Balancing Innovation and Regulation: Navigating New Frameworks in Fintech

Episode 4

As financial systems innovate to offer new products and address problems facing our communities, they may be subject to new processes like novel activities exams. In this episode, we delve into the complexities of regulatory frameworks with Kirsten Muetzel, Principal at KLM Advisory. Tune in to understand how fintechs and bank partners are adapting to innovative activities and what it means for safety, soundness, and consumer protection in the ever-evolving financial ecosystem.

Headshot of Kristen Muetzel

Featured Guest: Kirsten Muetzel

Kirsten Muetzel is an independent advisor to community banks and technology companies. Before establishing her own company, she served as a risk, finance and operations executive in Silicon Valley tech startups that partner with banks to bring financial products to market. Earlier in her career, she spent over a decade within the Federal Reserve System supervising the world’s largest, most systemically important financial institutions such as JPMorgan Chase and Citigroup. Kirsten has also spent time on Wall Street with Goldman Sachs, in Washington DC with the World Bank, and in emerging markets with the Peace Corps.

Episode Transcript

0:02 Hello and welcome to Social Currency, powered By Sunrise Banks, a podcast about the most innovative change makers in finance, technology and ESG and how they, our guests, are dismantling barriers and reshaping their industries and maybe even ours too.

0:16 I’m Tyler Seydel and I’m Eric Schurr.

0:19 Here we speak to those driving positive change through social entrepreneurship from cutting edge technology to creative grassroots efforts.

0:27 Each episode seeks to reveal the stories behind the revolution that is propelling us toward a world of financial inclusivity.

0:36 Today, we’re going to be talking about the current regulatory environment surrounding fintech and bank partnerships and perhaps even touch on a few salient topics in the space such as novel activity examinations and what that even means and more.

0:50 Let’s get into it by way of introduction.

0:51 Join us in welcoming Kirsten Muetzel.

0:55 She is currently a consultant for numerous financial institution and service organizations.

1:00 She has a background in risk management, banking as a service fintech, of course and was a former regulator.

1:06 She has spent time that being more than a decade at the Federal Reserve worked on Wall Street and was even a part of the US Peace Corps if you take the time to read her LinkedIn bio, it is a who’s, who’s list of accomplishments, Kirsten.

1:21 Thank you for joining us today.

1:22 We really appreciate it.

1:24 You know, Tyler just painted your career in, in broad brushstrokes.

1:27 We’d, we’d love to hear about your career journey.

1:30 How has your experience in the positions you’ve held position, you to speak about bank and Fintech partnerships.

1:37 Well, first of all, thanks so much guys for having me here today.

1:40 I love speaking on these topics and I really enjoy having the opportunity to talk about the things that I’m facing every single day in this market.

1:50 So, I, when I think about my career at the Federal Reserve, I mostly worked in really large institutions.

1:57 So the thing that appealed to me about going to the Fed was I was working in the financial crisis on Wall Street with Goldman Sachs, and I didn’t understand everything that was happening in the markets.

2:10 So when Goldman Sachs became a bank holding company, I walked across the street, walked into the Federal Reserve and basically signed up to work there.

2:21 So I walked in didn’t really understand a lot about the regulatory framework, but over the next few years was part of a group of people that were trying to implement Dodd Frank.

2:32 As you guys know, one of the small aspects of a, a little tag along with Dodd Frank was this interchange piece that got passed with the Durban Amendment.

2:43 and that ended up impacting a lot of the things that we’re seeing in fintech and a lot of the activity that’s happening to use Mike Sue’s comments, you know, outside of the regulatory perimeter.

2:54 So, while I was within the regulatory agency, one of the many things that I, I did was I participated in third party management horizontals.

3:06 So I looked at practices all across the United States for the largest institutions and how they adopted the Interagency Guidance that came out in 2013.

3:15 So in 2013, there was this, you know, they didn’t call it vendor risk management.

3:21 It was an an outsourcing S R letter.

3:25 And we looked at, well, how are the large institutions implementing that?

3:29 And so over the time, while I was at, at the fed, I got very, very familiar with various practices of overseeing diligence, you know, for third parties.

