Credit Union Exam Solutions Presents With Flying Colors

Hey everyone.

This is Mark Trico with an emergency
episode of With Flying Colors.

President Trump has been sued over
the firings at NCUA being sued by.

Todd Harper being sued by Tanya
Ska, both former NCA board

members and who were let go.

Earlier this month.

I'm going to walk through a little
bit of their legal filing, a little

bit of what my take on it is.

Again, I'm not an attorney.

I'm not a lawyer.

I've spent a lot of time with attorneys
and lawyers at NCUA, so I understand

some of what makes them tick.

I did a little bit of research on
the case, did a little bit more

research, and that's what you're
going to hear from me today.

All right, so we're gonna break this
down into three categories, the legal and

constitutional framework of the lawsuits.

Then we're gonna dive into NCA specific
structure and functions and how it relates

to the lawsuit, and then we're going to
dive into some of the litigation strategy

and broader implications of this lawsuit.

This is a slide from one of my recent
PowerPoints and one of my recent podcasts.

By the way, I've presented this to several
leagues across the country credit union

leagues, and if you're with a league
and interested in hearing any of this

or having any of this presented to your
members, feel free to reach out at the

contact information at the end of this
PowerPoint slide, and at the end of this

podcast and the end of this YouTube video.

All right, this kind of walks through
what has happened at NCUA, and I've

got two screens going here, so you
might see my eyes darting over.

But in February of 2020, the NCA
board agenda mentioned that Todd

Harper was going, or that a board
member was gonna be named Vice Chair.

It's my understanding and again,
on the left I have timeline,

truth, rumor, and intuition.

I've heard.

Some of this is truth, some of
it is rumor, and some of it's

based on all my time at NCUA.

I did hear that Helpmann was asked
to remove that item from the agenda.

They did that.

That was followed by Har Harper
Ska taking on excuse me, that

was followed by Helpmann.

Changing the overdraft and NSF reporting
that had been put in place by Harper

for billion dollar plus credit unions.

That was followed by Harper
and ska issuing statements

vehemently against that, saying
What's wrong with transparency?

Transparency is a har, transparency
is a hard word to argue about.

Then there were closed meetings,
a couple closed meetings to get

NCAA's downsizing plan approved.

By the way, they're going to be talking
about that at the May board meeting

according to the agenda that came out
in a statement that came up from Halman.

All right, so they have the
downsizing going on it first.

Didn't it get approved?

Then it got approved by a
two to one vote, I'm told.

And then NCUA announces they're
going to have a briefing on this, and

then Doge arrives at NCUA and then
allegedly Doge is unhappy with I.

The lack of following presidential
orders, if you will, particularly as it

relates to having staff back on site.

I'm hearing that some things have been
decided, and they're going to be forcing

the union staff back on site also.

So April 15th, Harper Noka were fired
via email that came from a statement.

Email reference came from a statement
that ska made and that is reiterated

here in the lawsuit into a canceled
their board meeting that NCA after a

couple days comes out with a statement
to staff saying that a quorum is one.

The Federal Credit Union Act requires
a quorum for the NCA Board to act.

They're saying if there's only one.

Then a quorum is one, and then NCUA on
April 23rd, a couple days ago, announces

they are reopening succession planning
and the simplification of insurance

rule, which would require a board action,
meaning that halman plans to act as

a board member of one, theoretically.

All right, so that's a little bit of
background on how we got here, and then.

Reporting this on April 29th.

This will go up on April 29th.

Yesterday they filed, they ska and
Harper filed a lawsuit against president

Trump, Scott Besant, Larry fao,
and others in the chain of command.

Although I wouldn't, I would argue
FAOs not in the chain of command, but

he probably had to take some actions
at NCUA, like taking away their access

to their computers, taking away access
to their email, taking away access

to the building that a staff member
would have to do, which is probably

why his name is in the lawsuit.

All right, next slide Is the NCOA
specific structure, and excuse me.

Next slide, the legal and
constitutional framework.

So we're gonna walk through
the constitutional show,

go Showdown beginning.

We're gonna what at pleasure means versus
independence in the 1978 restructuring.

We're gonna talk through the Humphreys
executor precedent, protecting

independent agencies unitary executive
versus congressional design, the

narrowing path of agency independence.

Robert Swan versus Bill
Clinton that's also NCUA.

And the 50 year of 50 years of.

