Compliance v Sales: Wrestling with Pay by Bank Growth

EPISODE SUMMARY
In this episode of Wrestling Payments, host Joe Casali sits down with Sarah Stapp, Chief Commercial Officer, and Geoff Scott, Head of Compliance, at Aeropay. Together, they dive into the ongoing push and pull between sales and compliance in the world of pay by bank, exploring how teams can move fast without leaving risk behind.

Sarah and Geoff discuss the growth of pay by bank in the United States, noting how new technologies and consumer demands are accelerating change. Sarah explains how sales teams must balance ambition with clear understanding of compliance boundaries, while Geoff shares his approach to building programs that enable innovation without putting the business at risk. They tackle challenges around third-party relationships, prohibited industries, and the tightening regulatory lens following high-profile industry failures.

The conversation highlights how the lines between banks and fintechs continue to blur. Both guests agree that effective payment operations depend on collaboration and a willingness to adapt. They close by reflecting on the importance of innovation, the evolving regulatory landscape, and how staying informed keeps both sales and compliance moving forward together.

GUESTS-AT-A-GLANCE

Name: Geoff Scott
What they do: Head of Compliance
Company: Aeropay
Noteworthy: Geoff brings deep experience in banking and risk management, guiding fintechs through compliance challenges as pay by bank and digital payments evolve.
here to find him: LinkedIn 

Name: Sarah Stapp
What they do: Chief Commercial Officer
Company: Aeropay
Noteworthy: Sarah helps financial institutions strengthen risk management, streamline compliance, and train teams to navigate ACH and payment operations with confidence.
Where to find her: LinkedIn

KEY INSIGHTS
Compliance Enables Growth—If You Build for “Yes”
Compliance doesn’t have to mean slowing down new ideas or blocking deals. The most effective compliance programs help operations move forward by focusing on how to reach a safe “yes” rather than defaulting to a hard “no.” This approach starts with clear frameworks, strong collaboration between sales and compliance teams, and early qualification of potential risks. When both sides understand the rules and communicate openly, teams avoid wasting resources on non-starters and instead build processes that let innovation flourish. By getting ahead of gray areas, documenting use cases, and educating everyone involved, organizations can streamline approvals and stay nimble in a changing payments landscape. Compliance, when structured proactively, becomes a business driver—not just a backstop.

Payments Innovation Is Driven by Consumer Demand
The payments industry constantly evolves because consumers want faster, easier ways to move money. Real-time money movement, instant payouts in gaming, and new payment methods like pay by bank all reflect this demand for speed and convenience. Merchants compete to keep users on their platforms, while financial institutions and fintechs race to roll out new options. This environment rewards those who listen to consumer behavior and adapt quickly. At the same time, teams must balance this pace with compliance and risk management. The firms that thrive are the ones that treat consumers as the starting point for innovation, shaping systems to meet user needs while maintaining clear operational guardrails.

Transcript

NEACH - Wrestling Payments - Sarah Stapp & Geoff Scott

Compliance v Sales: Wrestling with Pay by Bank Growth

Season 3, Episode 20

Joe Casali [00:00:00] Hello, welcome to Wrestling Payments. My name's Joe Casali. I'm your host. We have a battle today between good and evil. Not gonna say who's who, , but we're gonna talk about, , sales and we're gonna talk about compliance. , for intros, why don't you guys introduce yourselves?

Sarah Stapp: , well, I think good and ladies should go first. , so Sarah staff, , chief Commercial Officer at Aero Pay. , I've been in payments about 15 years and, , this is my second time on wrestling payments. I'm very excited to be here. , folks that may have watched the last, , or listened, watched, listened to the last podcast, , with Joe and I, , I was employee nber 20 at Braintree and have had lots of experience across multiple different geographies, , around the world and, , in the credit card, debit [00:01:00] card, alternative payments, local payments world.

And now, , I am hyper-focused on pay by bank in the US with Arrow Pay. All right, Jeff.

Geoff Scott Thanks sir. So, Jeff Scott, head of compliance at a pay. I have been in banking in some version of compliance for about 17 years now. So small community banks, regionals, , as an examiner with the Fed. , this is my third or fourth FinTech. . And all along the way, just trying to fight the good fight and make sure sales doesn't get me in trouble.

Joe Casali Nice just for those people tracking at home. He didn't say if he was good or evil. Just saying, , as we go on, . Jeff, I gotta ask you, you're new, , we, we, we have a little part of this that we, we talk a little bit about professional wrestling. Any, any experience. Did you watch it as a kid? Do you watch it now?[00:02:00] 

Geoff Scott , I threw my son on my bed, , the other day in a very fun, fatherly way, so. Definitely a level of recent experience. , yeah, I, I didn't really watch it much. I played a, a, a horrible Nintendo 64 game. , that didn't work very well when I grew up, but yeah, that's my

Joe Casali That's awesome. They, they go across the screen like this. I know exactly what you're

Geoff Scott Yeah.

Sarah Stapp: yes.

Joe Casali Very good. , alright, so let's get into it. Let's talk a little bit, you know, when you're talking about, , compliance, let's start with compliance. When you talk about compliance, . What are, what are the top three things you keep in mind?

, day-to-day basis on staying compliant? And, I'm sorry, let's rewind just a second. What's aero pay do Jeff? .

