director on the Digital Asset Advisory Services Team at SRM, also known as Strategic Resource Management, an independent firm that helps financial institutions identify cost savings and new revenue potential. He’s an expert in risk management and strategy. Josh’s central role at SRM is as a Digital Asset Risk and Revenue Enhancement Strategist for Financial Institutions.

I met Josh first at NCUA, where he was a principal examiner and received several awards. Some of which he received from me, including a Rookie of the Year. He previously served as Vice President of Strategy at Frankenmuth Credit Union, where he was Chair of the Risk Committee and oversaw risk identification, risk mitigation and strategy efforts of the credit union.

During his time at Frankenmuth Credit Union, he also developed and created a leading cannabis banking program called Envy. Before that, he was previously a VP of Compliance at Comerica Bank and a Senior Associate at Doeren Mayhew. He has been featured as a guest author for various industry media outlets discussing his unique perspective on risk in the financial industry. Josh, that's a fantastic summary. You've done a lot in a short period of time. Very impressive.

Thank you. Thanks for having me. As you said, that Rookie of the Year Award you gave me, it gave me a lot of confidence. I was a second-year examiner in 2011 when I got that award from you. I'll never forget and tell this story that I got up from my computer for five minutes, walked away, came back and had an email from Mark Treichel, Regional Director of NCUA, that said, “Call me.” I go, “What in the world did I do?” It was fantastic to have that phone call with you. Fantastic to get that award. As I said, it gave me a lot of confidence as a second year examiner. Maybe I was onto something there. It's great to be on this show with you. Thank you for your service at NCUA as well. You led the agency very well.

Josh, I appreciate that. I remember when I came up with the idea to do that Rookie of the Year within region one, that was my favorite day of the year because you get into the grind of doing everything you've got to do, dealing with credit unions, staff, HR. That time of the year when you can reflect back on the year and reward people for good actions.

It was always fun to have those phone calls and surprise people with the cryptic message that led to them getting a little bit of a cash award. More important than the cash award is the recognition and the empowerment to , that so people are recognizing that you're doing well. You've continued parlaying that into different opportunities.

Two of the things I'd like to talk to you about are cannabis banking and the Envy program that you started. Also, digital assets as well. I think we'll start with cannabis banking or Cannabis. Why don't you tell me a little bit about the journey that you've had in cannabis banking?

I'll start with, I like rephrasing that, taking the banking out of that. I always feel weird saying banking. But credit unions do things differently, especially on the cannabis banking side of things. When I joined Frankenmuth Credit Union, becoming known as the weed banker was not in my immediate plans.

As you mentioned, I came from NCUA. I came from Doeren Mayhew, both positions of evaluating risk and somewhat of checking boxes and ensuring compliance and not promoting or taking excessive risk. I viewed cannabis banking as an excessive risk at the time. It was not in my immediate plans, but at a very high level there, there are two different types of credit unions in the banking space. There are yeses and noes. Most are no, meaning they don't have a program. Therefore, they don't accept any businesses or individuals associated in any way with the cannabis industry.

This even goes down to employees on a state level. A state legal business that's fully licensed. If you're an employee that collects a paycheck, there are many financial institutions that will, for lack of a better term, kick you out of their institution because you're associated with the industry. There's noes then there's yeses. The yeses develop a program. It's a very high-level comparison because even on the yes side of things, there's a wide variety of services. Some will be a checking account and some will be a full array of services in a fully developed product suite.

The first part is saying yes. Take it even further for context, the way that cannabis works in Michigan is that it is state legal. I know that's not the case for all 50 states yet, but there's some progress being made there both for adult use and for medicinal purposes. There's a licensing process that businesses have to go through.

It's extremely strict and extremely regulatory and regulation-driven from the top within the State of Michigan. Even though it's state-legal, communities have to opt into allowing these businesses. For example, there are townships and cities around me that did not opt-in and there are some that did opt-in. You can usually tell the ones that did opt-in because there'll be more than one dispensary, more than one grow facility. You can tell the ones that didn't because there's an absence there.

Going to Frankenmuth, once all of this got kicked off a little bit with communities opting in, we quickly saw that communities that surrounded Franken's footprint were opting in. Frankenmuth’s CEO, Vickie Schmitzer, has been there for 40-something years. I think she was employee three at the credit union. She’s a fantastic leader and fantastic CEO.