Of respect for fifth term
fi for fixed terms that have

been in place at the agency.

So first up case background and context.

So this newly filed lawsuit, Harper
v Trump Challenges presidents Trump's

un unprecedented removal of two
national Credit Union administration

board members earlier this month.

This marks the first time in NCAA's
50 year history that a president has

removed board members during their fixed.

Terms, and that's key,
creating a constitutional

showdown over executive power.

These removals allegedly came with no
explanation or cause delivered through

identical one sentence emails from the
White House presidential personnel office.

So second bullet the 1978 restructuring
and implied the implied removal

protection Congress significantly
restructured the NCUA in 1978,

replacing a single administrator who
explicitly served at the pleasure of

the president with a multi-member board.

This deliberate removal of.

Pleasure language combined with fixed
terms and other structural elements

forms the basis of the plaintiff's.

Plaintiff's argument that board members
have implied removal protection.

The complaint specifically cites
Senator McIntyre's statement that the

amendment was intended to transfer
management from a single administrator

serving at the presidential.

To a board with fixed terms.

If you've listened to my other
podcasts, I often talk about how

an NCUA rule is a three act play.

You have the proposed rule
and the preamble to that.

You have the final rule, which is proposed
and voted on, and you have the preamble

and you have the actual language of the.

Of the rule that gets approved and
what they're, in my opinion saying

here is there were statements by
Senator McIntyre, which shows the

intent of why they made that change.

That change.

And I'll tell my clients sometimes
that, for example, you wanna understand

why the commercial loan rule reads
like it does read the preamble.

They'll say what their
intent is, so they're there.

I think cleverly showing that the intent
was to take away presidential power by

creating this board as opposed to saying
that they can just be flat out terminated.

The Humphreys executor precedent, I.

And independent agency precedent.

So in 1935, Humphrey's executor case
established that Congress can limit

presidential removal powers for
officials at independent agencies

that perform quasi legis legislative.

Quasi-judicial functions.

This precedent has protected independent
regulatory agencies for nearly a century.

Though recent Supreme Court cases
have begun to narrow its application,

the plaintiffs are relying heavily
on this precedent, arguing that the

NCA structure and functions place it
squarely within the Humphreys framework.

So that's what Harper
and Otsuka are arguing.

So the unitary executive theory
versus congressional authority.

So this case represents a clash
between the unitary executive theory,

which holds that the president must
have authority to remove officials

who exercise executive power.

And by the way, that's what
the press Secretary said.

He's the president, he
can fire whoever he wants.

Previous podcast, I had
her exact quote on that.

And Congress's authority to
structure independent agencies.

So lemme repeat that.

This case represents a clash between
the unitary executive theory and this

theory holds that the president must have
authority to remove officials who exercise

executive power and Congress's authority
to structure independent agencies.

Recent Supreme Court cases have trended
towards expanding presidential authority,

making this case particularly significant.

This theoretical conflict has profound
implications for administrative

governance and the separation of
powers in modern American government.

So I think that's why
they're suing, right?

They're saying, Hey, we
don't think you can do this.

We think you can, and it's gonna
take a probable long journey to

resolve all this which creates
other issues, which we will get to.

So recent Supreme Court precedence
that I've referred to, I'm gonna

take a sip of my spring water.

Although I may need something a
little stronger if we have more

of these emergency podcasts.

So the recent Supreme Court precedent
cases like SEAL A law versus CFPB in

2020 and Collins versus Yellen, Janet
Yellen, that is have narrowed Humphrey's

executor suggesting greater presidential
removal authority over agency heads who

exercise significant executive power.

The NCA case could test the boundaries of
these recent precedents in the context of

a multi-member financial regulatory board.

Of course, that multiple re multiple.

Member Financial regulatory board is
the NCA Board, which typically has

three board members, typically two
of the par of the party in power.

But that got all mucked
up a couple rounds ago.

So the situation was you had two
Ds and one R with an R in the

White House, which is probably what
triggered some of this some of the

reasons for why they were fired.

Despite the fact that they had
a one sentence apparently had a

one sentence firing that didn't
really go into any of this.

This nsu, a TE case could test the
boundaries of these recent precedents

in the context of a multi-member
financial regulatory board.

The current Supreme Court has shown
a willingness to revisit longstanding

precedents regarding administrative
agencies and executive power.

This Supreme Court has an
appetite to take a look at this.

