Credit Union Exam Solutions Presents With Flying Colors

Speaker: Hey everyone.

This is Mark TriCal with another
episode with Flying Colors.

Today's episode is going to
be a little bit different.

I'm going to respond directly to
a podcast put out by the American

Bankers Association, the A BA on
what they're calling the dangers of

Credit Union member Business Lending.

To be specific, March 30th, they
issued a podcast called Our Credit

Union Commercial Loans Risky Business.

It's, uh, not that long of a podcast.

I made it about halfway
through and heard so many.

Wrong statements that I decided I was
gonna do a podcast at that juncture.

So I've been researching my memory on some
things and putting a a, a script together.

I typically don't use much
of a script when I do these

things, and it's very clear.

The podcast that I'm referring
to didn't use a script because

they didn't even use any.

Facts, quite frankly a lot
of their stuff was squishy.

A lot of their stuff was wrong.

And it's, uh, something I wanted to deal
with here because credit unions do a good

job in commercial lending generally, and
I kind of wanna set the record straight

so if you're listening to this for the
first time, uh, I spent 33 years at NCUA.

I was.

The executive director at NCUA for
the last eight years of my career.

And I also spent another five and a
half years since then in consulting.

So in October I'll have 40 years
in the credit union industry.

And, uh, so I know a
lot about credit unions.

I know a lot, lot about.

Uh, how NCA deals with credit unions.

I was there when a lot of the things
that the A BA claimed happened happened.

And so I kind of want to give you my
take on this and my facts on this.

And again, uh, the A BA has every
right to advocate for its members.

That's literally what they're paid to do.

Banks and credit unions compete.

Now, that's a real reality.

And when credit unions expand into
commercial lending, banks feel

it, then they call their trade
association and they say, push back.

So I understand that,
but call it what it is.

Advocacy addressed as analysis,
and the range of what's going

on here is pretty wide at best.

This is sloppy.

At worst, it's an attempt to mislead the
public about the credit union industry.

I'll let you decide where on that spectrum
this falls, but either way it doesn't go

unanswered 'cause I'm gonna answer it.

So a former colleague of mine.

Had a phrase that he used
called Roughly correct.

It meant you're in the ballpark,
the direction is right,

even if the details are off.

He would use it at the NCA
board table when he didn't wanna

embarrass an NCA board member when
they got it roughly correct and

wanted to keep the meeting going.

. But the reality is what's in the A BA
podcast isn't even roughly correct.

The host invents a waiver
process that doesn't exist.

The economist conflates two completely
different regulatory mechanisms.

The stress testing argument
ignores the most relevant data

point in the entire discussion.

That's not roughly correct.

That's just wrong.

. So I listen to a lot of podcasts,
a lot of sports podcasts.

A lot of banking podcasts.

I do it when I'm.

Getting ready to go to bed.

I do it when I wake up and go for a walk.

If it's not music I'm listening to a
podcast and one of my favorite sports

podcast is a show called Check the Mic.

They have a segment on that show
once a week where they talk about

the shouty shows, as they call them.

Shows where people shout.

That's the name they give for shows.

By Skip Bayless and Stephen, a
Smith type content, loud opinions,

selective facts, and maximum outrage.

They take a real topic, they strip out all
the nuance, they pick the most alarming

angle, and then they yell it confidently.

It makes great content,
but it's not analysis.

In my opinions, that's what this
episode of the A BA podcast is.

It's the Shouty show version
of their take on credit unions.

And today I'm gonna do some fact checking.

So fair warning, this episode's
gonna, this episode is gonna run

longer than the one I'm responding to.

They made their case in
about 12 and a half minutes.

It's gonna take me longer to fact check.

Their mistakes or their
claims, if you will.

And one more thing before we
jump into, uh, the specifics.

I love credit unions.

The a BA loves banks.

We both have a bias.

I'm gonna do my best to stick to
the facts and show you my work.

They didn't do either.

So I, you know, again, I spent my
career inside the agency that regulates

credit unions and the last five years
helping credit unions from the other

side, having changed teams, if you will.

I've seen examinations,
I've seen the data.

I've sat in the rooms where
these decisions get made.

So, and been in on some of these
decisions that they're criticizing.

So let's go through their
claims one by one and look at

what the data actually shows.

So claim number one, but first,
actually before I get into claim

number one, a little history of the
the a BA hopes that you've forgotten.

I.