3:41 And then one of the other things I was exposed to because I worked in the San Francisco office.

3:48 I was on the Supervision Committee for the 12th District and a few of the institutions in the 12th district were doing these what we’re now calling novel activities.

3:58 I got to see front and center, not all how are we as a system going to now regulate or examine these super large complex sophisticated institutions like JP Morgan or Citigroup, but also I was front and center with, oh my gosh, look at all this new activity happening in Silicon Valley.

4:23 How are we going to examine this?

4:26 How are we going to ensure the safety and soundness of our system and of our banks given these types of activities that are happening in like green dot So I think that those experiences over, you know, a decade of just asking questions being with senior leaders and getting the the benefit of being able to question really great thought leaders in the space.

4:50 I think that’s kind of served me well for coming into the unknown and, and being in this space for five years now where there really isn’t, there’s not a map, you know, there’s a lot of a lot of questions, a lot of uncertainty and you know, ambiguity that we try and just kind of sift through.

5:10 I think that’s well stated and well captured and just to dovetail into a little bit of that ambiguity that ambiguity really gave rise to novel activities or what is now a phraseology of novel activities examinations?

5:22 How would you say that a novel activity examination differs from a safety and soundness exam?

5:27 And, and could you walk folks through exactly what a novel activities exam is?

5:32 Such a great question because I’m hearing that a lot by any bank that’s engaged in.

5:39 I would really call it innovation.

5:41 How is an examination if you are a bank that’s designated as,, engaging in novel activities.

5:47 How does that differ from just a regular safety and soundness exam?

5:51 Well, it doesn’t really what it means for the banks is that you are now going to have different people attending your examinations.

6:01 So, community banks that,, are, let’s call it, you know, you’re a $3 billion community bank.

6:10 It, somewhere in the middle of the country, you are used to having your examination team that you may have known for five years, 10 years, 20 years, you now are gonna have different people coming out.

6:23 So there are likely going to be specialists who are either very attuned to the type of activities that you’re in or people who are out there and learning from you about the activities that you’re in.

6:38 So, one of the things that has been made pretty clear by the public comments, not necessarily by the, the guidance that’s been issued and by guidance, I mean Interagency guidance, F F I E C guidance, you know, bulletins from the 0 cc or S R letters from the fed.

6:56 One of the things that has been made clear, not from that, but from speeches from publicly released remarks of people within the agencies is that the agencies are catching up to what these activities are.

7:13 They are very aware of things like web three, you know, crypto and gaming and the partnership arrangements and they are, are creating a cross functional team within the agency and specifically right now, I’m, I’m speaking of the Federal Reserve, to then be able to layer on top of the Community Bank examiners who come out and conduct the safety and soundness exams, your compliance exam, your BS A exam.

7:46 So really no difference in ratings, you’re still gonna be subject to the same type of report of examination, but the people that are coming out are different and then there’s more stuff happening.

7:58 In my opinion.

7:59 This is, you know, my vocabulary, not the agencies, you know, there’s, there’s the wizard of Oz kind of thing going on where you’ve got a curtain, you’ve got some people behind the curtain that are engaged in determining what’s communicated in your R O E.

8:14 So thank you for that.

8:15 We’ve heard from a couple of banks at least.

8:20 there’s there, we’ve, I’ve, I’ve had some conversation with a couple of banks that that have recently gone through these and it feels as though those expanded teams are learning how to work with each other and engage with the financial institutions.

8:36 So in, in some respect while they’re following a playbook, they’re also amending it a little bit to make sure that they’re being comprehensive and providing the right level of exam examination to the various financial institutions.

8:52 Are you hearing any key takeaways from regulators or banks who have participated in recent novel activities, exams that you can, that you can share.

9:02 Yeah, I’ve had some conversations with banks that are subject that have been designated as banks engaged in novel activities.

9:11 Some of those have gone through their examination and, you know, to be fair, I wanna say no one is revealing any confidential supervisory information to me.

9:21 I want to be fair to all of those banks that have had these discussions.

9:24, but what, what I’m gleaning from the commentary that I’m hearing is that there, there definitely are procedures, there are examination procedures that have been developed internally.

