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Hey everyone.

This is Mark Treichel with another
episode of With Flying Colors.

I'm excited today that we're
going to be talking about the

national supervision policy manual
and the NCUA examiner's guide.

I've got two Of my team members here
that if you're a longtime listener,

you're very familiar with them.

Todd Miller and Steve Farr,
guys, how you doing today?

Doing well.

Yeah.

Up, up by Glacier park today.

So it's gotta be a good day.

Living the dream, living the dream.

Hey let's for, we may have We got a
lot of long time listeners, but we

might have someone who stumbled across
us here the first time, either based

on the topic and a Google search
or who knows just a new listener.

So Todd, if you could give a little bit
of your background at NCUA for those

that are listening what you did at NCUA
before you, you switched teams with

Steve Steve and I to help credit unions.

Sure.

I spent about 34 years with N.

C.

U.

A.

I can break my career down into
about three different parts.

I spent a decade or so as an
examiner and a problem case officer.

Then I spent a decade or so as
a capital market specialist.

I had a lost year at West Corps,
basically after NCOA conserved it,

where I spent time there under you.

Then I spent about the last 11
years of my career as a Director of

Special Actions in the Western Region
supervising troubled credit unions,

problem case officers, capital market
specialists, got to sit on a lot of

internal committees at NCOA during that
time, was a member of their supervisory

review committee for handling appeals,
so an enjoyable 34 years all together.

Very good.

Yeah.

Interesting times.

And on that last year, I was
the acting director of the

corporate program at the time.

We had some retire, retirements at NCUA
and of course the corporate crisis.

And I was thinking the other
day, relative to that funny

story, at least it's funny to me.

I used to read books on the way out
to California when we were doing

the West core conservatorship.

And I was watching a TV show a couple of
years back and I thought, you know what?

I think these are the books I read.

And it was Bosch on Amazon prime.

So I was, I think I read every Bosch
book known to mankind on the flights to

West core and then on the red eyes back,
I would listen to Dave Matthews band

live with Tim Reynolds in Las Vegas.

Cause it was acoustic and
it was easy to listen to.

And after about six months of doing
the red eyes, my wife finally told

me, I don't know why you do that.

Cause when you come back you're angry.

So you might as well stay another day.

Yeah.

All right, Steve let's hear
let's hear your NCUA synopsis

of the time you spent at NCUA.

Yeah, I'm gonna Gary my comments specific
kind of the topic of the day and that

helpful and that my career is really
to two parts versus Todd's three.

And then I spent the 15 years as in the
examiner ranks out in the credit unions.

And as a problem case officer,
I was involved in a lot of

administrative actions and few
conservatorships and a lot of items

that are covered in today's subject.

And I was a big user, of course, of the
examiner guide, and then I spent the

last half of my career in an additional
15 plus years in the central office.

Where we would be working on, the
development of guidance and super,

the NCUA supervisory letters and
those types of things that were

produced to try and help examiners
and credit unions understand the

regulations and what NCUA is doing.

I think those parts of my
career will come in handy today.

Yeah, I'm looking forward to this chat.

And I remember, I started
on Columbus day, 1986.

They gave me, my first day was a
annual holiday and they told me that

the paperwork was too hard to start
me on a Tuesday and I asked my trainer

what I should do and he said, pull
out the examiner guide and read it.

Pull out the federal credit
union act and read it.

And I remember that beautiful
blue binder with those really

slick connectors on the side.

It was the coolest binder
I've ever seen in my life.

Bye.

I think I might have
finally gotten rid of that.

But yeah, it was Todd, I think
you might still have it or he's

looking to see if he has it.

Hey, this is a podcast.

You couldn't see Todd move, but
he looked like he was checking to

see if it was there on the shelf.

So anyway.

If it is, it's down on the
library in the basement.

I might have gotten rid of it,
but yes, I carried that blue

binder around for many years.

It was quote unquote our
NCOA Bible there for a while.

All the answers were between
those two blue blue binders.

Very good.

All right.

So, who wants to go first?

We've got the NSPM, which came later.

We've got the examiner guide, but
maybe a little bit of history of

how we got here to kick this off.

I can start on that and Steve can
fill in the blanks if he would like,

or we'll let Steve talk and I'll
fill in the blanks if he likes.

Yeah, we, the, one of the things
that I wanted to up is we'll talk

about the history of, the exam guides
been around, before we, we were

even around in some shape or form.