Geoff Scott Aero pay, , helps people pay by bank. So to move money, . Quickly and easily from their bank account to a merchant, , [00:03:00] selling them various services. , we also help link accounts. So if you have an account at one institution and you need to link it to your merchant, we can help with that. , we also have a fraud, , in risk product in the middle to try to cut back on any untoward activities.

Joe Casali And from a, from an, a newcomer to the industry, not you, but the, the idea of pay by bank, , how are you seeing growth? How, how's it, , developing, how, what's going on?

Geoff Scott Yeah. I, I think it's, it's, it's fun being here right now because the interest is definitely picking up. I mean, coming off of COVID, people not wanting to pay. Fees, , me as a user, everywhere I go now there's like, we're gonna charge you two or 3% for a credit card. , and I was the AM l officer at Discover, , network for a couple years.

So, , familiar with that side and have just been really surprised that that fee's out there. , also before [00:04:00] ape, you know, I'm familiar with Venmo, Zelle, all these other things, like why is, why is pay by bank needed? , but. They grew up a little bit differently. So I think the, the growth where we have, like in regulated markets and then , a lot of new types of merchants for anyone ranging from like grocery stores, , software companies, all sorts of things that have been showing interest in our product has been, , really fun.

, just for more of a compliance guy, like having a chance to be at the front of the wave of, of a product, even though it's been around a while in different shapes or form, like. Pay by bank itself, just, it feels new still. So that's a lot of fun.

Joe Casali Let's, let's, , I'm, I'm just gonna explore that just a little bit. Is it, . Is it a US system? Is it, , is is international, have it at all?

Geoff Scott So yeah, there, there's pay by bank, , in the US and internationally. , so everyone has kind of their own version of it. Well, I don't know about everyone, but, , there's definitely Europe [00:05:00] version. There's, , versions picking up in Latin America that I can't speak to as much. . But the version we work on is stuff of the US version of pay buyback.

Joe Casali Perfect. Alright.

Sarah Stapp: ours is on the HCH rails. Right. And so we we're, we're living. Staunchly in us, , U the United States of America. But of course, you know, there's, , seppa, there's faster payments in Europe. There's in India it's exploded in, , Brazil. It's exploded with picks. So there's all these different flavors that are rolled out very different ways.

So it's been actually really fascinating to watch. Like Jeff, like you said, it feels new and it does feel new in the US even. 'cause we're all in the us we're always a little slower, I think to pick up speed and, and things like that. We have a lot more people in the game too, I think in the US that we have.

You know, so many financial institutions compared to other countries, but we're, we're getting there and I think we're seeing very heavy concentrations of [00:06:00] adoptions in those regulated markets where cards, , the authorization rates are, are a little lower. , whereas we're acting as the processor, we're making the decisions based on data as opposed to leverage, you know, having to rely on this exchange of limited data between the acquiring side and the issuing side.

We're getting tons of data from, , this open banking, you know, bank linking, , process in, in the checkout experience. And we can make very informed decisions that way. So it's, , if I'm being extra payments nerdy, it's really cool to, , see how it's developing in the us.

Joe Casali So we're not really keeping score, but she got points for seppa,

Sarah Stapp: Bam, bam.

Joe Casali Nice. Gotta gotta check. Not marking it down. So as you think about compliance, Jeff, . You know, what are the, what are the top three things you think about? I also kind of reach out to financial institutions. [00:07:00] There's a whole, you know, there's a, compliance is at the core for financial institutions.

What, , what are some of the things to keep in mind for compliance when we, we talk about pay by bank.

Geoff Scott , yeah, a few things. I mean, I'll say a guiding principle for me for compliance is to try to find a way to get to yes. That, that's, that's how I think about compliance in general. , not, not like give an answer. It's how do I make it? Yes. , which along the way I might run out of ideas, you know, and I'm not, this isn't like, let's, let's commit fraud to get to Yes.

It's, we find a permissible way to get to. Yes. , so that, that's how I think about it at the top. I think maybe a nber two right now is there's a lot of, , focus on third party relationships. Especially partner Bank. The bank is a spon bank, , sponsor banking model. So we get kinda looped in with that, at least from like how I think about compliance at Arrow Pay.

So they look at us and say, all right, you're a FinTech, you're, [00:08:00] you're, , renting a charter, you're partnering with the bank. We're not doing these things. But a lot of the standards that are being applied to the third parties because of what happened with Synapse, , and the banks, , writing in that platform.

They look at us and say, well, surely you're holding customer money somewhere. We're not. , and now that the regulators are examining us really closely, so, , we have to look at you very, very, very closely. , I'm not saying you can't look at us, you shouldn't look at us closely, but we we're, it's not in the same, , universe where if you have your life savings with us, it's gonna be lost if we do something wrong.

Like that's just not, that's not our, , industry platform, vertical, whatever you wanna say. , finally, I think just compliance in general. How am I organizing, , the program and how am I follow what I said I would do without being a complete tto , TTO or with check boxes? 'cause I gotta merge. How do I get to yes, but also what [00:09:00] I have in place?

So I think the interplay between those two things is really important. Get better over time, but mostly follow what I have and try to find a way to keep things moving forward. . I, I had this one manager at Discover who said something to me, which like, it was, it sounded so stupid and look looking back, but he is like, the company has to make money, Jeff. You know?

Sarah Stapp: right.

Geoff Scott I think about that all the time. Yeah.

Joe Casali Little,

Sarah Stapp: But that's what I'm doing, Jeff, by bringing you all these deals you see, is to make the company money. No, but Jeff is really,

Geoff Scott right.