9:39 Have I seen those?

9:40 No, have the banks felt those?

9:43 Yes.

9:45 Have those been published?

9:47 Not to my awareness.

9:48 So, and that that differs from if you go through AAA triple L examination, you know, so like right now, some banks are still going through their early adoption of Cecil, not early adoption, but they’ve, they’ve implemented Cecil for their A triple L and they are going through their safety and soundness exam for credit and, and looking at the A triple L methodology, those procedures are available to people.

10:19 So if you’re a bank and you’re gonna walk into a meeting with an examiner, you’re pretty clear on what you’re examined against and what the benchmark is.

10:26 Now, when you look at the Novel Activity Supervision Program, it’s it’s more ambiguous and I think that’s because there’s a range of activities out there.

10:39 So, you know, you may say that, well, if you’re in a partnership arrangement, that by definition or by default, puts you into a novel activities program or supervision program, but there’s lots of different types of partnership arrangements, right?

10:52 So what we’re learning today, you know, this week we’ve had lots of stuff in, on LinkedIn posts and in blog posts and in articles coming out about the difference between going direct with a partner versus using some type of middleware or technology layer in between the partner and the bank.

11:14 So even the way that you conduct those no novel activities are different.

11:20 And I think because of that, there is no crystallized examination protocol for the Federal Reserve conducting these novel activities reviews.

11:32 So what am I hearing of banks that have come out of these?

11:38 I’m hearing it, it kind of goes back to this concept of there are some specialists who have been out there and involved in these banks that were early players, they have been exposed to leadership at the banks who may have had really good internal controls risk programs.

11:58 BSA programs, governance over the pro over the partnerships and those are those people are training some of the other specialists in the novel activities programs.

12:10 So you’re having kind of a it’s a bespoke outcome at each bank because it it depends on who the examiners are that are coming out and how experienced they are.

12:24 I think that’s well captured simply because when you say there’s a different maybe market manifestations because operationally, there’s a lot of way you could deliver a value proposition or fulfillment proposition to the market.

12:34 And so when an examiner is entering an institution, it’s not always gonna be a one for one because people are taking a different approach to accommodate some of those market dynamics.

12:42 So I do think that that provides a lot of interesting context or color contrast perhaps for the novel activity examiners as well as the bank going through that examination.

12:53 It also feels and perhaps you could expound on this a little bit.

12:56 It also feels as if that shifting expectation now isn’t just related to asset size, but rather could be related to volume as well as institutional complexity.

13:06 How do you determine kind of your asset size equivalency if you will?

13:10 And what are your thoughts on that?

13:13 This is something I’ve thought a lot about and I have actually been misinterpreted in the past.

13:19 So, I’m glad that we’re talking about it because it’d be great to get my view out there and and see if I can articulate it better today than I have in the past.

13:30 So, a phrase that I’ve been trying to use is that complexity has been divorced from asset size.

13:40 So in the past, there was a ra you know, supervisory programs and even what I was referring to earlier, the ratings you know, so you might be under a different ratings paradigm under, if you were a certain size of an institution, if you had a certain type of complexity due to the size.

13:59 So in the past, we had thresholds of asset size, that would be, you know, 10 billion at one point, it was 50 billion at one point it was 250 billion.

14:11 And, and so at each inflection point or at each hurdle as the bank grew larger in asset size, they would get more resources dedicated to them from the various agencies or from their P F R their primary federal regulator.

14:27 What we’re seeing now is that it doesn’t mean that just because you’re a $3 billion community bank that is headquartered in Kansas, that you will be subject to a community bank exam.

14:45 So in the past large complex organizations had a dedicated team assign, assigned to them.

14:53 And so somebody like me, when I entered the Federal Reserve, I was dedicated to a large financial institution, you know, $2 trillion institution.

15:02 We sat out at institution, we worked on that institution year-round.

15:08 There was one institution I worked on for six years.

15:11 I was dedicated.

15:12 It didn’t mean I didn’t do other things, but it was, I sat at that institution, I knew it inside and out and I knew all the different business lines and the executives, community banks typically have been subject to let’s call it a 12 month exam cycle for safety and soundness or they might be on a, you know, 18 month exam cycle.