But the one that caught my attention was.

Let's talk about the newer document,
the National Supervision Policy Manual,

and why did that even, get developed?

I was at a conference when the
first discussion came through, and

that the NSUI board is going to
require that we put together this,

basically, a procedure manual.

And so I wonder if you guys have the
thoughts as to remembering why that

came about, and see if they match
what my recollection on that is.

So I have Todd, you go ahead.

I have some definite thoughts
on it, but let Todd go ahead.

I think the two are really tied together
in a lot of, respects, because as

the NSPM, the National Supervision
Policy Manual came into being,

NCUA de emphasizes the exam guide.

But back when Mark, Steve, and I
started, that exam guide was our primary

document that told us how to do our job.

It was in hard copy, the internet really,
none of that was online back then.

And they even mailed up
updates, we got little packets.

Take out this page, put in this page.

But over time, the regions all had
developed their own different ways of

actually doing their work, their project
plans for the year, how they administered

exams, how they put in place, enforcement
actions, how they wrote doors, findings

became like six little different agencies.

There were some similarities there.

You had an exam guide that tied
them together, but each regional

director and directors of supervision
had a huge influence on how each

of the regions were operated.

And as examiners would sometimes work
on teams that crossed regions that

created challenges because they would
do their work a little different way.

So you'd have some.

These internal issues when examiners
worked across regional lines.

And we did that sometimes when
there were staff shortages.

And the other thing is credit
unions, it's a small world.

They all talk to each other.

And so they knew about
all the differences too.

And complaints would find their
way back to NCUA board members.

And I believe it was Ms.

Matz was the chairman when the
first and SPM came out, I might be

wrong about that, but I think it was
mismatch when they first came out.

It's Matt said, Hey,
this is not acceptable.

The regions need to all
be on the same page.

And that led to that first national
supervision policy manual as a way to

get the regions on the same page and
doing their work and administrating

their programs in the same manner.

And as that NSPM came out, there
was a D emphasis on the exam guide.

Over time.

There's more and more has
been put into the NSPM.

It's up to 427 pages now, but it
gives you a pretty good idea how

NCUA supervises and administers
their exam and enforcement programs.

Steve, anything you want to care
to add to Todd's synopsis there?

All I can remember is because I was at
a conference with, it was basically all

of E and I was at it and this word came
down on that and we had that normal

reaction on resistance to change,
the same as credit unions deal with

when something comes along and that.

We were like, Oh, man, why
in the world do we need this?

This is going to be, nothing but trouble.

And, and plus, I think we were
thinking that it's going to be

a lot of work to put together.

I remember that initial
resistance to change it.

My recollection is same as Todd in that
there was probably just a particular

couple issues that made it all the way up
for board actions or something that were

done quite differently between regions
and the credit unions involved were being.

Pretty animate, probably correctly.

So about why are we being
treated differently depending

on what region we're in?

Yep.

You, both of your memories are similar
to mine and Todd, you were all right.

It was a board member, Debbie
Matz that, that pushed for this.

And I can remember.

So I transitioned from regional director.

To executive director on January 1,
2013, and I can specifically remember

being at a meeting where we also
had a regional director meeting.

There was also it was either
the kickoff meeting to the N.

S.

P.

M.

or the 2nd or 3rd meeting of the N.

S.

P.

M.

And I can remember.

My representative in region one at the
time, Albany was Rebecca Palowiczynski,

Sherry Freed at the time, who by
the way is about to retire from

NCUA was a representative, I think
from the Western region at the time.

And that introduced the topic of layering.

The concept was the age, the board
would come out with a regulation,

NCUA would come out with some
guidance, and then Todd, as you

said, the regions would layer.

Their own thoughts on top of that and
layering became banned and the only

way that something could be changed
would be via this new vehicle, the N.

S.

P.

M.

And that would be through this committee.

So if a regional director in the
old ways said, you know what?

A code three.

I don't want to do 90 day contacts.

I want to do 73 day contacts.

They could do something like that.

Now, if they wanted to float that
idea, it had to come to this committee.

And as there are no in the whole
planet, there are no statues for

committees because committees
tend to slow things down.

Sometimes they make things better,
but it made NCUA more consistent, but

it made them a little bit less nimble
and a little bit more bureaucratic.

And we might tip into some
of that bureaucracy, say that

bureaucracy a little bit later.

