Credit Union Exam Solutions Presents With Flying Colors

Treichel: Hey everyone.

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

I'm here today with Todd Miller,
formerly of NCUA and of my team of

experts that help credit unions.

Todd, how are you doing today?

Todd Miller: I'm doing well.

It's a beautiful fall day here in Montana.

Things are going well.

Treichel: That's great.

It's humid, but I am near
the ocean here in Florida.

I'm having a good day as well.

Today we're going to talk
about a topic that we've hit.

And we've hit with a lot of our
conversations with credit unions.

We've hit at different times
in different podcasts, but it

relates to the board package.

And what should be in a board
monthly package so that the

board sees what they need to see?

And oh, by the way, how will that
package rise to the level of.

Making NCUA comfortable
with what's in that package.

So you can call it the
optimal board package.

You can call it a good board package,
the perfect board package, but that's

what we're going to chat about.

But before we do that, just in case
someone's listening to this for the

first time, if you could give a little
bit of your background at NCUA before

you started working as a consultant
to help credit unions, what did

you, what's your history at NCUA?

Todd Miller: Certainly.

So Mark, I spent 34 years.

With NCOA, you can break it
up into about three parts.

The first third or so of my career, I was
an examiner and a problem case officers.

That middle third, I was a regional
capital market specialist, worked

with good credit unions and bad credit
unions and everything in between.

Actually, during that time, helped
a lot of Development of policies

of how NCUA looks at interest rate
risk and looks at liquidity risk,

did a lot of examiner training.

Then the last third of my career, I was
the director of special actions in the

western regions, supervising problem
case officers Capital market specialists,

some regional lending specialists between
that capital market specialist here

and the director of special actions.

You created a loss year for me
where I spent a year at West core.

And then I started my director
of special actions role right

in the middle of a recession.

So made for some pretty interesting times.

And I enjoyed my career with NCUA.

It was a blast.

I enjoyed all of it.

The board package that we're
going to talk about today, I

conserved a lot of credit unions.

I returned a couple to the members.

So how board reports fit into
this is near and dear to my heart.

Treichel: Yeah.

And from listeners conservatorship is when
NCUA removes the board and serves as the

board and the insurer and the regulator.

And when that happens, the
staff at NCUA get are basically

running the credit union.

They'll have a CEO, but they get
very hands on in that regard.

And so that's what Todd's
referring to there.

And by the way, there is a podcast
on Conservatorships that I can

put a link into the show notes.

So if you're curious about
Conservatorships, there's a

whole podcast on that topic.

All right, let's a board policy,
a board package let's start

walking through what should be
in a board, a good board package.

Todd Miller: I'm going to just give a
little background and just throw out.

We've done other podcasts
here on corporate governance.

We've done them on risk appetite
statements and in those we discuss the

nature of, this becomes a culture and
part of the credit use culture and the

board package is reflective of that.

It's a foundation for establishing that
board culture, but it reflects that.

Or culture in corporate governance
as well, at the end of the day,

the board of directors, they're
responsible for that general direction

and control of the credit union.

They set that strategic plan, they set
those risk appetites, they're responsible

for ensuring the credit union complies
with laws and regulations in the

board package at the end of the day.

And at its very simplest nature.

It's there to provide and help
the Board of Directors make

good decisions with review.

Respect to their responsibilities.

We spent a lot of time in
troubled credit unions.

I think there's some things that
come out of troubled credeans.

And 1 of the things is they always have
boards that are actually want to act

in the best interest of the members.

And then how do they get in trouble?

Usually it's because the
board Is misinformed about

the credit is risk position.

They don't know what's going on.

In rare cases, they, their management
staff misrepresented the whole

risk of the credit into him.

But a lot of times they're just kept
in the dark and that was something that

came up over and over in my career.

When you get into a trouble credit,
as boards were in the dark as to where

their credit is were in terms of.

Actual risk.

So I think that's somewhat
of an interesting thing that

I was preparing for this.

I thought, oh, I could Google
what's in a good board report.

I'm sure there's hundreds of web pages.

I will tell you, here's 8 principles
or here's 10 principles or whatever.

I chose not to do that.

I just made an own outline
off of my own history here.

Our listeners, they can go back and
Google that and we'll see how much, we

hit and how much we miss, but I'm going
to try and keep it a little bit more

simpler and a little bit more direct.