She came to me and said, “We need to figure out a way to say yes to these businesses. We exist for our membership. We need to make sure that it's compliant, but we need to make sure that we're serving our membership. We need to figure out a way to stop saying no to our members because it's only going to grow.” It took a little while to the point of me saying yes, but that's what we did. At the end of the day, Vickie and the credit union making a conscious decision to say, “We're going to serve our membership here and figure out how to serve our members.”

We exist for our membership. We need to ensure we're serving our members and figure out how to stop saying no to our members to grow.

Thanks for that. It's interesting. My many years at NCUA started as an examiner and ended as an executive. During that journey, I went from being risk-averse to being much more comfortable with risk. It sounds like that's the journey you went through from your early days at Doeren Mayhew and NCUA. Now you're going, “There's all these rules. How do we get to yes, where you're in charge of making sure that you're compliant, yet, you want to be able to serve those members?” Your history at NCUA, did that help you? How might it have shaped what you first learned and what you were comfortable with in cannabis banking?

That's a good insight because you understand that the process of going from the examiner to the risk manager to the risk taker. Something that I get questioned on a lot is how in the world do you go from NNCUA examiner to building a cannabis banking program? The two don't seem to go together. There's something interesting. The current NCUA board understands this too, that regulations aren't necessarily prohibitive.

They're more prescriptive. Stay within these boundaries and build a program that you need to build to serve your membership. My time as NCUA examiner, whether it was reading regulations, guidance, both on the federal level and on the state side of things. In Michigan, it's the DIFS and so I got very familiar with reading the state documents, which are different than the federal documents. I also became familiar with what you mentioned, which is seeing the big picture of risk.

With cannabis banking, that was identifying what the real risks were. A lot of times, at least for me, looking at something that I'm unfamiliar with, it seems complex and that complexity makes it seem risky. The more, for me, when I dive into something, it becomes less complex and you can pull it apart a little bit. You can find out where the risks are.

NCUA and my time as an auditor helped that. Once we pull apart what cannabis banking is for a credit union, what the industry looks like, we can identify what the risks are. Now with those prescriptive regulations and guidance out there, we can build a program that stays within those rails. Also, serve our membership at the same time. Being an NCUA examiner, even though it seems like a paradox type of situation, it helps build a compliant program.

Talking risk, talking challenges, what would you say the primary challenges credit unions are facing when they want to provide services to the cannabis industry?

The first one, and I forget about this, is the stigma still. After being in the space for a few years, I forget that there's a stigma out there that exists about the industry. I would say that's the number one hurdle. The number one fear of credit unions entering the space is not compliance risk. It's not a BSA/AML. It's what's our membership going to think if we enter into this space.

I can tell you from experience, that was a concern that we had. What's our membership going to think? Thirty-plus branches, 60,000-plus members, all it takes is a couple of complaining members on social media or something for you to get a bad reputation. What we found out was the industry is very professional. The ones that you want to bank with you are very professional. They're very compliant. They're held to a lot of regulations.

They want to stay compliant. They're not going to walk into your branch and you're not going to have any issues. I stayed very close with the front lines at the branches that we had opened and said, “Are we having any issues? What's going on here?” The biggest concern was, is the cash going to smell? That's what everyone wants to know.

Once you understand the process of the way it works, so typically as an ATM, you go get your money out of the ATM. You go up to the register, you purchase or whatever you're purchasing at the dispensary. The cash then goes into a safe, the owner takes the money from the safe and takes it to the institution. There's not even a whole lot of exposure for the smell to be there. What I heard from the front lines was, “We're having no issues with these members, but because it's legal in our communities, our normal membership is smelling more than the businesses are.”

We go, “We don't have a reputation problem here. We're doing what we set out to do,” which was serve our memberships.” The first was the stigma. Second is never getting educated on the topic. Once you get over the stigma, you say, “We're going to serve this business.” It's very important to get educated on a topic because you find out that you're going to build a program that might not meet the needs of your membership.

It's important to get educated on a topic because you will not build a program that might not meet the needs of your membership.

Educating yourself on the industry and what your local businesses need. Third, I think this is a big one, is entering the space scared. You get over the stigma, educated on the topic and you still hand out your membership form with your hands shaking a little bit. “Please don't sign this paper. We’re offering it, but we're a little scared of the space.” What I said before, these businesses want to stay compliant. They are held to more regulations, at least in Michigan, than perhaps any other business industry in the state. To have an issue with one of these would be an outlier.