But yeah, that's the interesting
times, those transitions.

I have a story kind of related to that.

So I was the director of special actions.

The first one came out for staff
comment, and a lot of the policies and

procedures in that very first one that
came out for staff comment exempted

the division of special actions.

Then the actual first version came
out, all those exemptions were gone.

So I didn't put a lot of comment in it
because, Hey, I'm exempt from all of this.

I'm exempt from all of this.

And then when actually version one
comes out, I'm no longer exempt from it.

Even the direct vision of
special actions, which does

quite often have to move quickly.

Now they had to follow every single
thing in the guide to where in

the first draft version divisions
of special actions were exempt.

So I wasn't very happy with the
first version when I found I had

to follow all of it when I read the
comment version, which said I didn't.

Might have been, that might been,
they change it pretty frequently.

You mentioned 2013.

They're on version 22.

22 Now, they do tend to change it
every year, but as the board changes

policies and procedures, they do make
midyear changes to it on occasion.

'cause in 10 years we're up
to version 22, 22 versions.

Go ahead, Steve.

So the owner of the NSPM
that is, am I correct?

It is the Office of Examination
and Insurance or is it the

committee itself, Todd?

It's, it is the E& I director.

Correct.

Correct.

And 22 versions and every version
they seem to redact a little bit more

which is a podcast all for its own.

But Todd you had talked
about how, everything was in

hard copy when we started.

And then there was, then initially
there was an examiner guide that

went on the webpage that was very
consistent, it might've been outdated,

but it didn't change very often.

And then that started to
be updated more frequently.

But then for whatever reason, NCUA.

Either redacts or provides dead links
on a lot of things that used to be in

earlier versions available, which is
frustrating as we try to help clients.

It's frustrating for Credit unions,
when they're trying to figure out

what it is, NCWA's expectations are.

And it's frustrating for me when
I compare it to what FDIC does.

And that, again, that's a topic
for a whole other podcast.

It's a topic for a FOIA request
that I just never seemed to get

around to doing but any thoughts
on what you've seen there?

Any, I think maybe a little bit more
history is relevant and maybe we should

talk about it a little bit, because
at one time the exam guide was the

primary document examiners used to do
their job, then the NSPM came out now

the exam guide is turned into kind of a
mismatch of different things and it's.

A good reference general reference
document, but it's not very current.

It's a mixture of a web based access
and some of it is still the old

PDF chapters that we use before but
it hasn't been kept very current.

I know they started a project
to make it all web based.

He's probably eight or nine years
ago, and it's still not finished.

If you go to that exam guide,
there's a lot of areas.

Where if you click on it, it will
say content still under development.

There's not an easy way
to print it out a chapter.

What I would say about the exam guide
is each section has a workplace or a

reference section and work paper section.

Those are useful, all
the references there.

That's probably the only useful
piece of the exam guide that's left.

Is all that reference because then
it gives you citations to regulations

to some of the OCC documents
to some of the FDIC documents.

Page one of the exam guide
there is a disclaimer.

This is not a strict requirement
unless it's noted by law or regulation.

So they disclaim a lot of it.

You can tell there's different authors
because the new chapters are somewhat

inconsistent, but I do think we should
maybe just talk a little bit about.

Agency transparency, because the
exam guide used to be transparent

about what examiners do.

Now they've moved to the NSPM, where
it's transparent about processes and

supervision, but their exam processes
themselves are no longer transparent.

Under ARIES, you had questionnaires,
so examiners could, or credit

unions could do a self assessment
of how they're doing according to

what their examiners would look at.

As NCUA is moved to MERIT, They've done
away with most of the questionnaires

and they have what are called job aids.

None of those are public anymore.

That's how the examiners do their exams.

Part Aims have no access to
any of those unless maybe an

examiner gives them to them.

So they're all hidden away.

Within the NSPM quite often there are
links to some of these checklists.

There's references to some of this stuff.

Most of that is links to MCUA SharePoint.

So the public can't see it.

There are some areas that I
have notes of what's redacted.

So we might as well just
run through it really quick.

That would be great.

I would love to hear the
notes of what's redacted.

Oh, there's a lot of broken
links, but there are specific

sections that are redacted.

There's parts of the administrative
actions chapter that are

redacted and blacked out.

I suspect some of that is their kind
of decision tree is when they move

from one to the other, but I don't
know that because it's redacted.