15:32 And that was because they didn’t have a systemic risk to the financial system.

15:36 It was because the,, the P F R had, had designated that the risk to the system, the risk to the district, the,, the pace of development, the pace of innovation at that institution was slow enough that it wasn’t gonna go off the rails if the,, if there wasn’t a dedicated team that was out there, day in and day out.

16:03 Now, what’s interesting is that with the advent of, Dodd Frank and Durban Amendment and having all of these activities happen in not, I won’t, I don’t wanna say non regulated entities.

16:17 I hate it when people say that because they are regulated.

16:20 The FTC regulates these institutions that are non bank entities, they are regulated.

16:28 But because there are institutions that, you know, small community banks in, in the sense of $3 billion headquartered in Kansas that may have 10 different non-bank partners that they’re working with.

16:44 And some of those non-bank partners might have 3 million, 5 million, 10 million US consumers.

16:52 Whereas a normal community bank that’s 3 billion in asset size might have a couple 100,000 end users or, you know, account holders by virtue of that complexity that there are very large non-bank entities that are using that small bank, small asset size, banks charter to deliver financial products and services to the US market.

17:22 By virtue of that, it signals that they need.

17:26 They’re more complex.

17:28 The asset size doesn’t matter.

17:30 It’s the complexity of the business model that the bank has engaged in and often there’s transactions.

17:38 I mean, I’ve seen some banks very small banks less than $5 billion in asset size that rival large, you know, multinational institutions in terms of ach volumes.

17:55 So that is why asset size no longer signals complexity.

18:03 That is why institutions, even if they’re only $3 billion in asset size may require an enterprise risk management, m enterprise risk management framework that is more like a $15 billion bank or a $25 billion bank.

18:21 So I hope I answered it better this time than I have in in the past publicly.

18:27 I thought it was a brilliant answer and I guess what I’m taking away from that is it kind of comes down to potential for consumer harm and consumer impact?

18:36 Is that a nice way to sum that up?

18:38 Because that complexity, that ach volume that all results in a potential for consumer impact or it would affect an end user?

18:44 Is that kind of the in your mind?

18:46 Is that a a nice way to maybe summarize that if you’re looking at your portfolio is what could create a potential for consumer harm as you’re assessing your approach for controls.

18:55 OK.

18:56 So I love that’s one angle to look at it because what you just talked about is what I call a dap with a AA there’s consumer protection, there’s dap with a AA is focused on the consumers.

19:11 But the thing is a lot of these programs may just be business, right?

19:16 And so even the ones, even the ones that are just focused on businesses also may create complexity.

19:24 And so it’s not just about consumer harm, although I think that is absolutely one of the elements that should be in a risk assessment.

19:33 So in any of these partnership arrangements, I take that guidance that I talked about that had come out in 2013, there’s refreshed guidance that has come out in 2023.

19:44 There’s now in May of 2024 a handbook that’s come out to help even further promulgate these interpretations or, or this guidance into execution.

19:58 I I think about it as there are these third parties, if they’re operating on your charter, they are critical by definition, those are critical so that you have to look at it as what type of risk assessment should I be doing?

20:15 And I look at the full suite of risks.

20:17 So OCC has seven risks that they use and they framework or paradigm, I add a few more to that.

20:26 But then I, I create a risk assessment and I ask questions like this, does this partnership arrangement serve consumers?

20:33 What is the potential for consumer harm?

20:35 What could go wrong?

20:36 So that’s one element of it, but a whole another element of it might not have to do with consumers.

20:43 It might be that you blow up the bank because you’ve allowed your partner to send a wire on fed wire and you don’t have limits around it.

20:52 So that has nothing to do with consumer harm.

20:55 That’s a, you know, some people have heard me say liquidity trumps capital any day and that’s a liquidity risk to the bank right there.

21:04 So it could be, it could be nothing to do with consumer harm.

21:07 It could just be pardon?

21:11 So Kirsten, as I hear you talk about this, I I I I think about a retail bank.

21:16 You talked about the prototypical $3 billion bank that sits in the middle of the country and has, has no novel activities from a consumer experience perspective.