Before I get into these specific
claims, I want to give you some history

because the A BA presents this as if
it's a new concern driven by new data.

It isn't.

This is a 35 year campaign and
understanding where it started tells

you everything you need to know about
what risks really motivating it.

Today, the A BA filed a lawsuit,
challenging credit union

field membership, specifically
multiple common bond membership.

Back in 1990.

Why field of membership?

Because more members meant more
competition, more deposits,

more loans, more relationships.

The A BA wanted to slow that growth,
that case wound its way through the

courts and ended up in the Supreme Court.

And guess what?

The A BA was, right?

And they won by a vote of five to four,
written by Justice Thomas, the attorney

who argued that case for the A BA.

A fellow by the name of John Roberts.

Yes, the current Chief
Justice of the United States.

He won that case for the bankers.

The Supreme Court decision
threatened the existence of over a

thousand credit unions overnight.

Congressional Congress responded with
HR 1151, the Credit Union Membership

Access Act signed into law in 1998.

It fixed the field membership problem.

The A BA lost the legislative
battle, so they won the court battle.

Credit unions rallied.

Congress said, Hey.

These credit unions have a lot of power.

We like credit unions, so
they came up with a fix.

Now this is what it, where
it becomes interesting to get

HR 1151 through the Senate.

There had to be a compromise, and that
compromise was the 12 and a quarter

percent member business lending cap.

Now there's another podcast, credit Union
Conversations with Mark Ritter who had

Todd Harper and Mike Radway, formerly of
NCUA, and formerly involved in 1151 and

other things in Congress, uh, on, on.

And I had listened to that podcast
and I know some of the history,

but I'm connecting now going to.

In a little bit, I'll be connecting the
podcast that Mark Riter did on 1151 and

the a b, a podcast that I'm talking about
that, that came out a couple days ago.

So Mike Radway, who helped
draft that legislation and was

in the room when it happened.

Described it plainly in a recent episode
of the Credit Union Conversation podcast.

The cap was there to assuage this
is, this is Mike's word, assuage

Senator Richard Shelby of Alabama.

Shelby needed something he could point
to and say to the bankers, I voted for

this bill, but I got you something.

And that something was the MBL cap.

Now think about that for a moment.

The A BA didn't sue over business lending.

They sued over field of membership, but
when Congress handed them a legislative

defeat on field of membership,
they were happy to take a cap on

commercial loans as part of the deal.

Law and sausage, right?

What are the two things you
don't wanna see being made?

Law and sausage, because commercial loans.

Are where the fees are.

Origination fees, servicing fees,
relationship banking, cross sells.

That is a very profitable
line of business.

The cap was a two for one.

They lost on field of membership,
but walked away with a constraint

on the most lucrative product.

Banks offered their members.

That wasn't about protecting safety and
soundness as alluded to in the, uh, a BA.

Banking journal podcasts.

This was about protecting bank revenue.

There's one more historical
irony worth noting.

The cap that was designed to limit
credit union business lending

actually had the opposite effect.

According to Mark Ritter, the host
of Credit Union Conversation podcast.

Who featured this history lesson made
an observation that stuck with me.

He said the cap jumpstarted, the
credit union business lending industry.

It helped create the QSO ecosystem.

It helped credit unions working together
and raise the flag that said, if that

said, this is a legitimate thing to do.

Mike Radway called it The Law
of Unintended Consequences.

You put in place A limit thinking
you're going to stop something, and

all you did was rave wave a red flag.

So the next time you hear the A, BA,
talking about safety and soundness

concerns around credit union business
lending, remember they created the

conditions that produced the cap.

They extracted it as a consolation prize
after losing on field of membership,

and the cap ended up growing the very
industry they were trying to constrain.

Keep all of that in mind as
we go through their claims.

So claim one was the 2016
rule change was a relaxation

that opened up the floodgates.

Let me start with a direct quote from
the A BA podcast because I want you to

hear exactly what they said the host
asked about, and I'm quoting these

waivers that come from NCA to operate
above the cap, and whether it's a

rubber stamp for credit unions to exceed
the 12 and a quarter percent limit.

The economists respond
at the 20, the 26th.

Teen change had to do with the change
in the waiver process where pretty much

you could go ahead and self-certify and
really there was a relaxation there.

End quote.

These are two separate errors
running together in that exchange.

And I wanna untangle them both because
they go to the heart of whether this

is sloppy work or something else.