When the credit union approaches this with a scared mindset, you end up treating these businesses like a criminal, which is not what you want to do. We've found that we got a lot of comments. We didn't get comments about how great our fees were. We didn't get comments about our product offering, which our fees were lower. Our product offering was great.

We got the most heartfelt emails from our membership saying, “We felt like we were normal when we walked into one of your branches. We felt like we didn't have to hide what we were doing.” Starting from the top, that was the goal from the CEO, Vickie. It permeated all the way through to the front lines that these businesses who could finally go someplace where they could be a state legal business. There are a few things, a few hurdles that credit unions need to get through, but it's becoming easier to get through those.

That's interesting and that fear part, entering the space scared relates to the AML/BSA side of not wanting to violate that and know your customer and all that. From the beginning of the journey through the end of the journey and maybe even from thinking back to your NCUA time, was it the Kohl memo that drove a lot? I read it back in the day and I don't do much in it now, but I always can remember that as something that NCUA looked at back then.

It's easier now from a regulatory landscape. Have you seen the regulatory landscape evolve? What considerations should credit unions keep in mind when navigating that space? Even though the regulations used to be a little bit more aggressive because it was new. As you said, it's not legal everywhere. Hopefully, eventually, the Feds will come to their senses and make it legal so everybody can bank everywhere and everybody can be treated as normal. What have you seen relative to the landscape in this whole arena?

On the federal side, I've seen a lot of promises and a lot of high hopes for years. It seems like we do the rollercoaster a few times every year with nothing happening. Promises of a safe banking act going through, promises of sections of the safe banking act going through.

The problem on the banking side of things for a financial institution, the problem is it's federally illegal. If you take funds from something that's federally illegal, you're essentially money laundering.

There is that mindset of and we had an attorney say it to us, “There's money laundering, then there's illegal money laundering.” Leave it to an attorney to say that. I like the way that he said that, though, because there does have to be an understanding of that’s essentially what FI’s are doing here because of the way that marijuana and cannabis are still scheduled, but because of that, 1) There's not every front institution is in the space.

2) Visa and MasterCard are sitting on the sideline here. Not only can you not offer merchant services and things like that through MasterCard and Visa, but your membership can also not go to these establishments and use their Visa or MasterCard or branded card. There are alternatives in the space for payments that isn't necessarily cash intensive. For the most part, there is still more cash in these businesses than your average retail establishment out there.

There is a big need for legal banking services that everyone can have access to. That's on the federal side. On the state side, I know every state is different, but things have been great in Michigan. I know other states, it's not going as great. In other cities, it's not going as great. We've seen states adopt and continue to adopt. We have an interesting situation here, so states tax these businesses. The federal government taxes these businesses.

I can only assume that the state and federal governments are making the most money off of this than anybody. I'm not in the government. My perspective, there's not a whole lot of motivation to change anything when you're getting a lot of funding coming from this now. On the federal side, we're on that rollercoaster now, where there are promises and hints that something's going to pass.

Stateside is perfectly fine, but as long as you're in a state where it's legal. My personal opinion is that other than needing Visa or MasterCard to get on board and things like that, if you're a credit union sitting on the sideline, you don't need to wait for that federal clearance to get in on it because NCUA is going in and examining federal credit unions. Not even State charters but federal credit unions. Not giving them a prohibition on doing it because it's federally legal. On the state side, it's going to be state legal. We're on the rollercoaster on the federal side now, but I would not let it prohibit or inhibit a credit if they want to get in.

In that regard, setting aside the resolution we need on the federal rules. Can you highlight some key operational and compliance issues or factors that credit unions should consider when they're considering serving these cannabis businesses?

I've talked to various credit unions over the years. Even Frankenmuth was about cannabis banking. Typically, these programs want to be built in a silo. Whether it's a separate name or its own vertical within the credit union, there's a desire to have it be separate. I think that's fine. There are pros and cons to that approach.

I would say make sure to include the necessary departments in that vertical. I've seen them built up and you forget accounting or integrating with your cord or something like that. A major piece is that once you start onboarding accounts, it becomes a big issue. Second, and you touched on this, compliance is key. Understanding the issues and potential issues and red flags and the flow of funds and business structures is very key in running a successful program.