They seem to whittle away at the
independence of the agency and

create more power for the President.

We could be heading for a showdown
on this topic at some juncture.

So the role of Swan Robert Swan
versus Clinton as president.

So I was at NCA when Robert
Swan got fired by Bill Clinton.

I was in the division of Special
Actions at the time, I believe.

So the DC circuit's decision in Swan
versus Clinton examined NCA Board member

removal authority, but ultimately,
it only assumed removal protection

without definitely ruling on it.

This creates an interesting presidential
situation where the most directly

relevant case avoided a final
determination on the core issues, leaving

significant room for interpretation.

Plaintiff cites SWAN as supporting their
position while the government, Trump would

likely emphasize its non-binding nature.

So they assumed that there were
removal protections for swan.

They didn't address it, and then
they went on to explain why it

was okay for Swan to get fired.

I don't wanna get into too much
detail here, but Harper and Otsuka

are saying this helps their case.

I would say the fact that it only assumed
that they had a case that Swan had a

case means it doesn't help them as much
as they think or hope that it will.

And there's probably other stronger
items that we'll walk through here

or have already walked through that
are actually a better defense or a

better offense, for the plaintiffs.

So the role of historical non-REM removal.

The role of historical non removal
precedent, the complaint emphasizes

that during the board's nearly 50
years of existence, so that's the

NCA Board's been around for 50 years.

The president has never removed a
member whose terms has not yet expired.

This administrative precedent could
play an important role in the court's

analysis as historical practice often
informs interpretation of constitutional

boundaries between branches.

The unprecedented nature of
these removals highlights the

cases exceptional significance.

So it's interesting they say that's
that history means something to me.

They have the authority in
never having used it doesn't

mean that they couldn't use it.

And I'll make a credit
union based comparison.

NSU a says that they can remove officials.

The Federal credit Union acts as they can.

Their policies and procedures establish
ways on which they should do that.

Behind the scenes,
they've never used that.

They'll only remove the entire board.

Y why just remove one when
you can re remove all easier.

So they've never used that rule.

But they claim that they can
use it at any point in time.

So if I was the Trump
administration, I'd be saying yes.

So what, they've never
done it in 50 years.

We'd never had a situation like
this where it needed to happen.

And I think, again, I don't
think that's necessarily in my

mind, a very powerful argument.

All right, so next slide.

Moving to the next slide, the NCOA
specific structure and functions.

So let's talk about the plaintiffs Harper
and Otsuka, Todd Harper and Tanya Otsuka.

The removed NCA Board members at
hand are suing in both personal

and official capacities to be in
straight in reinstated Harper.

Previously appointed by Trump and
later designated as Chair by Biden had

been leading initiatives on financial
stability and consumer protection.

Otsuka, a more recent
appointee had been focusing on.

Underserved communities access
to financial services, and this

is according to their writeup.

Both were removed despite having years
remaining on their statutory terms,

Harper, until 2027 and Otsuka until 2029.

Now I'm gonna digress here a little bit.

So Todd Harper actually had two terms,
and the Biden administration changed

the definition of what a term was.

Essentially, they said if you didn't have
six full years, you get two terms, which

has never been how it was interpreted.

Oh, by the way, we're up above,
they're arguing that this has

never happened in 50 years.

What had never happened in.

50 years was somebody succeeding
themself, Harper succeeding himself

and getting another six year term.

We've had board members
come and go and come back.

We've never had them run
for longer than six years.

And I, I, to me that's not what the
act, but no one has challenged that.

And at the time that it happened,
I remember trade associations and

discussions with credit unions
saying, Hey if somebody pursues

that, you could argue that anything
that Todd Harper voted on wasn't I.

A legal vote by the board, and we'll get
into that a little bit because I think

that has ramifications for discussions as
it relates to Houtman and him potentially

making making, taking action as a sole
board member, claiming that they have

that power, claiming that one is a.

A quorum.

Whether that's right or wrong, who knows?

All right.

The NCA structure and role in financial
regulation, the argument is that

NCA is a core financial regulator.

They're, they have a seat
at the table at fs o.

It might be at the kids' table,
but they do have a ta a seat.

All right, so the NCA structure
and role in financial regulation.

The NCA stands alongside the FDIC and
Federal Reserve as a core financial

regulator overseeing credit unions
that serve 142 million Americans and

safeguard over 2 trillion in assets.