Sarah Stapp: really great to work with. I think that, oh, go ahead, Joe.

Joe Casali No, no. I wanted to, that was a great segue. I wanted to. , see with your top three when you're thinking about it, you know, your pedigree is just outstanding. That it, you know, that last answer was like, oh yeah, check, check, check. You only got one point, but it was great. But, but when you're thinking about sales, what, , is it, is it [00:10:00] education or is it sales?

How does that all work? Your top three things you think about.

Sarah Stapp: Yeah. , and I think for me it's . Especially working with somebody like Jeff who has that mindset. 'cause I've worked with plenty of people in risk and compliance in the past. I won't name names or companies. , but it has been, they've been dubbed the department of no. , so, you know, it's, I have had a lot of, , experience trying to stand on my head and say my ABC's backwards and, you know, .

What, what is it? Pat your head and rub your belly at the same time. Whatever that takes to get, , compliance to say it the right way to get the right answer. , and so for me from , working with compliance and how do I get deals through, it's making it as easy as possible for them to say yes. , and by, and to do that is understanding.

The framework in, in which, in the bot my, my sandbox [00:11:00] basically, in which I'm able to play in now. Where it gets fuzzy is when, , you know, it's like, oh, we, you know, we don't do adult. Okay, well it's a dating service adult. Like, it's just understanding those definitions, right. And, and, but asking early on and qualifying, that's where I've gotten burned in the past in doing sales stuff.

'cause I'll just. Somebody wants to get a deal and I see big dollars and I'm like, wow, that's a great opportunity. And then I bring it to, I brought it to compliance. They're like, , why did you think that we were gonna accept this? And I was like, because they're like the biggest. X whatever in the industry.

And they're like, okay, but it's still blah, right? They're like, we don't do that. That's on our prohibited list. So, , you know, understanding the prohibited list, but also understanding where there's the gray, , and getting that sense of clarity for compliance is very important. , I think to your point on education, you know, education on our, with within our own sales teams, but then also [00:12:00] educating compliance with.

Putting this information together, what is the use case? What is the flow of funds? And I feel like a lot of new salespeople, especially in payments. They just think, oh, it's payments. It's like, no, no, no, no. I need to know, like, are they holding funds? Is this like a payback model? Are they operating as merchant of record?

Are they taking on the, the, , risk? , are they handling customer support? What's their refund? You know, this like. Understanding, even though Jeff is trying to make it as easy as possible to say yes, there are still boxes that need to be checked, right? Like you, , have to have a refund policy. You have to have these things in place.

So I try and do my due diligence on the, in the very, very early stages, even before I'm spending a lot of time with that merchant. Because I don't wanna waste their time. I don't wanna waste the company's time either. , going down a path that we wouldn't be able to approve them. Or if I identify an issue, then I am, you know, highlighting that early on.

Like, Hey, we [00:13:00] are going to need, so like a good, a good, , example of that I think Jeff is, is like the third party audits, right? For a lot of regulated. Industries, they, we have to get third party audits or legal opinions. That is not something that you're gonna be able to turn around in a week, right? If you don't already have one on file, highlighting those early on and saying, Hey, we can say yes, but you do need to provide these pieces of information.

, so I think it's, it's doing our, doing my due diligence, it's educating the merchant on what is needed and educating compliance, and really putting together a package that is explaining. Their use case, their flow of funds, what is their business? What are they selling, what, you know, what are they actually doing at the core, even as long as it's within the acceptable use policy of the company.

And if it's in the gray area, then I'm going and talking to Jeff and being like, Hey Jeff. So, , I've got a really cool one. Anytime I say it's really interesting or really cool, , it's definitely pushing the boundary up like oh. [00:14:00] Now what, what, what does Sarah have today?

Geoff Scott I get excited.

Sarah Stapp: He does actually he's, he's like, Ooh,

Joe Casali I, I kind of wanna set you guys against each other as far as like a debate goes. , but I have a question. I have a couple, I, I, I have lots of questions. ,

Sarah Stapp: fire away.

Joe Casali them because I fi I forget them. As you think of the, what you just said, you said, , prohibited list are you seeing this year, especially with the new administration?

. Th that morphing at all because I, I know I watched a, and I continue to see news, but I watched a debate, , by senators grilling regulators on Why aren't you letting, , digital asset companies bank, you are prohibiting them from participating in the banking system and they went off. So are you seeing that line move at all?

Is, is that changing?[00:15:00] 

Geoff Scott Yeah, I don't think we could both answer, but, , I, I wanted to point out my background. Is gray and Sarah has guitars like this. I'm just not helping the, the perspective of compliance. , but yeah, so, , to answer your question, I'd say yeah, definitely was crypto with, , digital assets. . The perception is a little bit better now.

I was at a crypto company and I have some crypto myself, so like me, myself, and my, my views are, are, have been a little more open to it, but like, yeah, banks that wouldn't talk about it are now talking about it. , all these companies that are talking about a dollar backed coin, who never would've probably entertained it before.

Some, some who would've, but a lot, a lot would, would never have. It's definitely there. There's some things where like, I'd like to see more movement, , cannabis, like there, there's just, there's still a lack of clarity federally, and meanwhile you have like new markets like that pushing to get some, , [00:16:00] attention locally.