Treichel: You got it.

So you talked about misinformed on risk
and as you're talking through that,

I'm picturing different conversations.

Where you've been involved with some
client conversations where there's

like a, and I'm also thinking about the
concept of foreman substance, right?

That you can have amazing data, but if it
isn't handled in a proper way so that the

board can easily find it and they have
to spend, the package grows and grows,

and it's just a data dump that's not
organized well, that can create, right?

A situation where they don't understand
the risk, even though maybe you can

hunt and peck and find all that.

But if it's put together, it
has that form, whether it's an

executive summary on the top.

I know you've had some conversations
relative to, some large credit unions

where you've seen some really good
board packages and some covers to that.

So when I bring that up, what
should be on the front end of a

good board package in your mind?

Todd Miller: You bring up a
lot of things there, Mark.

And I

Treichel: did.

Yeah.

So just run, I

Todd Miller: have answers to all
of those on this little piece

of paper that's in front of me.

All right.

Let her rip, so a good board package,
so first off NCUA, they don't have

a lot of guidance, but they do say
something about board reports and their

exam guide, and this is the only quote
I'm going to read from anything today.

The rest of it is all just going to
be me talking, you talking, but NCUA.

They put it in writing, they say reports
to directors should support the complete

understandable and accurate information
appropriate to the size and complexity

of the credit union size and complexity.

The credit union is an
interesting statement.

The regulators use it all the time.

And because of that caveat.

There is no perfect board package,
credit unions are going to have a

governance culture, a risk management
culture and their board packages are

going to reflect that, all I will say
between board packages and it doesn't

matter to the size of your credit
and you're going to have quantitative

and qualitative information in there.

Board packages, they do have
a tendency to grow over time.

You're always fighting this balance
of what does The board want and

what does the board need to have?

And those are difficult
questions to answer.

Every board brings with it.

It's unique skill sets
and unique background.

So how you present information
to them is going to vary across

organizations how you order your
board package and the information.

It varies across different organizations.

You see some organizations, they put
all this compliance stuff in front

and other places, they put it in back.

Some people start with
a financial statement.

Other people end with
a financial statement.

At the end of the day, there's
no one right answer to how you

organize your board package.

Talk about some of the qualitative
and quantitative stuff.

A short, Version of it in the way
I always assessed it Is and this is

todd miller's personal view of what a
board package looks like To me board

reports should reflect management's
responsibility to demonstrate compliance

with business plan board policy Risk
appetite standards of the credit union

Treichel: say that one more

Todd Miller: time So they should reflect
management's responsibility to demonstrate

to their board compliance with business
Or policy and risk appetite standards.

And those are all things
the boards put in place.

They create that business
plan business strategy.

They set all the policies.

The board is responsible for
setting that risk appetite to me.

Board report should demonstrate
management's compliance with those items.

Treichel: As you say that, I think
of a couple of conversations we've

had with credit unions over time
where a credit union strategic plan

said A, B, and C, and then what they
did was B, Q, and R, and there was

no pivot in those board documents.

And so NCUA Criticized and those
credit unions pretty harshly

because they didn't really do
management really didn't do that.

And the board didn't ask to
see that in those situations.

Todd Miller: It's fine if the credit
union does that, but somewhere there

in your qualitative board reporting
and discussions, there has to be okay.

Today's business.

This plan ABC is not working.

Here's why.

And here's an opportunity to pivot and
accomplish board goals by doing X, Y, Z.

And here's the opportunity
and risks entailed with that.

Like I said, there's no right way to do
it, but that's one of the things that

comes out, in your qualitative reports,
and we'll talk about qualitative reports.

They need to be clear,
concise, provide context, but.

At the big level, your CEO, CFO,
lending people, whatever the case

may be, they should be providing
explanations for deviations from plans.

Why are we not able to do what
we thought we were going to do?

But, we're in an election year.

Things are going to change.

We just went through a cycle where
we went through COVID and We have

these massive increases in interest
rates, which no one can predict.

You respond to those by laying
out, in your board reports and

your CEO, let's go discuss.

The world has changed.

Our risks and opportunities are different.

We have to pivot.

Here's how we're going to do it and make
that a discussion at the board level.

Also, you lay that kind of stuff
out in your qualitative reports.

I'm getting ahead of myself because you
ask questions that get us to the end.

Treichel: Get back.