Its three member board with fixed
staggered terms and bipartisan

requirement was designed by
Congress to insulate credit union's

oversight from political pressure.

This independence is particularly
crucial during financial instability as

demonstrated during the 2023 liquidity
crisis mentioned in the complaint.

I'm guessing that was the best argument
they could come up with because credit

unions didn't really have a liquidity
crisis when compared to what happened

at Silicon Valley Bank, signature Bank,
which were liquidated over a weekend.

And oh, by the way, in my opinion
they bailed people out beyond

the $250,000 insurance limit.

But again, that's a story for another day.

I have podcasts out there on that topic
and why I think that was a boondoggle

and that it was unprecedented assistance.

But that's the argument.

The, I can putting my, my,
I've been around lawyers a lot.

They said, you need to
explain how you are crucial.

And that happened when
both of them were there.

So they make the argument that.

I think SKA was there in 2023 as I'm
getting texts about this as I chat.

All right, so we talked about n
NCAA's structure and role in financial

regulation, which they're saying
they have, this is something they

have to claim as part of the case.

So executive functions versus
regulatory independence.

A central question in the case is
whether the NCUA performs substantially

executive functions favoring pr, which
favors presidential control, or primarily

quasi legislative and quasi-judicial
functions, which would favor independence.

The Trump administration would likely
characterize the N C's supervisory

activities as executive in nature
while the plaintiff's position.

As a, as similar to the FTC
and other independent financial

regulators, the complaint specifically
highlights the NNC a's rulemaking.

Consumer protection and market
oversight functions as paralleling

the FTCs protected role.

And they wanna parallel the FTC because
of the past Supreme Court case that

went forward as it relates to the FTC.

One of the things that I thought about is
the N-C-F-N-C-U-S-I-F ownership structure.

I.

So the N-C-U-S-I-F is owned by
insured credit unions themselves

rather than the federal government.

This creates a unique structure
that strengthens the argument

for n NCAA's independence.

This industry funded
model distinguishes it.

Distinguishes it from agency
agencies directly controlling

federal funds and suggests a
quasi-independent regulatory role.

The mutual ownership structure
also emphasizes the agency's role

as an overseer of a self-insuring
system rather than a direct

administrator of federal resources.

Now, the caveat to that would be
if the fund gets wiped out, the.

Taxpayer is liable ultimately.

So I think that you can
argue both sides of that.

But ultimately, treasury would ha
would have to, taxpayers would have to

fund it if the insurance fund was so
insolvent that credit unions couldn't

fund it themselves by recapitalizing it.

So it would be catastrophic,
but it's theoretically possible.

Now the central liquidity facility
would be an argument in support of the

Trump side, so the central liquidity
facility and executive authority.

The NC a's central liquidity facility
can borrow from the Federal financing

bank, creating a direct connection
to treasury and federal resources.

This relationship could strengthen
the argument that the NCA exercises

some executive functions that require.

Presidential oversight, particularly
during financial crisis, the

administration could argue this borrowing
authority involves economic policy

decisions that should align with the
President's overall financial strategy.

Now, as I'm thinking this through, if I.

If I was helping one side or the other,
which I've done in some lawsuits that

impacted NCUA, I would be saying, Hey,
what has NCA board members, what has

Todd Harper said in front of Congress
as it relates to the powers of the

central liquidity facility and what
they can and what they can't do?

I would look for language that
was utilized in front of Congress

if I was the Trump side to
try and say, Hey, here's why.

The central liquidity side of it.

Makes this something that is creating
a direct connection to the treasury and

that also strengthens the argument that
NCAA exercises some executive functions.

I think that'd be a pretty strong
argument, but I would try and

use their own words against them.

I would go search those
statements by Harper.

Not that anybody from the Trump
administration is listening to this, but

if they were, that would be my suggestion.

Alright, the quorum crisis.

Agency paralysis.

Do I need to change slides here?

I think I do.

Let's see.

The CLF, the Quorum Crisis
and Agency Paralysis.

Oh no.

Here we go.

We're operating without a quorum.

So the re, the removal of two
board members has left the NCUA

without the statutory quorum
required for board actions.

While the administration might argue that
a single remaining member constitutes

a quorum in emergency situations,
the plaintiffs contend this would

circumvent Congress's multi-member
design and bipartisan requirements.

If you only have one, you
only have one party in there.

That would be the argument.