So that still hasn't been solved, but now there's other similar, , products, if you will, that are looking to get the same attention. , yeah, I know, I know I'm missing one other out there too, but, well, yeah, there, there is, , an interesting. Area, especially that that affects us, the whole state versus federal in gaming.

, that, that has been a really interesting one to watch because generally I view the Trp administration as like more state's rights, , but sometimes the federal regulator that might make business easier. So it's not really that, that clear. , and the line may be moving there about like what's gonna happen with states versus federal.

, I don't know. But things are changing to, to your answer, to your question.

Sarah Stapp: Yeah, I was actually gonna say something along the same lines that, like this administration has been so, , heavy on states rights, on so many topics, , but in, in our world, in payments land. I think particularly with [00:17:00] crypto, I think it's a combination of, obviously there's interest of a lot of people that have a lot of money in crypto or want it to do things, but all, so, you know, and we've seen that in other countries as well, where the central banks are, are supporting it.

So I think it makes sense regardless of who the administration, you know, it is whoever is in power like. We as a country kind of need to get on board, right? That's the way that things are moving. Almost everybody I know has crypto. Even my granny is like, was asking me how she gets Bitcoin and I was like.

Why do you want Bitcoin? 'cause I was afraid that there was like some scam that she was trying to, I was like, granny, is somebody asking you to send you Bitcoin because you should not send anybody Bitcoin? She's like, no, no, no. I'm doing it as an investment. She's like, I'm buying, she's, she's buying, she's buying crypto for my kids.

So as, as an, it is super cute, but then like, she didn't know how to do it. Right. Of course. Like it's, it's very complicated for people who don't understand, you know, it's even for people like us, [00:18:00] I think, in payments who understand all these bits and pieces and bobs are like. It's scary sending money, you know, like, is it gonna go there?

Is it gonna get where it is? So, , I'm actually very interested in what's going to happen in the next few years, but I know five years ago, you know, we, like crypto was a no-no word. Like that was you, you did not talk about crypto, especially to the banks. Oh my God. Like, and then they would go wishy-washy.

They'd be like, okay, we'll accept some crypto. And then no, nevermind. We're not doing crypto. Okay. We're kind of doing crypto again. We're dipping our toes. But now I think with the, with this administration, everybody feels like they can go whole hog and like to your point with these. Senators that were grilling people's, they would not have been grilling people three years ago.

They would've been, why are we talking about this? Like, this is, this is fake, fake real. This isn't all of that. But I think the infrastructure being built out, I think the, , you know, people are getting more used to it and having it backed with the staple coin, , [00:19:00] like a lot of pieces are falling into place.

So I'm, I'm really excited about it, especially for us for Pay by Bank is a great use case.

Joe Casali Excellent. My, my next debate question, , so we have a FinTech initiative going on. We're working with fintechs and, and really, , trying to get them to partner with banks and, and all of that. Five years ago, right? If I use your nber five years ago, , regulation was the, the, in my opinion, , fintechs and banks were speaking different languages as far as how, here's how our product works and the bank saying, here's how it's regulated.

Would you agree? And you both have experience with this, has, has that changed? It seems like they're fintechs are much more knowledgeable about regulatory requirements now. Thoughts?

Sarah Stapp: I, I just rely on Joe or Jeff to tell me what the, what, what the regulations are. I just, Jeff, Jeff, Jeff, do I need to care about this? , but no, [00:20:00] I, I, at least in our, in our company, Jeff is always paying attention to the regulations, but. , I think that definitely the lines are much more blurring. Like you said, it, it was kind of like fintechs and banks were like at a dance, and they were like on opposite, you know, like opposite ends of the room.

They were not, no commingling did their, did their happen. , but now I feel like the, the financial institutions are actually like reaching out to fintechs and saying. Hey, let's work together. We, you guys do your thing really well. We do our thing really well, and I feel like it's because fintechs have tried to get into the regulatory game and different companies have had different levels of, of success or not, as we've seen in some implosions, , you know, some pretty big, , stories in the past.

, but I do still think that fintechs are never going to be as, . As good as at at regulatory things [00:21:00] as, as, , banks are. But banks are also a lot slower and we can, as a fin, like as Arrow pay, as a FinTech, we can provide that layer and that speed that they just can't get to. So I am actually really excited about us, like actually working together as opposed to being like, what is it the Jets and the Sharks on?

Was that West Side story, right? Like different gangs.

Joe Casali Yeah.

Sarah Stapp: What do you

Joe Casali break into song now. Yes.

Sarah Stapp: I dunno. Jeff, can you sing? ,

Joe Casali , Jeff, you coming from Yeah. Coming from that background. Thoughts on, , have you seen an evolution or, or, you know, were you always, you know, we were always compliant.

Geoff Scott , I, I think the, the pressure's definitely been on more like that first kind of tranche of fintechs and I, I wasn't in it, but my observation, I was, I was actually, so I was at GE Capital Bank. We got, we got sold to Marcus, but we were a little different 'cause we were, we had, , , a Utah, , industrial [00:22:00] loan charter.

So that was a bit of a different situation. But like the earlier days, I think some of 'em, the, the vole was there. They went and talked to a bank and the money was happening so quick, was coming so quickly and the revenue was going up that, , I think some people were caught off guard. And then like, as far as the regulatory side, like when I look at like third party risk guidance, it wasn't really designed for, like there's this whole new thing.