There's pieces to changes in
officials that are redacted.

And I think a lot of that is just how NCUA
researches those officials backgrounds.

So it's some privacy type information.

Under district management, this is the one
redaction that I don't understand at all.

They redact almost half of what is
related to concentration risk reviews.

So concentration risk has caused
NCUA the greatest number of losses.

But within the redacted area,
they have triggers as to what they

consider excessive concentrations
and what they expect examiners to do.

Those triggers are redacted.

So NCA is very open about where their
triggers are for interest rate risk.

You have a pretty good idea where their
triggers are for liquidity risk, but the

area that causes them the most losses,
concentration risk, they're not going

to tell you where their thresholds are.

I have a form that says this is
what we look through when you have

concentrations above a certain limit.

And that form basically is these are
the steps they look to mitigate risk.

Something that examiners would, or
accreditings would like to know.

What are processes that we have
to manage our concentration risk?

Totally redacted.

NCUA has a job aid on concentration risk.

Tells examiners how to
review concentration risk.

It would be helpful for accrediting to
build out their risk management processes.

Totally redacted.

They do have a letter out
on concentration risk.

It's not as specific as that
job aid or what's in that

actual concentration risk form.

So I find it somewhat interesting
that their area of greatest risk is

where the agency is least transparent
about what their comfort levels are.

When you put it, when you put it that
way, that's a pretty powerful statement.

And this is redacted,
not dead link, right?

This is blacked out, right?

And, to redact something there, there has
to be a legal reason not to provide it.

And I was going to say.

The word guarantee you is on my mind here.

I want to say I'll guarantee you that all
those redactions have not been reviewed by

the Office of General Counsel, especially
by the volume of them coming up.

And if the redactions have been reviewed.

I absolutely guarantee you that with
the number of dead links that they've

got, that has not been reviewed.

And I remember a time where I was
in the audience and a board member

had to testify to Congress and they
had to testify on a certain topic.

But the topic that came
up was the redaction.

Of a state, a document that the state
that was very interested in related to the

overhead transfer calculations, and they
had redacted all sorts of things because

it would have made the discussion with
NASCS easier and became a challenging.

Discussion with Congress
for the chairman of N.

C.

U.

A.

They went around and they turned
around and were ordered to go

back and look at it and re redact.

Make sure that they have legal
reason to not redact some of that.

And it turned out that it was
staff didn't want to release it.

It wasn't stuff that should have been.

Redacted.

But in this instance, Todd, you nail
you really nailed the issue of redaction

with a very fine point here that the
agency loses money when they put too

many, when credit unions put too many
eggs in one basket and here they are.

Having these rules in a black box,
not explaining it to the industry.

And we've had conversations with
some credit unions where that has

turned out to be very frustrating.

And I just, I don't think.

I'm sure they could make a legal
argument if they want to, but it would

be good for credit unions to know
where those guardrails are, right?

I think it would, and like I said, it
would help them round out their own

governance and risk management processes
because those expectations are laid out in

those questionnaires and in that examiner
guidance or job aid is what they call it.

They choose to not share that with us.

Especially when we're seeing an increase
of NCUA saying you need to really justify

what your concentration risks are.

Again, it would be good
to have those guardrails.

Steve, any thoughts on this?

General topic.

Yeah, and doing kind of research
for this and some other items

we've been working on lately.

I, I looked up this interagency
statement on clarifying the

role of supervisory guidance.

It was came out in 2018 and it's by
the federal reserve, FDIC, NCOA office.

So control their currency, and one of the
bullet points on there is the agencies

intend to limit the use of numerical
thresholds or other bright lines in

describing expectations and supervisory
guidance that creates a problem.

Because we say, everybody would like
to know what the examiners are looking

at in terms of the bright lines,
for lack of a better term in what

is considered a concentration risk.

They didn't eliminate the bright lines.

They just hit them.

Yeah, and yeah, so I don't know
how that sits in terms of this and

it's we have numerical thresholds.

Is it because of this
that we don't disclose it?

But if the examiners have it, then
they have the same effect because

they're managing to those items.

It's certainly in the best
interest for credit unions to

be able to know where those are.

And then with, proper other Guidance and
issues and how those will be looked at.

But that information is so useful.

If the examiner is using
numerical thresholds, yeah, the

cranes seem to know about it.

Cause there's, they do pretty good
documentation on where we're at with some

of those interest rate risk measures.