Or something, whether this is
sloppy work or something worse.

Error one, the host says NCUA, issues
waivers to let credit unions operate

above the 12 point a quarter percent cap.

That's just factually wrong.

There are no such
waivers, there never were.

The cap is set by statute, by the
Federal Credit Union Act itself.

To operate above it, you either had to be
a Credit Union chartered specifically for

the purpose of member business lending.

Or hold a low income designation.

Both of these are statutory provisions.

Congress put them there.

NCUA has no authority to waive the
statutory cap, and the economist sitting

right there never corrected the host.

That alone should tell you something
about the rigor of their analysis.

Error two.

What NCA actually eliminated in 2016
were loan level underwriting waivers

under part 7 23 of N NCAA's regulations.

Under the old rule, credit unions had to
come to NCA and get case by case approval

for specific underwriting exceptions,
things like making a commercial loan above

80% loan to value, waiving the 25% equity.

Interest requirement or waiving
the personal guarantee requirement.

NCA was literally approving individual
loan parameters and individual loans.

And here's what N NCAA's
own record shows by.

By the time the 2016 change, there
were over 1000 active MBL waivers.

Over 1000 NCA itself acknowledged
the waivers had become the

norm rather than the exception.

This is not a well-functioning
regulatory system.

This was a bureaucratic bottleneck.

So what did NCA do?

They eliminated the prescriptive
requirements that were generating

all those waivers, the specific
LTV ratios, the equity minimums,

the portfolio concentration limits.

And replace them with a principles
based framework requiring board approved

policies, qualified lending staff, and
demonstrated risk management programs.

The federal register for the
2016 rule is explicit quote.

The removal of the prescriptive
requirements does not relieve the credit

unions from setting appropriate limits.

The NCA Board believes these
internal constraints are necessary.

Risk mitigation practices, end
quote, oversight didn't weaken.

It shifted from checking boxes
to evaluating whether the risk

management processes actually works.

That's what every other financial
regulator in the country does.

The A BA calls that a election,
NCUA called it modernization.

I was there then and it was modernization.

I spent 33 years at the agency and
it eliminating a thousand waiver

backlog of case by case loan approval.

Eliminating a thousand waiver backlog
of case by case loan approvals

and replacing it with the same
supervisory framework that OCC and F

DS uses is not loosening oversight.

It's finally catching up to how the
rest of the industry already operates.

Come on guys.

The a BA economist described the
elimination of a loan level underwriting

waiver process as if it were loosening.

Of the CAP oversight, those two complete,
those are two completely different things.

One is a supervision methodology.

The other is a statutory lending limit.

Conflating them is either
misunderstanding of how NCA

regulations works or it's deliberate.

You decide which claim two, the
member business lending cap is.

Notional.

The A BA podcast argues that between
low income designation, exemptions,

waivers, and bank acquisitions, the MBL
cap has become essentially meaningless.

Their words, not mine.

I already told you
where the cap came from.

It was a political deal, not a carefully
calibrated safety and soundness limit.

So when the A BA complains that the
cap is full of holes, what they're

saying is that the political bargain,
their industry helped negotiate in 1998

didn't hold up the way we had hoped.

That's a political
grievance, not a regulatory.

And every single mechanism they're
complaining about was put there

by Congress, not by NCUA, acting
unilaterally, not by credit unions

gaming the system by Congress.

The low income designation exemption is
in the Federal Credit Union Act itself.

The act of Congress, the waiver
process, has statutory basis.

The bank acquisition pathway
was never prohibited.

By the way, they got into banks.

If the a BA thinks those statutory
exemptions shouldn't exist, they should

go to Congress and make that case.

But calling it circumvention
implies credit unions are

doing something underhanded.

They're not.

They're using mechanisms.

Congress deliberately authorized
using a lawful exemption isn't

circumvention, it's compliance.

I pulled the number of credit unions
currently operating above the 12 and a

quarter percent cap from NCA call report
data as of the end of the year, 2025.

It's 285 up from the 184 in 2021.

But every one of those credit unions is
using a mechanism Congress authorized.

That's not a loophole.

That's the system working as designed.

Claim.

Three, the low income
designation explosion, the A

BA makes a lot of the fact.

That the share of credit unions with
a low income designation rose from

6% in the year 2000 to over 54%.

Today.

They frame this as suspicious as if
credit unions are gaming a designation.