Get back to your agenda.

We've got qualitative.

We've got quantitative.

This is the next thing that we do
is walk through 1 of those or what?

Todd Miller: Let's go through the
quantitative reports first, because

these are numbers, and I will just say
this, you break quantitative reports

down into, I break them down into
a number of categories, and I think

you'll find in the literature, this is
probably the same, even though I didn't

look it up, you have key performance
indicators, how are we doing financially.

And how are we doing against our
budgets and our strategic plans?

You have key risk indicators, NCOA
throws out a whole historical, key

ratios and historical ratios on
their financial performance report.

A lot of those are key risk
indicators, key performance indicators.

You have financial reports
and then you have budget.

In a strategic plan updates, I think
there's a couple things that, in a good

performing credit, and you're going
to see is there's going to be a lot of

consistency in these quantitative reports.

They're going to tell you where
you've been where you're at.

And give you some indication of
where you think you're going.

And I think that's important with
boards, especially because they're

not there in the criterion every day.

They need some measures to
show where they've been, where

they're at, where you're going.

I think those pieces are in there.

Now, the quantitative reports.

This is very interesting.

I like dashboard type level reports.

And the challenge for any criterion
is how do you summarize these things

without providing too much detail?

You give a board too much detail
and it causes a couple problems.

One thing, you lose your directors because
they can't interpret the information.

And the other thing, if you give them
too much detail, it really invites

boards to start micromanaging little
numbers and that's not their role.

So board level reports, they
need to be summary type of data.

I like the dashboard things.

I think it's important in accrediting
that your board reporting these numbers

are reported in a consistent format,
regardless of where they come from.

If you're still.

CFO is giving you refinance
reports, and he highlights

variances with red, yellow, green.

You should expect to see the
same thing from the lending.

You shouldn't see lending reports
that use blue, magenta, and purple.

There needs to be some consistency to
that throughout the organization, because

it's how you build credibility, trust,
and it makes it easier for your board

members to understand data given to them.

It used to drive me nuts when I would
go into a credit union and say, Okay

here's the financial trends here.

And, they go the oldest information on
the left, newest information on the right.

But then you pick up another report on
the next page, and it goes the other way.

It's just like that just
adds confusion to things.

Let's Keep this whole process
consistent, and there should actually

be some conscious thought put into
that within an organization of

how we're going to organize data.

Now, along with a qualitative report
like that, like I said, I like dashboards

sometimes credit unions do need detailed
information, but, at the end of the

day, There should be qualitative
reports that go with these dashboards.

So I wouldn't be should be telling
the board, hey, everything's fine.

Let's go on the way.

We expect.

Wait, wait, we have variances here.

This is not going the way we expect.

Here's why.

Here's what we're going to do about it.

Sometimes you just need
to explain to the board.

Here's the 2 or 3 key pieces of
information on this dashboard.

This is what you need to be
looking at have any questions.

I also think, 1 of the things
I said, I talked about.

Where we've been, where are
we, where do we want to be?

I do think it's also important
that credit unions have dashboards

that compare themselves to their
peers, too, where are our peers at?

Where are our competitors at?

Almost everyone does that in terms of
setting loan and share rates, but you

should benchmark your key performance
and risk indicators against your peers.

Occasionally, too it helps that the
board set that strategic direction.

But I think the con System
formatting is available.

If a board member wants to dig into raw
data, fine, make it available to them.

But I don't think it has to be, in the
reports every month, and I do think it's

important to that boards and especially
on these qualitative reports from

executives, they tell board members.

What's important?

What's not in here?

I'll give a couple of examples.

That happened in real life about this.

Most board reports, they
don't have cost accounting.

Cost information, that's a daily thing.

It doesn't need to be in there.

But, as in a travel carding
with them, they had 52 branches,

39 of them were losing money.

I think maybe you should tell your
board that's maybe something they

need to know, and then contrast that
with a carding at the same time.

That's 2 states away within
their strategic plan.

They laid out, okay, we have multiple
branches, we have small, medium,

large ones, we expect them to make
profitability within, within a year.

18 months when the open on 20 on the small
and medium ones, 24 months on the big one.

I have a policy.

If we have a branch that's losing
money over a 12 month period, we're

going to have a plan to fix it within.

12 months or we're going to close that
branch or it doesn't have to deal with it.

Expectations are laid out.

Here's what we're going to do.