And that those are out there and they've,
they work pretty hard on saying, the

Canadians can have their own, but
it has created a lot of friction.

And I'm sure Todd, you'll have
that's additional thoughts on this.

Like the interest rate response,
and this is the same way with

their internal concentration.

Targets their scope determinants
determines that whole exam scope

and it lays out expectations for
governance, with the interest rate

risk and their supervisory test they
say, okay, you hit these targets.

We're going to look at your
processes a lot more closely.

And they specifically say these
are not limits on the institution.

It's when our risk thresholds are
triggered and we're going to spend

more time and effort on looking at
how you manage interest rate risk.

This is the same thing with
the concentration risk.

I know cause I was on the committee
that helped develop them and the job

aides and the whole forum that they use.

And it becomes a scope determinant.

And it would be helpful for the
industry to know what those are.

It would be helpful for them to
even see the job age because here's

what we're going to look through
concentration risk governance.

And I would say this with
all the job aids and merit.

With areas you had the questionnaires,
credit unions could do a self assessment

of their risk management process and
all those different areas and how many

questionnaires were in that workbook.

But they covered pretty much
every area of operation.

They have these job aids and
merit now, and none of those

are transparent and available.

So credit unions They have to use
basically external types of information

to do their own self assessment.

The FDIC, the comptroller, the currency,
they're very transparent in their

exam processes of their documents.

MCUA used to be under
merit, not so much anymore.

But just a couple other things
that are redacted in the NSPM.

There's the development of
critical case in this case list.

It's an internal thing.

Really no benefit for credit needs
to know how the regions do that.

It doesn't impact them in any way.

There's some documentation requirements
for contact shorter than eight hours.

Industry probably doesn't
need to know that.

There's a whole section on the
fiscal program and enforcement

actions that are blacked out.

It's not blacked out for the federals,
but it's blacked out for FISCUs.

And I'm not sure exactly what that is.

It's probably things dealing with the
state regulators is probably why they have

it blacked out, although I don't know.

And then the entire quality
assurance program is blacked out.

And, would that help Cardenas or not?

Maybe not.

It would explain why some of them
are taking months and months and

months to get their exams up.

Months and months.

And we haven't had one
that took a year yet.

Got one that came close.

But that's an interesting list.

And again, I've got it on my baby
someday I'll send some letters or some

FOIA requests to NCUA to get a little
bit of this information to improve.

The transparency for our clients and
perhaps to discuss here on the podcast.

Okay.

And Todd, when you were talking
about, the examiner's guides outdated,

the NSPM is really taken its place.

And then of course, there's
letters to credit unions,

which are official guidance.

And then there's the the reference
section, which you said is

the key of the examiner guide.

I'm trying to remember.

I.

I don't recall seeing or having
discussions with any clients

where we saw NCUA refer back.

To the examiner guide
or refer back to the N.

S.

P.

M.

They'll refer back to
guidance, but not the N.

S.

P.

M.

Or examiner's guide.

You guys agree with that?

That was part of mismatch.

This thing to change doors and findings
to specific regulatory citations.

Either the act regulation
letters to credit unions.

So there, I don't remember that we ever
referenced the exam guide, most sections,

like I said, in that reference section,
they will list out all the regulations

that are applicable to that chapter.

They'll have links to, some of
the other regulatory agencies.

Sometimes they'll cite the
other regulatory agency,

but it's not an actual link.

You would have to go to the other
regulatory agency and search it.

Quite often in the web based exam
guide, there's links to the NSPM,

but it takes you to page one because
they change the NSPM frequently.

So they don't give you links to the
appropriate chapter in the NSPM.

It just makes you go search the NSPM.

I can understand why they do that.

Cause the exam guide
is very slow to change.

It goes through a committee process,
and it seems to be at the bottom of

E& I's list of things to update, and
like I said, it's fallen out of use as

they've buried all these job aids within
the merit exam program, so examiners

don't reference it very often, so I can
understand why it's low on NCUA's priority

list and why sometimes They don't have
links to actual places because those

links get outdated and frustrations.

But by giving titles of things
to look up, it's helpful.

And like I said, in the exam guide, those
reference sections at the end of each

chapter can be very helpful if credit
unions are searching on a specific topic.

I don't know that cardings use
it very much anymore because

like I said, it's very difficult.

You can't download a chapter to a pdf.

You can download the nspm and search it.