To avoid the MBL cap, let's look
at what the data actually shows.

And Sue's call report analysis confirms
the total number of federally insured

credit unions has fallen from 5,000.

48 in 2021 to 4,374.

By year end 2025, a drop of
over 13% in just four years.

The industry is caught
consolidating rapidly.

I recently did a podcast on
mergers couple weeks back.

If you're interested in that
data, take a look, uh, on.

The podcast from mid-March, so when
the A BA points to a rising percentage

of low income designation credit
unions, part of what they're seeing

is simply a shrinking denominator.

Fewer total credit unions means
the percentage rises even if the

raw count of low income designated
institutions stays flat or declines.

And the lid, credit unions who take
advantage of subordinated debt so they can

serve their members who take advantage of
not having the member business loan cap.

So that they can make loans in their
community make sense that those

might be the ones that would survive.

'cause they're serving the
entire purpose of what they

can do, but more fundamentally.

Why has eligibility grown?

The criteria for low income
designations, again, shocker, are

set by statute and regulation.

They haven't been dramatically loosened.

What changed is that NCA has done
outreach to encourage eligible credit

unions to apply for a designation.

They were already entitled to.

Demographic changes over the past
25 years have genuine, genuinely

expanded the universe of credit unions
serving lower income communities.

The A BA wants you to see a conspiracy.

The data shows a regulator encouraging
eligible institutions to take advantage

of a congressionally created designation.

Claim four.

All of these are laughable, but
this one is quite laughable.

N two A lacks the expertise to
supervise commercial lending.

I take that personally, and I say
that as someone who's, again, spent 33

years at NCA, the A BA says, and I'm
paraphrasing, the NCA, probably lacks

both historical and current expertise
to supervise commercial lending.

Their evidence.

Bankers on their commercial real
estate committees say that credit

unions will do some loans that
bank regulators wouldn't allow.

So, let me get this right.

Low income designated credit unions
are getting served by credit unions

making loans, and they must be bad
loans 'cause banks wouldn't make them.

That's not evidence of
supervisory failure.

That's evidence of competition.

When a credit union offers
a loan that a bank won't.

Or at a lower rate.

It might mean the credit union has looser
standards as they implied, or it might

mean the bank regulators are overly
conservative, or it might mean that the

bank is overly conserv conservative.

Or it might mean the credit union
has a different relationship

with that borrow borrower.

You can't tell from that anecdote.

What I can tell you that NCUA has had
member business lending regulations

since the 1980s, updated comprehensively
in 2003 and modernized again in 2016

by one of my members of my team, VIN
Vitton, who helped rewrite the rule.

NCUA has specialized
commercial lending examiners.

They have, some would argue they have
too many commercial lending specialists,

but it's not an area they ignore.

It's an area they get hyper aggressive on.

The agency also has concentration
risk, guidance, interest rate, risk

requirements, and net worth standards
that apply to commercial lending activity.

So as N C's Commercial Lending
supervision identical to what

the OCC does for large banks?

No.

Should it be no credit
unions are different.

They're member owned cooperatives,
not investor owned corporations, but

the claim that NCUA is asleep at the
wheel on commercial lending supervision

simply doesn't match the reality.

Now, I'll throw one caveat out there.

Okay.

NCUA, I've talked about this a lot.

NCA has lost 27% of their staff.

They lost a lot of good staff, but the
one area they were overhired in, in

my opinion, was an regional lending
specialist, which includes the super, the.

The specialization of commercial lending
and understanding that environment.

And by the way, every banking regulator
is dealing with that because they all had

to deal with the Trump mandate to shrink.

So is the a BA criticizing banks
and the OCC, uh, for shrinking?

No, they're not.

They just wanna attack
credit unions, in my opinion.

That is.

Claim five, the bank acquisition,
commercial loan comparison.

The ABAs economists pointed out that
credit unions that have acquired

banks carely nearly 20 times the
level of commercial loans as credit

unions that haven't done acquisitions.

They present this as alarming.

I want you to think about
this for one moment.

When a credit union acquires a
commercial bank, what does it acquire?

A commercial bank's portfolio.

Of course, the commercial loan
balance is dramatically higher.

Part of that's because.

They didn't have a 12.25%

cap thrust upon them because
the banks wanted it to be there.

Why?

Because it's profitable.

So that's the entire
nature of this transaction.

That's the A mathematical identity
dressed up as an alarming finding.