It's a different

Treichel: those 2 examples you gave him,
putting my old head on and you could see

in your 1st example, all those branches
losing money and not having the data.

You could see a pretty rough exam
wrapped around that and maybe we're

examiners will point that out.

And the other 1, you can see where that.

It not only helps the board understand
it, it helps the relationship with NCOA

and helps NCOA get in there and get
out quick because they can, they, you

the management team and the board has
put together a package that is succinct

yet provides the right information.

And then the other thing, when I'm
thinking about dashboard, it reminded me

of a Confucius quote, which is, it's a
simple task to make something complex.

And it's a complex task to
make something simple, right?

How do you.

The work behind building that
dashboard can be very complex can

be very challenging but it provides
a simple summary that someone can

take and make decisions on and.

Meet their regulatory needs, meet
their needs of understanding the

credit union because, because
it was artfully put together to.

To tell the appropriate narrative of
what the board needs to understand.

Todd Miller: Yeah.

And, you mentioned complex made
simple and, probably the biggest area

with respect to that is credit risk
reports, you have a very complex thing.

And this is the biggest risk
in any credit out there.

If they fail, it can.

Was to be credit risk or liquidity
risk and if they have liquidity

risk that causes a failure It's
almost always because of poor

asset quality at the bottom side.

So it all comes down to
this credit risk is it?

most significant risk in any credit union.

And, credit unions are involved in all
kinds of different types of lending.

You have your consumer lending.

You might even indirect lending.

You might have participation loans.

You have various types of
residential real estate lending.

You have all these different types of
commercial lending, and they all require

different types of reporting structures.

And, how do you lay down What's important
for a board, and how do you get them in a

succinct one or two pages in each of those
areas to understand where credit risk is?

It's a very challenging issue.

A lot of credit unions, they
use a company called Encino to

monitor their consumer loans.

You can break that thing down to where
there's hundreds of pages, but there's

also ways to break it down very easy
in two or three pages to here's where

our credit risk scores have migrated.

And here's where our LTVs have migrated.

Here's what this looks like when we
combine LTVs with credit risk scores

and how that changes over time.

It can be done in two or three pages.

Just, but there's a lot of hours
of work behind it to get it there.

So the board doesn't get bogged down,
but they still have a clear picture of

what's going on with that portfolio.

You'll see this with clients, all people
that have business loan portfolios, you're

making large loans, quite often, two or
three large loans, you lose them in a

year and it's a years of profitability.

Out the door right there.

You will always see the examiners
and the regulations harping on what

type of business loan reporters
have to end up in the board package.

And sometimes you think it's on onerous
board members sometimes might think it's

onerous, but they're important pieces that
the board has to look at and understand.

You get another piece of this nowadays
where credit unions, almost all of them

have fairly complex committee structures.

That manage different
areas of the operation.

You have IT steering committees, you have
ALCO committees, you might have a risk

committee, you might have a business loan
committee, you might have a regular loan

committee how much of that information
makes its way to the board and you're

going to do that in summary or detailed
information, it becomes a challenge.

You do have to figure out a way
to get all these committee type

reports information to the board and.

You don't have to spend
a lot of time on them.

If things are going according to plan,
the board should really try and keep

their eyes focused on strategic direction.

That's opportunities and threats.

If things are going well, they
don't need to spend time on that.

They need to spend time
on where do we need to go?

And how do we get there?

And so it becomes a big challenge.

But at the end of the day, all
those committee stuff used.

It needs to be available to them.

Today, that's easier than ever.

There's lots of software
platforms out there.

A lot of people create their own
software platforms where board

members can sign in and look at it.

I remember the old days
before there was that way.

I had 1 of the largest
credit unions in the U.

S.

in my district.

I think they were the only credit and
used every line on the call report.

Other board packets came in
a binder to me each month.

One of these cardboard bifolds,
I don't know, it was probably

250 pages, but, they had.

Five or six keys, those and
all kinds of joint ventures.

And it was very interesting.

And, I sat down with this chief operating
officer that creating one of the exams.

It's there's all this stuff.

Get in here.

I said 90 percent of his
examiners told us to put it there.

We don't look at it.

But you find things that, okay, this
was a regulation requirement, 10 years

ago, and it got thrown in the board
packet and it never got taken out.

The other thing that, credit unions
need to do and board members and CEOs

need to do this probably once a year or
every other year, they really need to

go back and assess their own packages.