WFC 109 | Cannabis Banking
Cannabis Banking: Understanding the issues and potential issues, red flags, the flow of funds, and business structures is key to running a successful program.

There has to be an acceptance of these business structures. These businesses are used to operating under the radar. We see some of these business structures that the web is tough to unwind, but you have to put in the effort to unwind that. As long as everything's on the up and up, they have a place to go and bank because it looks different than what your normal businesses look like. It's not a reason to turn them away.

In Frankenmuth, we spent hours trying to un unweave some of these business structures because that's the way they've had to operate under the radar. Ensuring compliance with all of that is ultimately key. Trust your gut. If something doesn't feel right, you still have the prerogative to say, “We're not comfortable with this, so we're not going to do it.”

On the silo thing, there's a book I refer to a lot on my show here called The Wisdom of Crowds. You need to get the wisdom from all the departments. I was talking about enterprise risk management and the importance of enterprise risk management as it deals with different risks.

Everybody has blind spots and if you do it in a silo, I would recommend being inclusive when you're looking at that. I could see where they might want to do that, but that's an interesting thought. Success stories or examples of credit unions that have effectively navigated this process. Can you share some success stories and what contributed to that success?

I can talk about some who have gotten into the space. I'm not going to give any names on that side of it, but who have gotten into it. They either wanted income or some financial gain from it. I'm not saying a financial gain is wrong because it's not. That was on our radar when we were looking at it, but from my perspective, it needs to be mission-focused.

If you're entering the cannabis space, for us, it was a passion for saying yes to our members and not turning them away. We dug in. We figured out the cannabis industry. We figured out the risks associated with and how to offer a wide array of product offerings. Being mission-focused is key. Frankenmuth is a good example of a success story where the financial benefits are there. The deposit influx is there, but it was done with compliance in mind.

It was done with the user experience in mind. Our first couple of months, we monitored the program on a monthly basis, the financials and other KPIs and things like that. To this day, I'm no longer there, but the success of the program is measured by, are we treating these businesses as normal as we can? The rest is going to come. That’s a general business practice as you treat people. You don't have to worry about the rest of stuff. Everything else is going to fill in around it.

Frames goal from the top, treat the businesses as normal as possible, treat them with that Frankenmuth touch or whatever. Treat them with that special membership touch that you have and the rest will fall in place. If you go into it with solely financial goals, it becomes clear and evident. Good advice and a good strategy is to be mission-focused, find out what that mission is, then that'll drive you through a lot of it.

Mission-focused, do the right thing, serve your members, all seems like noble reasons to trying bridge the gap and provide this service. That's great. Let's pivot to digital assets, which is what you're doing now at Strategic Resource Management. When I say digital assets, that might mean different things to different people. When I say that, what do you mean by the term digital assets?

First of all, let's pivot from high risk to high risk. The NCUA examiner journey gets more interesting here. Digital assets, this is something that you mentioned on some of your other episodes, too, is trying to get to the definition of something. You go to or you Google it or you ask ChatGPT, what does this mean? Digital assets is not something where you're going to get a consistent answer.

It makes it tough to have a conversation around something when the definition is so different. I have a couple here. IRS defines it as any digital representation of value, which is recorded on a cryptographically secured distributed ledger or any similar technology specified by the secretary. They include examples of convertible virtual currency, cryptocurrency, stablecoins and NFTs, non-fungible tokens.

That seems an okay definition. We go to National Institute of Standard and Technology or NIST. They say, “Any asset that is purely digital or is a digital representation are physical assets.” I like that one even more. There are less caveats to it and it's pretty streamlined. The number one search research is up is going to be Investopedia. They say, “Anything that's created in-store digitally, it's identifiable and discoverable and provides value.” Now, we're getting down to literally breaking apart the two words, digital, which it's in digital forms, assets, so as value.

The NASDAQ says, “Anything that exists in digital form comes with a distinct usage.” The point is, it's tough to narrow in on this. We have the movement of changing the branding of crypto, which got a bad name because of FTX and some of those other things, trying to rebrand that as digital assets and put it into that bucket and use them as synonymous terms, which they're not. Digital assets, in its truest form, is probably a combination of all of these definitions. When I talk about it, it does have to do with cryptocurrency, Stablecoin, NFTs, tokenization, different things like that that we generally put into that bucket is typically what I'm referring to. It's tough to get a definition for sure.