That's like an appendage to the bank that brings in customers. And it just, it just didn't really like, oh wow. The bank's gonna have like a child, like, that's not a subsidiary, but it's like, it's here. , so I, I don't think the setup was really there, even though like if you were looking ahead, you could see where this should go.

Like, well, they're giving us depository, , FDIC insurance. , they're giving us a little bit of a, a, , not, not a shield, but like awareness with their. Bank name being here so the customers can feel [00:23:00] safer. , so we should give the cu the consers customers, whatever the same safeguards that the bank would.

, you know, I think, I think the smart fintechs probably saw that coming down the line and I don't know, fi five or so years ago, as I feel like was more the heyday of this. Like there was, we were kind of peak there and then. At some point, there's almost like how much opportunity is there here in some of these spaces, especially Neobank, when at the end of the day it's checking and savings and like how much different is it really aside from, , the skin?

And then you have this whole risk thing where there's people over here doing, having a lot more freedom because there aren't quarterly continuous supervision audits of every kind. , and then you have the bank who's like a little bit shielding from, from all of that. So that I think caught up. , long way of saying like, yes, I think there's more compliance knowledge in fintechs now.

, definitely depends on the type of FinTech [00:24:00] too.

Joe Casali Hmm. Excellent. , this is great because as you guys speak, I just keep thinking of new topics, so this is great. , you mentioned earlier, , synapse, and, you know, synapse is, is, , you know, one story. , there's been other blips along the way. Can you, , , Jeff just give a, the short version of what happened with Sin Synapse and what have you, what's changed since.

Geoff Scott , yeah, short version. So there, they were kind of the core providers sitting between, . X and a bank. So in, in theory, bank and FinTech are relying on them, or no one really knows who is keeping track of where the money is, how much money has moved in or out. , and along the way, some or all these parties lost, lost track of how much money should have been in, in which accounts.[00:25:00] 

, so that's, that's the short version. And then, . There was one or two bank failures and then there was contagion. 'cause people started to get their money out when they heard of concerns. And now you're, you're tipping into the FDIC fund that I think people, , were hoping wouldn't happen because, well, you have these insured accounts and there's a ING system and we know how much money went, but really they didn't.

, and you know, I, no, no offense to anyone involved in this stuff, but, , once I think you're actually like taking from the depository insurance fund. Now everyone's eyes are open, you know, customers are losing life savings. So yeah, not even just forget the government fund, like you've lost your future, , because you thought you had insurance, but really you didn't.

So now, now the scrutiny's much higher. I mean, that's, that's the biggest reaction I think is at least in places where you're telling people you should be able to trust that your money's safe. , like, we're gonna really, really look at you.[00:26:00] 

Joe Casali Sarah, anything.

Sarah Stapp: No. Yeah, I, I couldn't have said it better myself.

Joe Casali Oh,

Sarah Stapp: the first time. For the first time, yeah. Jeff

Joe Casali Jeff. Point for Jeff just saying,

Geoff Scott How do we get these points? I don't know if I trust this system.

Sarah Stapp: It's like, whose line is it? Anyways, the points don't matter,

Joe Casali The points don't matter. Yes. , exactly right. , trends. Sarah's gonna win. I'm sorry, but, , , trends, the, , trends. What are you seeing for trends? Are there, , you know, , how do you stay, , up to date on compliance? How do you stay up to date on, you know, the, the, I think.

Back, you know, 20 years ago there weren't as many payment options. There just wasn't. And today there are so many payment options. , you know, some of the pa, some of the payment options. I, I'm a big faster payments guy and I understand the value of a [00:27:00] faster payments is. The settlement is immediate and, and, , it's good.

It limits counterparty risk. Awesome. As a conser. Venmo's super fast cash app super fast. So, , how do you, how do you stay ahead of, you know, , from a regulatory perspective and compliance and from a, but there's all these other options. Whoever wants to go first.

Sarah Stapp: I have a little bit to say and then I wanna hear what Jeff has to say. But I think just from my perspective of just pure payments nerdiness, I think it's, , it's, it's very fascinating. , and it kind of comes back to a lot of things we were talking about, like fintechs and banks and things that are changing and speed and all that. Things are, you're able to stand things up so much more quickly, , as, as a new company, right? You've got these, like banking as a service, like bass, you know, offerings, , that are available. So a, a startup can actually [00:28:00] grow and do things pretty quickly. , innovation is happening. I mean, we, like AI is a whole nother topic that we don't have time for today, but it's been accelerating so many things in our industry and everywhere across the world.

It's, it was already hard to keep up with that. , well, I almost said a bad word. ,

Joe Casali Edit.

Sarah Stapp: was a close one. , it would've been a negative point. , but there's so many things, like things are moving faster and faster and faster. And to be fair to the banks, it's like, it's hard to keep up with all that to the regulators and the compliance teams.

It's hard. It's becoming harder and harder and harder to do that. Fintechs don't have as much of that scrutiny that Jeff was talking about. So we're moving faster and faster and faster and faster as a, as a group. And the banks are trying to keep up right with all of that. So it's very challenging. My, my short story long answer is like, it's very challenging and there's so much information out there.

, the only way to really know what's going on is to read the really, really like dry, boring abstracts, [00:29:00] , to really know what's going on and, and understanding what is actually written in these, , changes like in the code in these things as opposed to. Somebody on LinkedIn or somebody, you know, it's like hot take on something, you know, it's not my job, thankfully.