This paralysis has real world implications
for the credit union system's regulatory

oversight, potentially affecting
millions of Americans who rely on

credit unions for financial services.

What's the sound of one hand clapping?

That's a line in a Van Morrison song.

A deep dive, a deep cut if you will,
but NCUA has come out publicly and

said that one board member can act and
that is their longstanding position.

It's their longstanding position
in my opinion, their delegations

say that the board can act
on anything that's essential.

A one member board, but that's a
delegation approved by the board.

The Federal Credit Union Act
says that you need a quorum.

So a quorum will be decided
perhaps at some day by the Supreme

Court as it relates to this.

Okay.

Financial stability and public.

Interest implications beyond
the constitutional questions.

The case raises serious concerns
about financial system stability.

The complaint emphasizes that
independent financial regulators

were designed for good reason.

A stable financial system depends
on independent regulators who act

free from political interference.

The outcome could affect how
financial regulators navigate future

crises and potentially impact.

Packed market confidence
in regulatory independence.

Time will tell as it relates to this.

All right.

Going to our second to last slide,
last substantive slide is the

litigation strategy and broader
implications of all of this.

So the legal strategies and
multiple claims the plaintiffs

have filed six different counts.

Including statutory violations,
administrative procedure act

claims, and constitutional
separations of power arguments.

This multifaceted approach gives the
court several potential grounds on which

to decide the case without necessarily
resolving all constitutional questions.

The complaint strategically includes a.

Claims for Dec Decla declaratory judgment.

The complaint strategically includes
claims for declaratory judgment, injunct,

injunctive, relief, mandamus, whatever
that is, and equitable remedies to

maximize potential avenues for relief.

So they're pursuing this
on constitutional basis.

They're pursuing this on
Administrative Procedure Act claims.

It's basically a full court press.

Throw everything against the
wall and see what sticks.

So I wanted to do a little research
on the legal firm that they hired.

And my guess is, oh, by the way, I'm
thinking somebody's funding this.

Some group is funding this for
Harper Notes because the cost of

this are gonna add up quickly on the
plaintiff's side and the agency I.

And everybody listed will be represented
by the US Attorney's Office, and

they can assign an army to that.

And there's no cost to these
individuals who, by the way, are not

being sued in their personal capacity.

They're being sued in
their official capacity.

But US Attorney's Office is an army and
somebody is funding this and I'm imagining

while it might be partially ska and
partially Harper, that somebody, with deep

pockets, who wants this constitutional
issue addressed is funding this so the

small but in influential legal team.

The plaintiffs are represented by Holwell,
Schuster and Goldberg, LLP which is called

a boutique litigation firm specializing
in high stakes, constitutional

and complex commercial disputes.

They were founded by a former judge.

Federal judge in 2012.

This relatively small firm is taking
on a case with potentially far

reaching implications for presidential
power and regulatory independence.

Their specialized expertise in
constitutional litigation may be

more valuable than the resources
of a large firm in this context.

So they have a niche, they found
the right people to, they're in the

right niche for what's going on here.

And they seem to, have done some of
this before, which is good for Harper

and Ska, but again, they're going up a
against an army against the US Attorney's

Office and they're going up against
Supreme Court that it leans to the right.

So it'll be interesting
to see what happens here.

So I don't know about the timeline.

I did a little bit of research and what
I found out is that cases like this

typically take three to five years to
reach Supreme Court decision if it.

Progresses through all levels of appeal
and given the cases constitutional

significance in involving presidential
power and independent agency

structure, it might receive expedited
consideration at some of the stages.

So does that mean trimming
three to five years to three,

or does that mean trimming.

Three years to one, or is that gonna
be something like the exporting of

illegals that gets, go past, go get all
the way to the Supreme Court quickly?

I don't know.

It's gonna be interesting, but if
it's three to five years, that creates

some challenges in many ways as well.

Also the composition of the Supreme
Court by the time the case reaches it

will be crucial as the court has been
incrementally reshaping administrative

law doctrines in recent years because
they're more on the right, they're making

decisions more with presidential power,
and so they may want to get this there

sooner than later, which might get it.

Quicker than the three to five years.

So who knows, maybe that means less
than a year time will tell implications

for other independent agencies.

The outcome could significantly impact
the structure and independence of

numerous federal agencies beyond the NCUA,
including other financial regulators.

The FCC.