I think about the IRS. They probably had to have some level of deeper precision because it all comes down to collecting the tax. If they were vague, someone could make the argument that it wasn't taxable.

I thought about saying, I can't define it, but I know when I see it. SEC Chairman Gensler uses that. I don't want to associate with that one.

That's like safety and soundness. That's a whole other episode. I think I've got one on that. We talked about the opportunities and benefits of cannabis banking. What are the opportunities and benefits for credit unions diving into digital asset services in their offerings for their credit unions? A follow-up to that, how can digital assets enhance the value proposition for credit unions and their members?

The credit union industry as a whole is in a good spot now. Kudos to NCUA’s board for that because they have not been sitting on the sideline, especially Vice Chairman Hauptman. I'm not going to say he's been an advocate for this, but he's been an advocate for responsible innovation. He's very clear about saying do it responsibly type stuff.

We've seen a lot of credit unions exploring in this space, whether it's CUSO development, blockchain development, actual products that go out to the members. We've seen a lot of use cases coming out of this. There's been actual guidance from NCUA around certain use cases. There's buy-sell whole guidance and different things like that. Credit unions are in a good spot because it's a different tone on the banking side of things now. If you're a credit union, now's the time to be exploring this.

WFC 109 | Cannabis Banking
Cannabis Banking: If you're a credit union, now is the time to explore digital assets.

I would agree with you that NCUA has taken a more, I don't know if liberal is the term but Hauptman, Harper and Hood all are for innovation. They want to make sure the risks are controlled. The other banking regulators have a pretty draconian joint letter that came out on it, which sends the exact opposite signal.

I would agree with you that credit unions are better positioned now to take advantage of this. There are risks tied to it and quite frankly, I don't even know what those risks are. There's a quote somebody says, “I don't understand it and I don't understand the people who understand it.” I'm in that category of still trying.

That's an oldie but a goodie, so I get that. I think the board is wanting credit unions to have the flexibility. You mentioned blockchain and there seems to be a bit of a pivot during the FTX and the crypto winter or whatever you wanted to call it. There was a lot of lot more discussion about blockchain and what that can bring to financial institutions and to the world of banking moving forward. That'll be interesting to watch. The landscape is changing rapidly on this whole topic. Any advice for how credit unions to not get destroyed by that and stay ahead of that curve?

I would say that's the million-dollar question, but I don't want to put a dollar note on it. That seems very FTX-like to say it's the million-dollar question. There are two types of credit unions. There are the ones who innovate and create use cases and businesses from those. There are the other credit unions that buy from them.

On the innovation side, that's typically true. You have the ones who are very progressive. They'll build, experiment and they'll end up creating stuff and selling it together. That's a business model that works fine. At SRM, we're involved in several projects within the industry that can change the course of business for credit unions.

Whether it's getting involved in a project or getting educated, credit union executives need to stay up to date on this stuff. We're constantly conducting board and executive training, which is now essential for any credit union. This was something that I found to be true, both as an examiner then working on the inside.

Executives wear many hats within a credit union. It’s not that you have one single job and that's all that you do. Everybody wears different hats and you don't even take one off. You stack another one on top of it and you do your job. Have a person dedicated to staying up to speed with both the technology.

If that was the purpose of a job, somebody could stay up on the technology but then to put it into the practical side of things and develop industry use cases, staying up to speed on both of those, then the projects that are in process as well, that's impossible. That's where SRM comes in. We help it fill that void and we allow credit union leaders to do what they do best, which is lead and implement some of the innovation in the space.

You talk about more training and staying up to speed on it. I joked about this being an area that I don't understand as much as I would like to, but the younger members are embracing it, even after the last challenges of 2022. It's part of their normal. Making it part of the credit union's normal so that you can keep those young members or get more young members seems like a good part of the mission.

You going back to the mission on cannabis banking, the mission of being able to serve people because this isn't going away. I don't believe, so thinking about making sure the boards understand what this means and how it might be able to help makes a lot of sense. Credit unions can partner with your organizations, but as far as specific strategies or other partnerships that credit unions can leverage to enhance their abilities, to make digital asset offerings, to help them keep those members and provide that competitive advantage. Any thoughts on that?

We're seeing several strategies that are either currently deployed or are in project stages or getting ready to be deployed. The one that typically comes to mind when someone thinks of digital assets is the buy-sell whole crypto option. When you go through your credit union, you can buy Bitcoin, transfer funds to your crypto account all within the same app and buy Bitcoin.