That's Jeff's job to read all that stuff and then tell me what's important. , but, , so he's much better equipped to answer the, the details of this. But what I'm seeing at a high level is just everything is moving so much more quickly that it's, it's just becoming really challenging to keep up with everything, especially in the us especially with it when it's like state by state when you're talking about things that are not federally regulated.

, like gaming, like cannabis, like, , or things that have like geofencing elements, like prescriptions and things like that. But, , Jeff, what do you, what's your thoughts on that?

Geoff Scott , yeah, a lot. I mean, like, so you giving me credit for looking at trends now? Maybe some compliance rule changes for sure. But I actually, I, I've literally asked Sarah, like, what do you. [00:30:00] Seeing. So sometimes that's all I do is

Sarah Stapp: I'm boots on the ground, you know.

Geoff Scott Yeah, yeah. Just ask her, Hey, what's up? , I mean, I, I, I follow things that are probably a little bit after some of the commercial trends.

I mean, I'm on FDIC alerts and fed alerts, OCC, , but I, and then I also have like custom Google alerts, like looking for state gambling, law changes, , privacy law changes. So like I have a lot of. Feeds coming in, and then sometimes I'm on LinkedIn and we have an internal, like industry news Slack channel where people post articles.

So I, I'm just trying to spend a half hour or an hour every day just reading a little bit of this. I mean, that's, that's trends for me. But yeah, Sarah mentioned, , like, so like new things coming on to give you a flavor of me and maybe the average compliance person. When chat GPT came out, all my friends were trying to see like the most ridiculous story they could write while I was still reading like their privacy policy, you know, and like, and I, and I actually read it before I [00:31:00] signed up and it was like, there was no protection over my email or phone nber or name, like, and I was like, I'm not signing up with this.

Like, no, thank you.

Joe Casali So interesting. So, right.

Sarah Stapp: if we, , if, if, , this whole payments thing doesn't work out, we can, , we can come up with an a, we can use AI to, to bring together payments, compliance, news, news feeds for, for the industry if that's what we can do.

Geoff Scott Yeah,

Joe Casali Easy peasy. Do that in an afternoon.

Sarah Stapp: Yeah.

Joe Casali , I, you know, this may be an unfair question, so feel free not to answer it. , stable coins coming along. Right. And it's, it's a, right now it's a past law and it's been signed and the plan is to have the states regulated and IT and audit it. And one of the things I've always thought is the, you know, FFIC guidance.

It's be, it's [00:32:00] behind, it's, it's, , I don't, I don't wanna, I don't wanna sound like that. It's behind. And, , you know, , if you look at the emerging payments, If you look at the emerging payments in the FFIC retail payments, guidance, it's webs and tells, and I'm like, that's not emerging. So any thoughts on how do the, even the regulators keep up with how fast things are changing?

And I don't know if that's not a fair question. Don't, don't, don't answer.

Geoff Scott No, that's so true. I, I, I think the, the last, I haven't looked at it a little bit, but, but a high risk business was considered internet banking. Like, I gotta go check if that's still in there, but I was like, that's everything. It's like, what? So, . Yeah, good, good question. How, how do the regulators keep up?

, I, I can tell you the, like, the fact we had like a little, , a conference thing. So like at Chicago, examiners would come from across the country and you'd hopefully have someone who knows what they're talking about speak on [00:33:00] a certain topic. So there's a little bit of like this internal professional training that people can do.

, I think the reality is what most of that learn, where most of that learning happens is them getting on site and seeing it. Like a lot of, a lot of folks, , would go the examination path. Like they might have started in accounting or finance and so, and they haven't like, played operationally with some of these things.

As far as it's gonna, as far as the learning, I think, I think it'll be behind, I think, , I think you're right. And then, , depending on how funding plays out, like I generally don't view the state regulators as having the same funding as federal. , so they're gonna be a little bit handicapped there. I mean, some states are gonna do better than others.

, but how they can, how they can get ahead. There's the same stuff the rest of us have access to is get certified, , go talk to people. It's just a little harder when you're in that situation. 'cause you can't, you can't say, I [00:34:00] approve this, or I, I'm gonna give you, , my view as the state or federal regulator that like this is, okay.

So I, I, I don't know if that's answering your question as much, but. But yeah, I think, I think this would be hard, , hard to figure out from there. End.

Sarah Stapp: Yeah, I think you're like, there has to be, , I mean it, similar situation, , now it's a little dated, but, you know, 7, 6, 7 years ago when I was still at, , Braintree, PayPal, one of the projects was to open up some of these high risk industries. And one of those industries was, , games of skill, games of chance, right.

, which included like the fantasy sports betting and the, you know, all of those types of things, sweepstakes and all of that. And the answer from our banks was, no, no, no. For two years I was told, no, no, no. And then we just kept coming back with like, let me educate you, let me explain to you what's actually happening.

And this is why we are okay with this. This is why we or our compliance teams are okay [00:35:00] with it. , but they kept listening. Even though they were saying no, we got told no, no, no, several times. And it actually, we got a, okay, maybe let's try it with one. Right? And then we got like conditional approval. And some merchant and some PSP processor has to blaze the trail for everyone else to, you know, clear the path for everybody.

Somebody has to do the hard work and, you know, take the. The, , you know, the path untrodden and, , and clear the way for everybody else. , and it, to Jeff's point, they have to understand everything. They really have to get in there and like get in the thick of things and understand how everything works.