21:26 They control all aspects of the consumer experience from the location of their branch to the decor, to the products and services.

21:33 It’s assumed that there’s some sort of a a customer base that is over there over the institutions is correlated with the asset size.

21:41 So you have a, you have an exam that’s, that’s old school exam if you will or the traditional exam, the ba banks, the partnerships we’re talking about the banks are in novel activities are expanding that user experience to extend it to partners.

21:56 So the bank has to control and oversee that experience from soup to nuts just as they would if they control that experience totally from a product side.

22:07 It sounds as though you’re saying that these partnerships can and encourage banks to to go into new products and services and and the banks themselves have to be eyes wide open to all the implications of introducing what may seem an innocuous product extension.

22:25 But to be actually very aware of what all the implications are.

22:29 So I have a more systemic approach to to product development if you will.

22:36 Right.

22:37 Yeah.

22:38 So, so a few things that I’m thinking about when with that, I’m gonna tease this out of your question.

22:44 So one is when I talk about a $3 billion community bank in the middle of the country that wouldn’t have novel activities.

22:52 What’s fascinating to me is I typically think of those not as consumer banks, I think of those more as commercial banks.

23:00 So a lot of the middle of the country banks that I am aware of that are not involved in, let’s call it innovation, fintech, you know, partnership arrangements or web three kind of stuff.

23:12 Not that those are the same thing.

23:13 I mean, you know, not involved in these novel activities purifying by the Federal Reserve.

23:19 A lot of times the deposit relationships are driven by lending relationship.

23:25 So there’s, there’s a link there between a geographic footprint where you garner the deposits from the businesses that you’re also going back and lending to.

23:36 So, so first I would say like some of the products and features that I see from a traditional or legacy community bank help develop our US economic system.

23:49 So I am a huge, I wanna just put that out there too that I am a huge proponent of community banks of banks being all across the United States that understand the local context, the local needs and develop pro and services to meet those local needs.

24:12 Having said that I am also a strong proponent of innovation and creating new ways to bring those products and services to those local communities.

24:22 So, going back to your question, Eric, when I think about the products that are being brought to market these and, and going back to the conversation of asset size, divorcing from complexity of the institution.

24:38 When you think of a typical $1 billion community bank, $2 billion there’s typically not an enterprise risk management framework, there’s typically not a new products and services committee because if you’ve been focused on your local market and that is, you know, a pretty established industry, you might have, you know, eight different industries in your geographic footprint, you’re probably not iterating on bringing new products to market to the point where you need to have a new products and services governance committee at your management meetings.

25:15 But if you are serving three partners, five partners, eight partners who are very quick moving and are bringing new products to market, you know, quarterly and they have a product road map going out three years, bringing new things to market.

25:31 That’s when you have to, as the bank think asset size divorce from complexity, we’re gonna uplevel our governance structure and we are going to create whether you wanna call it a new products and services management committee or something else.

25:48 You’re gonna create a cross functional leadership team that is going to be looking at those products and services that you’re bringing to market through these channel partners and you’re gonna start risk assessing those as if you’re a much more sophisticated complex financial institution.

26:06 Sure.

26:07 No, that makes sense.

26:08 Yeah, shifting gears just a little bit.

26:10 You, you work with fa community based financials.

26:14 and, and I know you help them prepare for, for these, for all types of exams.

26:19 When what do you recommend for a bank that is, that has gotten notice that they’re entering into the first novel activities exam.

26:27 We talked a little bit about having a broader, more more subject matter expertise, a deeper set of knowledge of from the examiners walking in a larger team.

26:37 Are there, are there any any tips and tricks you can, you, you would offer up to banks who are looking to prepare for their first novel activities exam.

26:46 Yes.

26:47 So first, I think any bank that is engaging in innovation and bringing innovative novel products and services to market should not do it alone.

26:58 I think there’s a lot of lessons that have been learned out there and you know, get help, get other people out there.

27:06 Talk join consortiums.

27:08 I know Sunrise Banks is, is part of a consortium.

27:11 You guys share your lessons learned with other banks that are getting into the interesting products.