What are we looking at?

Do we really need to see this?

Is this important?

Does it have to be in there?

A lot of those things you do put in
there, or if you've got subsidiaries

and stuff, you might only talk about it
once a year and a lot of it goes through

a consent agenda I have found, in that
one party, and I was just talking about

I said, do board members ever even.

Look at this stuff or
understand what's going on.

And I was there for an exam one time, and
they just had a regular board meeting.

And, the CEO invited me to come
to a regular board meeting.

Okay.

That board meeting was very interesting.

Those board members did
read all that stuff.

They did have questions on it.

They did understand all of it.

I was very impressed.

So qualitative reports.

Like I said, you need to have,
executives need to summarize and

address in a qualitative written form.

Format, all these qualitative reports,
and then I need to layer on top of that.

Hey, what's going on in the world?

That's increasing our risk.

What's opportunities that?

Hey, we didn't think about them when
we did our strategic plan 2 years ago.

But here's something that we can
do now that benefits our members.

It will be profitable.

Do we.

I want to go down this path.

Here's risk and rewards
of this type of thing.

So it's really important that especially
those qualitative reports, they

address those risk reward things.

It's an important that they
address deviations from plans.

We have a risk appetite.

We have a business plan here.

We have a strategic plan.

Things aren't going according to plan.

Those are the things the CEO,
the CFO, your lending executives,

they need to address those issues
in their qualitative reports.

Where are we having
deviations from expectations?

And the sooner you bring those things
up, the easier it is for everyone to

address them and pivot if necessary.

Treichel: Can you think of the example
of that use of qualitative where you

had all these branches that didn't.

That weren't making money.

And then this other one where
they were tracking it really well.

Can you think of any anecdotal
qualitative things that you've seen

that were done either particularly
well or particularly poorly?

Nothing might come to mind but any
examples like that, that, that come

to mind when I throw that out there,

Todd Miller: the poorly done ones,
there's lots of examples of those,

especially with lending areas.

Is where, you throw raw data at the credit
union or, especially business portfolios.

We're, we don't really disclose our
risk migration or we'll even lay it out.

Here's our business portfolio.

Here's the totals risk ratings, call
it 1 through 8 bad, good to bad.

We have the.

Some are seven or eight here
that are potential losses.

But what you don't say within
that is wait, two of these are the

largest loans in the credit union.

They're not just an average loan balance.

These are ones that
can hurt us materially.

And you don't share that information
with the board, material risks like that,

you need to just throw it out for them.

And, the.

The well run credit and those
qualitative reports, they're going

to be looking forward towards
opportunities all the time.

You have this new emerging AI issue.

What does that mean for us?

And we've seen credit games that, and
this is both good or bad, they play

with within the Bitcoin and the crypto
currencies and how do we provide services

and say, keeping for our members and
we've seen examples of credit games

that have structured this extremely
well and others that have dived into

it without really thinking through all
the implications and they, Been heavily

criticized by their examiners for doing
so four or five years ago, before I

retired, you'd see a lot of that with
the whole marijuana banking issue, right?

You got Freddie Ian's that dove into it.

They did a lot of homework.

They did an extremely good job with it.

Other credit unions dove into
it without doing their homework.

And, then you get an exam report and the
board doesn't even realize, Oh, wait we

had 300 marijuana bank and clients here.

And we've got a fine from FinCEN
because we didn't, handle our SAR.

Appropriately, and I've seen examples
of that in real life to the boards.

Just get surprised.

Hey, we get a fine from Vincent
for not doing something.

And, we didn't even know
we were involved in that 1.

And a business,

Treichel: That's that's
what they call a red flag.

Definitely.

Todd Miller: Yeah more of the examples of
the way we're, we've not really summarized

for our directors, those significant
risks, we bury them away in detail.

And that's where the qualitative
reports need to come out is,

let's not bury things in details.

Another example of that 1 time.

And a member complained about their CD
not renewing at the right weight, and

they appealed it to a branch manager.

Branch manager said, no, they appealed
it to the board management, told the

board, hey, we did the right thing
board upheld their branch managers

decision, how to renew the certificates.

That member pulled out 4 million
and I had to go borrow that

entire amount from the corporate.

No one told the board that this
member is appealing a thing here

over 200, but no one bothered to tell
the board that member had 4 million

in that 200 million credit union.