And then when they do, it's like, oh. Okay. It's not as scary as I thought it was, but I think, you know, if you're not edu specifically on like crypto for example, you know, most people I talk to that aren't in the industry, I talk about crypto. They're like, oh, like Bitcoin. I'm like, okay, well that's one token.

, or one cryptocurrency. . It's not backed [00:36:00] by, you know, it's not pegged to a fiat currency. It is like how, like how many cryptocurrencies do you think there are? Like, I don't know, PayPal has like four and I was like, just go look. Just go see how many there are. Like you can make new ones all the time.

Right? So I think really getting good about using the right terminology with compliance, no offense, Jeff, , is , is you really have to pick your words correctly. Like you don't say crypto, you say stable coin. , you know, something like that just to give that. It's infinite risk concentrated com, like putting the risk into a box that can be quantified.

I think if I can give that to a compliance person or a regulator, it's much easier for them to say yes as opposed to no. , so that's unfortunately for whoever that first merchant is, that's blazing the trail. , that, that's really I think how that's gonna. That's the way it's gonna be. I'm a little nervous about the states though, , versus federal.

I just feel like it would be a lot smoother rollout if it were federal, but nobody asked [00:37:00] me, so, you know.

Joe Casali What

Sarah Stapp: Yeah. No, no, not yet. That's, that's next year. Yeah.

Joe Casali Next year. Excellent. So I, I guess my, my final question really isn't a question. It's kind of an idea. , and then, you know, we can, we can go into to the final argent of why compliance is more important to sales or sales is more important to compliance. The final topic is, is kind of what you just mentioned, , innovation.

As you think about innovation, that gaming, that gaming area. They, they, they're so good at what they do. I mean, , I, from what I understand, you can cash out. You can cash in. It all works seamlessly. , all the, the, the people who use it are happy, well, not happy, happy that they can deposit or withdraw money.

Not, maybe not otherwise happy, but, , any, yeah, any, I mean, and. It's like a [00:38:00] use case. Like that really pushes the, the systems to, to innovate. I, I think pay by bank, if, you know, I think that's an innovation. Any thoughts on innovation and, and how it plays into your area?

Sarah Stapp: Yeah, I think from my perspective, I mean, I got there first, Jeff Shush. , the, , but I, what I would say is, you know, I think the gaming being a great example where it, whether you're talking about gaming or any other area of innovation in payments innovation, anyways, . It all starts with us as the conser, right?

No matter, we're a pay by bank provider. Our customers are merchants, right? You would think, but actually our customers are also consers because they're part of our ecosystem and they're the ones that are driving it, right? If we're talking about, , you know, all the things that we're talking about, like interchange and things like that, that's all driven by acceptable conser behavior, right?

You can charge [00:39:00] that much. For interchange in the US 'cause everybody wants their points, you know, and merchants are like, well I have to accept it because I need, you know, if I want people to pay me, then I need to pay for these things. , so I think in my view, innovation in our, and payments is always so conser driven.

And that's what I always go back to is like, what are consers? So consers are the one. That pushed for innovation in gaming because they, they were speedy. They wanted, they needed that money in so they could make those, , you really quick bets, right? , and then when you win, guess what? We're a very impatient society.

, I want my money now, , right now, Saturday at 2:00 AM. Dang it. , and, and the system has responded to that over the last, you know, 15, 20 years, the, , with RT P and Fed now and things like that to, to respond to the demand. , so it's very much conser driven. , and merchants obviously wanna make as many, they wanna accept as many payments as possible.

They [00:40:00] wanna keep as many people on the platform. And with all of this competition, , gaming and not gaming, right? Like you have to continue to be, , competitive and keep those table stakes offerings. So it's just constantly like, go, go, go, go, go. , everybody's one

Joe Casali just say table stakes?

Sarah Stapp: I did, it was pun.

Joe Casali extra points for that one.

Geoff Scott Don't give her credit. That was an accident.

Sarah Stapp: I did it on purpose. I was gonna see if you caught it. , but, but yeah, that's, that's kind of my thought. Jeff, anything you'd add to that?

Geoff Scott Yeah. I'll try to play the handout as adults. ,

Sarah Stapp: Oh,

Joe Casali for that one. Look

Geoff Scott hopefully push all my trips to the center table. , no, I. Yeah, innovation's important. , sometimes I was just thinking about it as, as Sarah's talking, I mean, sometimes I'm like, I don't want it, I don't want change. I just want to be like an an old guy in the corner and I want to keep doing things the same way.

[00:41:00] , but then I get bored and when I'm bored, . Trouble happens, you know, I just start to like, press at the system and, and just try to change things that shouldn't be changed. But meanwhile, I need to, I need to accept the innovation and, and change what I'm doing. , it's interesting though 'cause like, I feel like compliance, we have to innovate every day.

, and really over the, the past like 10 years, especially when I, when I first started, maybe this was just me, I was like, I'm gonna be in my ivory tower. Here's, here's a roughly improved, understandable version of what the law says. And then a few years after that, it's like I'm in the trenches with you.

, I'm interpreting it and telling you roughly what I think you should do. And then you're telling me I'm completely wrong. And hopefully somewhere in the middle we get to a solution that solves the, the rule, the prohibition, whatever it is. And now it's like I have all these rules and I need to figure out how to make, .