You can't do that with
the exam guide anymore.

So it's a difficult to
use reference source.

And I'll put a link to the in the show
notes to the link to the redacted version

of the NSPM that we're referring to now.

I mentioned exam reports
and, what you can cite to.

And we've got a couple great podcasts
coming up that weave into the NSPM

guide, the examiner's guide, et cetera.

But on camel code threes, what do
you do now that your camel code 3?

What do you do now that your camel code 4?

What do you do when NCUA asks
to meet with your board of

directors without the CEO present?

And we also have one that either has come
out just before or just after this one

that will be on document resolutions and
project management as it relates to that.

So a lot of good content coming to
your regular listeners as you gear

up, as you get out of summer and
you gear up for your next exam.

So what?

Anything else?

Go ahead.

Go ahead, Todd.

One little side light on the N.

S.

P.

M.

And the exam guide.

I said they don't keep the
exam guide links currents.

They usually due to the N.

S.

P.

M.

But the N.

S.

P.

M.

References the exam guide into several
specific areas with enforcement actions.

It references specifically chapters 29 and
30 of the exam guide in multiple places.

But those chapters of the exam guide
are not available to the public.

I don't know that it was
intentional, but they're not there.

I firmly believe that There's
some intent and there's some

just, oops that's going on.

Just be again, because it's hard to
keep all the links, alive and running,

which is a good segue to the fact that
Steve, in, in your former life at NCUA,

you wrote NCUA's enforcement manual,
there is a redacted version out there

that I have a redacted version of that.

If anybody's interested in getting
it, but any thoughts on the

enforcement chapters being gone
or enforcement in general, Steve.

The enforcement manual was
actually issued as an incident.

A instruction has had to
do with the politics of the

ensue board at that moment.

So that's a whole nother story.

1 thing that we've found in the Nspn
with our clients, we worked with is the.

Process that deals with the
processing of administrative actions.

So it's been really helpful for the
Koreans to know that they have to

respond within 30 days or whatever.

And we're able to point them as to
those time frames that they become

subject to with some notices and
in response to those particularly.

Administrative actions, I think
was, has been a part of it that

we've shared with our clients
more regular than any other parts.

Yeah, that's a great point that
and and of course, the 30 days to

appeal, we have a separate podcast
on appeals, a couple of separate

podcasts on appeals that are out there.

Generally speaking, appeals
you have to, they make sense.

If depending on how you define
victory of an appeal, because it's

hard to get something overturned,
but sometimes you can get.

Your point made or a few things
changed, but not when the like a camel

code overgrade override, for example.

But now I'm going down a rabbit hole.

If you're interested in appeals,
check that out on another podcast.

Very good guys.

Any last thoughts here as we wrap up
any questions I should have asked you as

it relates to the examiner guide or N.

S.

P.

M.

or any thoughts you want
to make sure we hit.

I would just say for credit unions,
if they want to dig into the NSPM, the

chapters to look at for the most part
that impact them are those chapters on

district management, it explains how your
examiners behave and schedule things.

Then there's separate chapters for
federal programs and FSCU programs.

Those chapters will lay out how the
whole exam process and timeline works in.

If you just look at nothing else just
look at those and it'll give you a

general idea of how your examiners
are operating and how your exams get

scheduled and things of that nature.

If you want to look at a regulatory
waiver, for any reason, whether

it's for derivatives, for non member
deposits, for bank purchases, mergers,

there is a chapter in the NSPM on
regulatory waivers that covers all

of that, which credit unions might
find helpful if they're seeking one

of those specific regulatory waivers.

I will say that unless it's
changed, the bank purchase had

some deadlinks and that's what
actually got me onto the topic.

In my mind of a potential FOIA because
they issued a proposed rule saying they

were going to clarify What it takes to
get a bank purchase and that it would be

in the nspm Then they never issued the
final rule, but the nspm is redacted.

So that was I actually went to nsu
and talked to him a little bit about

that which led me to the point where
I had to do a FOIA and just haven't

got around to it Very good guys.

This is this has been a lot
of fun bringing back some old.

You Old memories.

I never expected to bring up
Bosch and Dave Matthews in the

same podcast, I did here today.

So that's kind of cool.

Thanks guys.

Have a great day.

And this is Mark Treichel.

I want to thank you, the
listener for listening.

I hope you'll listen to it again soon.

Mark Treichel signing
off with flying colors.

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