27:16 Those banks share lessons learned with you.

27:19 So the first thing that I would say is make sure that you have and I’m not saying this in a gratuitous way, but make sure you have advisers around you that you can kind of just talk to and, and be unabashedly vulnerable with them and say we know this, but we don’t know what we don’t know, you know, what else should we be thinking about?

27:44 So I’d say that as one as you go into your exam and you’re preparing for an exam now that you’ve been designated, make sure you talk to some other banks that have been designated as, as novel.

27:57 And that you, you see how they went through their exam.

28:01 The other things that I typically talk about is communications.

28:05 People know I talk a lot, I talk fast and I am an over communicator.

28:12 I would say when you’ve been designated as a novel bank.

28:17 It’s new for your whole institution.

28:20 Don’t think of this as something just for your risk team.

28:23 Don’t think of this as something just for your innovation team.

28:26 Think of this as your entire bank has now been designated.

28:29 This, there’s gonna be concentric circles, there’s gonna be layers to this, that kind of wave out to the entire institution.

28:39 So talk to your whole bank about this new designation, talk to the bank about what that might have an impact to them.

28:48 You know, how will this impact your mortgage department?

28:50 How will this impact your commercial lending department?

28:54 So that one is talk out, talk to your whole bank, another is pull your E L T together and create a regular strategy.

29:03 So again, it goes back to this asset size divorced from complexity.

29:07 If you were a large institution, they have regulatory liaisons, they have people whose whole job, sometimes it’s whole teams of people who think about regulatory strategy.

29:18 And in this case, I would say it’s kind of the same, you want to have some type of understanding from the bank side of how to engage with your agencies.

29:28 When to share information, how much to share when you’re asking for a non object versus you’re just informing them.

29:38 And then finally, I’d say, look at these consent orders, look at what’s the they’re so rich with information.

29:47 And one of the best things that you can get from there is what went wrong in those institutions.

29:53 Are we doing things to prevent what’s listed in this consent order?

29:58 Something that’s in there is board training.

30:00 So going back to talking about communication, you talk out to your whole bank, you pull a group of E L T executive leadership team members together, you talk about the novel activity designation.

30:15 You have a regulatory strategy and then you talk up, you train your board, you have a training around what does novel activities mean?

30:24 What is this new S R letter?

30:26 How does it apply to us?

30:27 How is the novel designation to change the way that community bank board members previously engaged with the examination team versus how they’re gonna engage through these new exams that may have more frequent touch points with the board members?

30:48 I appreciate that.

30:49 I think one thing that you mentioned that I feel folks may be internalize more than externalized is that examination, that letter of examination you get it.

30:59 It’s usually a tight knit group.

31:01 It’s very, I, I don’t wanna say secretive, but it’s handled with an element of privacy and certainly some urgency.

31:07 I like how you’re positioning, talk out, talk to the whole bank and assess that ripple effect.

31:12 You may be missing something, there could be something within a blind spot and you wanna have that awareness, you can accommodate that.

31:18 And what you mentioned is you kind of start in that with the people, when you have the right people, the processes and technologies seem to fall into place.

31:28 And I think we know a lot of what we’re seeing right now by way of enforcement actions is because the product, our product set has and I’m gonna perhaps use your words, iterated itself outside of that regulatory perimeter.

31:41 It moved into a gray space.

31:43 You having been a regulator.

31:44 Is it possible for regulators to move at the speed of the market and innovation?

31:49 Could you color in perhaps your perspective surrounding that?

31:53 So, I’ve thought a lot about this recently because when I, so when I joined the Federal Reserve, I never thought I would stay for over a decade.

32:05 And yet it was such an interesting time to be there that every time I thought about leaving, there was some other new great challenge that came up now over the over 10 years that I was there, one of the things that I went in to learn was about why these banks failed?

32:24 And is there such a thing as too big to fail?

32:27 And in the 10 years that was there?

32:29 I don’t believe in my humble opinion that all aspects of that question have been resolved.

32:36 So I’ll give you an example was capital fixed.

32:40 Yes, were resolution plans fixed?

32:44 Probably not.