Yeah, it's like maybe the board would
have made a little different decision

if they had the whole story here
behind this appeal that came to them.

Treichel: Yeah, that's a great example.

I had a similar example.

I read it in a USA Today back
when USA Today was printed.

It's a guy came in and was disheveled
into the bank and wanted to get

the parking validated and they
wouldn't do it and brought it all

the way up to the vice president.

But no one had the idea to look at.

And he even said, I'm
going to close my account.

They go, sure.

Okay let me go do that.

And that's when the
light, the lights went on.

They saw, that that it was the biggest
depositor in that particular bank.

So great point.

Great point.

Beyond qualitative what else what else do
you have on that on your sheet of topics?

Todd's topics on board packages.

Todd Miller: I said, there's
no, no correct answer to this.

I do think.

It's important that, you keep
your reporting consistent.

Let's figure out what works.

Let's keep this consistent.

Let's not be changing it all the time.

I think board calendars and
board agendas are important.

Different boards will look
at how you go through this

agenda in different directions.

I've seen places where agenda 1 is our
agenda, Compliance report, that's the

first thing we're going to look at, are
we in with all our risk appetites, other

places that's 3rd or 4th down the agenda.

Their 1st agenda item is, here's our
financial performance this month and

here's the CEO's report and here's the
CFO's report and somewhere in there.

They eventually get to
these compliance reports.

But the important thing is
you create a consistent.

Way to whole approach your board
meetings and your board packages.

That builds trust with your board.

There's an art involved in this because,
like I said, you have to balance what the

board needs to know with what they want to
know, and based on their backgrounds, they

want to know more and there's always this
fine line between giving them appropriate

data versus giving them too much.

And like I said, you have
to be very careful about.

Overwhelming your board with detailed
data that they don't need because it

just creates a situation where they don't
understand what your risk profile is, or

it invites them to dig into micromanaging
stuff that they don't need to micromanage

and that can create a world of problem.

In and of itself, if the board starts
micromanaging daily operations.

Treichel: Great point.

Great point.

This is this has been as always enjoyable
talking through some more stories.

And I think this is another great episode
that credit unions can listen to, to

improve their corporate governance,
improve their relationship with N.

C.

U.

A.

Any questions I should have asked
you that I didn't ask on this topic?

Todd Miller: No, but maybe I can summarize
things, in just a couple short points.

And like I said, there's a lot of art
and a lot of detail that goes into this.

But at the end of the day, you're
trying to accomplish a couple things.

Is with good board reporting, you
want to present data that helps

board members make good decisions.

There's a lot that goes into that, but
at the end of the day, that's what you're

trying to accomplish is present data that
helps board members make good decisions

and you want to give them a clear
understanding of your current situation

and you want to keep their focus.

It's on future actions.

Where do we need to go going forward?

And that's the challenge.

And sometimes I wonder how did you
accomplish that as an executive

director when you had changes at the N.

C.

U.

A.

board level?

I have a feeling there was changes made,
each time you got new directors and

new directions there, but maybe not.

Maybe you guys were very
consistent about things.

Treichel: We were able to keep some
things on track, but as I said, every time

the board chair changed, it was, purple
became yellow and yellow became purple.

And a board comes in, like you said,
what does a board want to know?

And what does a board need to know?

They come in.

Every person is the journey that they've
taken through time and what they've seen,

what they've been exposed to, what they've
seen elsewhere, what their particular

interest is that what That plays a
role on it, whether it's the board or a

teacher's credit union board, which is
going to, have a certain, if they're all

teachers, they were trained in one way.

If they're all farmers, they're
trained in a different way.

I remember 1 of 1 of my favorite.

Learning experiences when
I was a new examiner was a

credit union in a farming area.

And the credit committee was all
farmers and the board was all farmers.

And I learned more about farming
in that one week than I ever have

in any point in time in my life.

And I got a comfort level, but they
were asking for particular things just

because of the journey that they've taken.

Todd, that was a great summary.

I think that's going to be the sound
that the sound bite from this one

is what you just summarized there.

As always, I appreciate your thoughts
on these important credit union topics.

Thanks for your time.

Yep.

Thanks for your time, Todd and listeners.

I want to thank you as always.

Thank you for listening.

This hope you'll listen again soon.

Mark Treichel signing
off with flying colors.