It tells you nothing about
underwriting quality.

It tells you nothing
about delinquency rates.

It tells you nothing about whether
NCO a's supervision is adequate.

It tells you that when you merge
a commercial bank into a credit

union, the credit union ends
up with more commercial loans.

Oftentimes, that's the
whole point of the merger.

Now, if the a BA wants to make
an argument that post-acquisition

integration creates examination
challenges, or that the combined entities

need enhanced supervisory attention,
that's a legitimate conversation.

I've had that myself, but
that's not what they said.

They presented a mathematical
inevitability as evidence of a problem.

Claim number six.

These loans haven't been
through a stress scenario.

The A BA argues that because most of
the growth in member business lending

happened during an economic expansion,
we don't know how this portfolio will

perform when things get tough and on
the surface that sounds reasonable,

but let me tell, give you a comparison.

Comparison.

They conveniently left out bank commercial
real estate delinquencies peaked at 9%.

9% in 2009 and 2010 following
the financial crisis.

9%, and that was under the
supervision of the OCC and the

FDIC and the Federal Reserve.

The very regulators, the A BA is holding
up as the experts that NCUA should

inspire to emulate current credit
union commercial loan delinquency

as of year end 2025, about 1%.

I know that because I pulled
it myself from N NCAA's call

report data, and if you use this.

The 60 plus day delinquency definition,
which is actually more standard

comparison to bank CRE figures, it's 0.44%

against the 9% worst case in 2008, 2009.

Now, to be fair, credit union
commercial loan delinquency has been

rising, and that's worth watching.

I've talked about it
here, that delinquency.

Collectively in the industry is over 1%
for the first time in more than a decade.

NCA itself has identified credit
risk as a supervisory priority, but

we're talking about a delinquency
rate that is a fraction of what

bank CRE produced during the actual
stress scenario of 2008 and 2009.

And oh, by the way, NCUA does
have credit union stress there.

They do stress tests on their,
when they have concentration risks.

I've seen it when I was at NCUA
and I see it and hear about it.

In my conversations with
credit unions today, the, these

loans haven't been tested.

Argument cuts both ways.

History shows us which system
pro produced the systemic crisis.

It was banks, not credit unions which.

Institutions had horrific delinquency in,
in oh 8, 0 9 banks, not credit unions.

So again, you be the judge of
what they're trying to do here.

And here's something, the A BA really
doesn't want you to think about.

Former NCA Chairman Todd Harper,
someone who spent years overseeing

the credit union system from the
top said it plainly in a, in the

same podcast I mentioned before,

well-written and well underwritten
member business loans have the ability to

perform differently in different economic
cycles than auto loans or mortgage loans.

And that he said is good.

From a safety and soundness perspective,
diversification into business lending

isn't a risk to the system done right.

It's a protection for this system.

The A BA is arguing it exactly.

Backwards claim seven.

The small business satisfaction
data, the A BA Economist cites the

Federal Reserve Small Business Credit
Survey to argue that small businesses

consistently prefer banks over credit
unions for their lending needs.

And they're right that the
survey shows higher sinis

satisfaction scores for banks.

But here's the methodological problem.

They don't mention that survey measures
satisfaction among approved applicants

at institutions they chose to apply to.

If credit unions have membership
eligibility requirements that filters

who applies in the first place,

you're comparing different
populations like apples to bananas.

The members who chose their credit
union and got approved for a loan

is a fundamentally different survey
respondent than the small business

owner who walked into a community bank.

Beyond that credit unions cons
consistently score among the highest

of any financial institution, type in
the American customer satisfaction in

index year after year, across the full
membership, not just business borrowers.

The A BA knows this.

They chose a survey that
supports their argument.

That's advocacy.

That's fine, but don't call it
objective economic research claim eight.

The level playing field
and the tax exemption.

The A BA argues that the combination
of credit union tax exemption and what

they characterize as looser underwriting
creates an unfair pricing advantage.

This is the oldest argument
in the ABAs playbook.

They've been making it since the 1990s.

The credit union tax exemption
exists because credit unions

are member owned cooperatives.

They don't have outside shareholders.

Their earnings return to members
through lower rates on loans, higher

returns on deposits, and reduced fees.