32:45 You know, there was there was good movement on liquidity, there was good movement on capital.

32:51 This whole idea of if something’s really large and complex and $2 trillion and has tentacles all around the world.

32:58 Can we allow it to fail?

33:00 And if it is gonna fail, doing how to orderly resolve it, I don’t think that was ever fixed the whole time I was there.

33:07 So going back to your question, even in a sense of where the whole world was watching the US economic system and we knew that this is a problem we have to fix.

33:20 We had a lot of bright minds focused on it in the 10 years.

33:24 I was there.

33:27 It didn’t get, in my opinion, was not fixed, it didn’t get fixed.

33:32 So now go back to your question of can agencies move quickly enough to stay abreast of all of the changes that are happening in the market?

33:45 I don’t, I’m going to humbly state that I don’t think that that is possible and I’m gonna caveat that with.

33:53 I don’t know if it needs to be possible because if we have a regulatory framework that is principles based, that can be flexible enough to allow the boots on the ground, the examiners that are out there interacting with the institutions, whether it’s day to day every six months, every, you know, every year, I think there’s that flexibility afforded that they can apply principles to ensure safety, soundness, fairness in the financial system.

34:26 So I don’t think you want the same personality in an examination role as you want out there developing products and services and, and creating innovation.

34:39 I don’t think that will serve the country.

34:41 Well, what you want is a, a person that might move slower, might be reticent to change, might surface all of the problems that might happen and will apply principles to ensure that those products are brought to market in a safe sound and fair way.

35:02 I thought that was brilliant.

35:04, principles, philosophies almost approximate things like the golden rule or as long as ye harm, none do what ye will.

35:12 I think that that’s a brilliant take on it.

35:14 Certainly fantastic context.

35:18 So with that Kirsten, when you’re not being a thought leader and driving innovation in the financial technology space, what do you spend your free time doing?

35:27 What is your passion?

35:29 So I moved to Indiana two years ago.

35:32 And one of the reasons I moved here was I researched as, as any good an an analyst would do.

35:39 I researched where is the absolute best place to raise a child.

35:45 So, you know, when I looked at going to grad school, I researched all the different grad programs.

35:50 I ended up at Columbia for business School and International affairs and through enough third program just to boot because they were good at that stuff.

35:58 Right.

35:59 And then, you know, when I looked at where to work after grad school, I went to work at Goldman Sachs and Financial Institution M and A because I was like the best thing, right?

36:08 When I wanna work in Silicon Valley, I went to Silicon Valley and worked for tech start ups.

36:12 When I had a kid on my own as a solo mom.

36:16 I said, you know what, I gotta start thinking about where I can raise this kid in a place that he’s gonna have like an idyllic upbringing.

36:23 So, what do I do in my free time?

36:26 I live on a cul de sac and,, we all kind of sit out there, we bring our camping chairs and we just sit out there and the kids go nuts and it is like 19 fifties, you know, neighborhood.

36:43 That is so fun.

36:44 There’s a guy down the street who still feeds the fish.

36:47 You know, we have like a little pond here and every night Tony senior goes out there and feeds the fish.

36:53 Noah likes to go down there and feed the fish with him.

36:56 That’s basically, I mean, my life is like a very, you know, Indiana suburban, not at all.

37:04 Silicon Valley or New York.

37:05 High finance.

37:07, that’s my, that’s my life these days.

37:09 Oh, my goodness.

37:10 She took me right back to my days and, and of course she had to be, you have to be home on the street lights.

37:14 Come on.

37:14 Right.

37:15 That was the number one source of my grounding for many, many years.

37:19 I just couldn’t get home in time.

37:21 Kirsten.

37:22 We really appreciate you taking the time to talk to us today.

37:24 Thank you so much for sharing your, your insights, your thoughts with our listeners.

37:29 Thank you guys for having me.

37:30 This was really fun and that engaging dialogue was powered by Sunrise Banks member FDIC.

37:39 Thanks for listening to the social currency podcast by Sunrise Banks.

37:43 If you’ve enjoyed this episode and you’d like to help support the podcast, click like and subscribe anywhere you get your podcast content, we’ll see you soon.