FTC and independent boards and
commissions across the government.

A ruling expanding presidential removal
powers could fundament fundamentally

reshape the administrative state
agencies with similar multi-member

structures and fixed terms without
explicit removal protections would be.

Particularly vulnerable.

So it, it would impact other agencies.

But beyond beyond that, the, let's
talk about within the walls of NCUA.

What's going on at NC A right now is
they have a restructuring going on and

20% of staff have left or committed
to leave by the end of the year.

That's a big number, and these staff that
are leaving are core, long-term folks

that were either eligible to retire.

Or could do early retirement.

So they're losing a lot
of corporate knowledge.

That's gonna create some havoc
at the agency and already is.

It's going to create maop
morale problems and already is.

And when the dust settles, what
will the new NCOA look like?

Who knows?

I have stated in previous podcasts.

That NCUA staff has a lot of
talented people at every level.

So people will rise up to the
challenges and rise up to be promoted.

But they also have some
inabilities of hiring right now

under the Trump administration.

So it's gonna be a little
chaotic at NCUA right now.

But let's go back and discuss the my
first slide from my previous PowerPoint

where I talked about the fact that Hopman.

Says he can act on regulation.

This lawsuit says they can't.

Helpmann says that he is going to reopen
the comment period on regulations that

have been approved by the past board.

Let's talk about succession planning.

Trump has said We want to get rid of 10
rules for every one that you put in place.

Last administration, it
was two rules for every 10.

This time it's 10 for everyone.

I don't see how, when putting
regulations in place, I see him

looking to get rid of some regulations.

I see.

I see him trying to show the
administration that he is a good

soldier and I think that's why.

First they came out saying they could
take action, then they said they're

going to reopen the comment period,
which is tiptoeing into him taking

actions as a board member of one.

If they end up canceling those
regulations, which I'm gonna assume

that's where they're heading with
succession planning that would create

a situation where, how does this suit.

Play out.

As I mentioned earlier, if there had
been suits saying Harper didn't have

the authority to be in for two terms
instead of one term, which I think

would be a pretty good argument, could
you unravel everything that had come

before it so you could see, in my
opinion if Harper and Ska win that.

Or they decide that a quorum is not one,
and HELPMANN cannot act that there could

be some things that were canceled and
pulled away that would go back in place.

So that's un, that's unknown.

It's like the unknowns that
we have with the tariffs right

now, which is making the market.

Shaky, which is making small businesses
shaky, which is making other countries

saying, Hey, what, when the dust
settles, what are the rules gonna be?

NCUA staff, with all these other
morale problems they've got going

on with the downsizing, I could see
people say, Hey, you know what, it

Harper and SKA had the right to sue,
but this could be what pushes, another

1, 2, 3, 4, 5% of staff out the door.

So I think that number will go up.

They're gonna go, you know what?

This is this is beyond the pale for what
those career folks might wanna deal with.

And I think it will have, I think
these lawsuits, while they may be

appropriate and they may win, I think
it's ripping a scab off for the staff.

And it's gonna burn a lot of energy, a
lot of energy that's not focused on the

safety and soundness of credit unions.

So this is a political battle.

This is a personal battle.

It may be viewed.

They never underestimate
the power of self-deception.

People look for facts that
support their position.

People on both sides of the aisle
are going to argue for what they want

to, and credit unions and NCA staff
are stuck in the middle of this.

And the sooner it can be resolved, the
better so that the healing can begin so

that the new agency, whatever that might
be at the end of all this, can come about.

And I, in my.

Presentations to some of the leagues.

I did say, Hey, we'll have to see if
these folks sue Harper and ska that

is, and now they've decided to do
it, and they've, they seem to have a

firm that knows what they're doing.

I think it's getting funded
by somebody, as I mentioned.

And the reality is there's gonna be
a lot of scabs ripped off between

now and when this is resolved.

I think it's a sad state of affairs that
the industry has to deal with this, and

you can, whatever side of the aisle on you
can put point blame to either side, and

the credit unions are stuck in the middle.

The staff are stuck in the middle.

I'm disappointed from that perspective
and I'm just going to leave it at that.

I hope you enjoyed this emergency
podcast with some of my takes, some of

what I've done via research, and some
of this was verbatim from that filing.

As always, I wanna thank you for
listening or if you're on YouTube.

I wanna thank you for watching.

This is Mark TriCal signing
off with flying colors.