Tax treatment reflects the co cooperative
structure, not a subsidy that Congress

has overlooked and banks are not exactly
operating without tax advantages of

their loans deductions, tax exempt bond
income, FDIC, deposit insurance, federal

Home Loan Bank access, the playing field
is not even in as the A BA would have

you believe Congress has reviewed the
credit union tax exemption many times.

Over many decades and has
chosen to maintain it.

That's not an accident.

What this is really about.

I wanna be clear about something.

The competitive tension between
banks and credit unions is real.

You know that better than me?

'cause you're listening to this podcast.

When credit unions grow, when they
expand their field of membership,

when they acquire banks and take
on commercial lending portfolios,

community banks feel that that's real
comp competition for real customers.

I'm not dismissing that, . But there's
a difference between making a legitimate

competitive argument in producing what
is essentially a podcast dressed up with.

Charts that we can't see and data
points that don't make sense.

The a BA podcast presented
advocacy as analysis.

In my opinion is cited data selectively,
in my opinion, and I think if you

listen to what I said before this,
you probably agree, it made alarming

claims about systemic risk based
on a commercial delinquency rate.

That is a fraction of what the commercial
rate was when during the crisis.

And if you compare the crisis
rate in banks to the what

happened in credit unions.

It was 8, 7, 8 9 fold, and their proposed
solution, congressional hearings, or an

enhanced oversight conveniently aligns
with the Abba's longstanding legislative

agenda to restrict credit union growth
when the solution happens to match

the advocate's preexisting agenda.

That's always worth noting.

What does the actual data show?

Credit Union net income for the full year
ending 2025 was up over 30% over 2024.

I pulled that from their call report data.

The aggregate net worth for federally
insured credit union stands at 11.28%

as of the end of the year.

Well above the 7% well capitalized
threshold and member business

lending has grown steadily.

From 109 billion in 2021
to 185 billion in 2025.

That's real growth, but it
is steady, consistent growth.

Growth over four years, not the
explosion, the A BA describes.

So I understand rough justice
sometimes you made a broad point

and the details aren't perfect.

I use it myself sometimes, and I say
the term rough justice, but rough

justice that produces wrong collude.

Conclusions and leaves innuendos hanging
in the air about an industry's safety.

And soundness is not analysis.

It's a talking point.

The A BA is entitled to
their talking points.

The credit union is entitled,
credit Union Industry is entitled

to the Facts, the ABAs Framing of
this as a systemic risk emergency

requiring congressional intervention.

That's a political argument, not
a safety and soundness argument.

And credit union people
should know the difference.

And up to this point in time,
Congress has known the difference too.

So my takeaway for credit unions, if
you're a credit union executive or

board member, here's what I want you
to walk away from with this episode.

First.

Know this, know that this
argument isn't going away.

The A BA will keep making the case
that credit unions have strayed

from their original mission.

They have the resources to fund
studies, generate media coverage, and

push this narrative on Capitol Hill.

You need to be prepared to counter
it with facts, with your own story,

with data about who you serve
and what you do for your members.

That's why I go to America's
Credit Union's, GAC.

That's why I'm thrilled.

Every time I see 6,000 credit union people
there hiking the hill, you hike that hill,

you tell your story, and you will keep
this nonsense from the a, b, A at bay.

Second, the best defense against these
arguments is running a good credit union.

Maintaining appropriate capital, having
strong underwriting standards for

your business loans, building in the
risk management infrastructure that

justifies the trust that your members
place in you when your institution

is well run the ABAs arguments find.

Who wants to listen.

Third, engage in NCO a's
supervisory process proactively.

Don't wait for the examiners
to find problems with your

commercial lending program.

Have the policies, the staff,
the concentration monitoring,

and do your annual follow-ups.

By the way, that's one of the things
when we get brought in to have

conversations with credit unions and
commercial lending, the one thing that.

That can always be done a little bit
better is those annual reviews show

the examiners you're on top of it.

That's how you get through your
exam with flying colors, and that's

what we're here to help you do.

And fourth, be skeptical
of data without context.

When someone cites a statistic
without explaining what it means.

What it's being compared to
and what they're leaving out.

That's usually a sign that you're
dealing with advocacy, not analysis.

All right.

That's all I've got for you today.

I hope you found this episode helpful.

If you wonder how I come
up with my podcast topics,

sometimes it's listening to.

Another podcast and concluding,
hell no, that's wrong.

And that's what this podcast was about.

As always, I wanna thank you for watching.

Thank you for listening.

This is Mark TriCal signing
off with flying colors.

I.