It's all closed loop. You're already doing your Know Your Customer (KYC) and all your BSA stuff on your member. They're going out purchasing the Bitcoin. It stays within the credit unions ecosystem. That's typically what people think of when we talk about digital asset solutions. We have vendors that we represent that offer us as a standalone option.

We're also seeing a big move towards offering that offering in combination with other offerings, whether it's self-directed or robo-advising investment solutions. One of the things that we're seeing, I think the industry is picking up on that a lot of these large wealth management firms typically will have maybe 1% to 3%. Your top 1% to 3% of your membership at your credit union under your assets under management.

That leaves 97% to 99% of your members without an option through your credit union. That's not the case everywhere, but what we're seeing is that, more often than not, that is the case. With some of these self-directed and robo-advising solutions like the Robinhoods, your members are sending their funds probably quite often. We're seeing that credit unions can do this themselves.

We're seeing the crypto option as a standalone. We're also seeing it combined with one of these where to what you're saying, meet your members where they are and offer them those solutions, whether it's the younger generations or whoever at your credit union that need these types of solutions. We're seeing that. We're also seeing outside of that. We're seeing development on the blockchain side of things and some good use cases come to the surface.

For a while, the space, at least my perception of it, was a solution looking for a problem. Now I think there are problems within a credit union chain or whatever logistics where you can say, “This is a great spot for some distributed ledger technology implementation.” The tokenization of real-world assets is going to be a big thing.

We're starting to see some actual real NFT use cases, not just an art thing selling for millions of dollars. Don't get me wrong, art has value. We’re seeing financial institutions having some real value for a credit union. The most important thing is that credit unions explore what their member needs are. Whether or not on the digital asset side of things or cannabis banking, understanding your membership and making sure that you're constantly meeting them where they're at with new solutions so that they can use you as their trusted institution.

Credit unions should explore what their members' needs are. Understanding your membership ensures that you're constantly meeting them where they're at with new solutions so that they can use you as their trusted institution.

You're talking about the member side of it. We talked a little bit about training the board. You don't necessarily have to train the members. There are members that are going to come to a credit union and say, “I want to do this.” There are members who are going to come to the credit union saying, “Do I want to do this?” As it relates to educating members about digital assets, any thoughts relative to what credit unions can do relative to educating members on this important topic?

We're going to see a shift very similar to that we saw on the cannabis banking side, where having a prohibition and policy isn't going to cut it anymore. You're going to have a membership that's involved in cannabis. You need procedures and policies outlining what you're going to do when that arises. Saying no isn't going to be acceptably more.

This is also something that's going to be tough to ignore. Even if a credit union says, “We're not going to offer solutions in this space,” which is totally a fine takeaway, I still think the board and executives need to be educated on this constantly. Membership education is going to be important as well because if your members aren't getting exposed to it from you, they are getting exposed to it somewhere and you're supposed to be their trusted source.

WFC 109 | Cannabis Banking
Cannabis Banking: Membership education is important. You should be your members' trusted source, not somebody else.

Even those credit unions who aren't going into the space from a product perspective, we're still helping credit unions from an education perspective for the membership. Whether it's an FAQ on their website about scams or what is this, then various articles and newsletters and things like that that you can send out to your membership. Just to keep them educated. Even if you're not going to launch a product, saying no isn't going to be a viable solution and you should be educating your members.

When you framed it up like that, there's a point in time credit unions didn't have shared drafts. There was a point in time most credit unions didn't do real estate loans. It was signature loans and car loans. The world changes and you either change with it or merge. Ultimately, it's important to educate. It's important to consider all these things. Josh, is there a question I should have asked you about either of these topics or something else that I didn't?

No, this was a lot of fun to be a part of and it's a privilege to be on here. I would love to trade examiner stories with you someday.

That sounds good. We'll do that off the record and without recordings. That's a good place to end. If one of my readers, would like to reach out to you, how would they best do that?

They can find me on LinkedIn. My name's Joshua Herman. Happy to answer any questions or collaborate with anybody out there. Go and hit the subscribe button to Mark's show. I have and I read them when they drop. They're extremely educational and informative. Thank you for having me on here, Mark.

You got it, Josh. My pleasure. Great to connect with you again. We'll chat down the road.

Readers, I want to thank you for your time.

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