An easily digestible version of 'em, so sales can get something through. Just like what [00:42:00] sales was talking, , what Sarah,

Sarah Stapp: I'm sales Sarah. I respond to both.

Geoff Scott , yeah. ,

Sarah Stapp: Thanks,

Geoff Scott actually a sales bot, , more than what she was talking about earlier.

Sarah Stapp: this is ai.

Geoff Scott do I, yes. So like with all these rules and everything and moving fast.

What's the best way for us to process something? I mean, meanwhile we're getting the lowest resources, so like innovation, compliance is, is a lot more important than you would think it is just on the surface. , I'd also say like, I wish there was some constraint to it. Sometimes, like, or, or someone was held like the, the chat GPT coming out and like, you know, the, this privacy policy you can do whatever.

No one was there to like, just, Hey, consers. Like, yeah, it sounds fun to like make a modern fairytale story with like, , with like modern actors. I don't know, but did you read this thing? There's just no one there. And, and I guarantee then I'll get in trouble. And then [00:43:00] generally, like I, AI is just the buzzword, but there's no agreed upon constraints like zero.

It can just, we're just gonna let it do whatever. . So it's my worst fears of Terminator, et cetera, like going on. , but I mean like stable point, like the fact that there's a law coming out is better than what was happening before, which is kinda like we're gonna shove it into, , the MTL area or otherwise just kind of like bare our heads in the sand.

One thing that's interesting that, , , former manager Mike Kirk Meyer, give a little credit. Like the US is really powerful in OFAC and sanctions because transactions have to clear in dollars. So huge voles of the world's money movement clear in US dollars. So if China has their own, you know, China coin and Russia has their own coin and all these guys have their own pin, we, I mean we lose a giant weapon in, , in US [00:44:00] public policy.

So like.

Joe Casali was that. That was, that's a couple of points. That was a nice,

Sarah Stapp: was a good one. Yeah.

Joe Casali Yeah, that was good. ,

Sarah Stapp: you think we'll have that same like with USDC stable coins, that that'll all have to be under that same brella, but still, if they've got their own, they don't need to move it through USD. So it's,

Geoff Scott right.

Sarah Stapp: be an interesting, yeah, that's, that's, I hadn't even thought about that.

Thanks for giving me nightmares, Jeff. , this is,

Geoff Scott Yeah, we just don't wanna be too far behind it, you know, because we're afraid of what it's gonna do. Meanwhile, like you miss. Oh, like US public po you know, international policy, like, oops. Yeah.

Joe Casali exactly right. A any closing statements?

Sarah Stapp: ,

Joe Casali I will tabulate the score.

Sarah Stapp: great like computing. , I would say. You know, obviously I think sales is the best. , but I in sale if, if I don't sell anything, the compliances have, it doesn't have [00:45:00] anything to compliance on, but, there's, there's no applications if I don't sell anything. , but being top of the, you know, the, the front of things is, . Has its own challenges, but it also, I do have like a lot of freedoms that compliance doesn't have. Like I don't have to think about these, you know, , doomsday scenarios like Jeff has to, I just like, how can I make it fit into this box? , as opposed to Jeff trying to make the box fit, whatever I've given to him.

So there's a lot of freedom in, , being able to bring interesting things from a sales perspective, but it is also a challenge trying to not waste time and resources, , as these things are changing so rapidly, like especially when there's state by state changes that are, , you know, up and down all the time and wishy washiness in terms of.

What's the hot flavor of the week and things like that. So I, I definitely would not [00:46:00] want Jeff's job. , I definitely would prefer this job 'cause I would, I would've dark circles under my eyes. , if I, if I had Jeff's job.

Geoff Scott Yeah, I feel

Sarah Stapp: You wanna do sales,

Geoff Scott I don't want to be told. No, no, I mean, like I, I, you have to be told no a lot and I want to be the one saying no. So I just, I just want a little more of the, the power, at least in theory. , and that's why, that's why I'm over here. I'm, I'm just afraid of rejection. , Sarah is all what it comes down to.

But, but no, I mean, I, I think, I think from either side it's a, it's a mindset. , I know me going back seven or eight years, like. Sales is crazy. Like, why do they want to talk to this? Like, whatever

Sarah Stapp: oh, we are crazy. That is, that's still true.

Geoff Scott , but now it's like, well, what, like they're trying to make money for the business. They're, they're trying to hit maybe their quota, like, so that, that's kind of their side. , but now if we get in trouble, what happens to me [00:47:00] and what happens to the company? So like where, where do I meet them? Where they're at.

, and try to, try to do what's needed for, for all of us. So, , I don't know. So, so much of it's a mindset for me.

Joe Casali Hmm. That, that, that's excellent. , you really represented, , compliance really well. . Yeah, really

Sarah Stapp: yeah.

Joe Casali , so, oh, okay. So, so if I tabulate the score, Sarah was leading for a very long time, but Jeff came in at the end with the US currency statement, so it's a

Sarah Stapp: was Oh, that's okay, Jeff. I'll, I'll accept a draw. That was the very good points. And, , now I'm gonna be doing some chat GPT research on, , that nightmare fuel that Jeff gave me. .

Geoff Scott That's good. We're gonna,

Joe Casali real thing. Mm-hmm.

Geoff Scott that was, you know, I don't know. I, I need an independent test.

Sarah Stapp: Yes.

Joe Casali a real thing. All right. Well, thank you for joining me. , if , you guys wanna reach out, , their information will be in the show notes. [00:48:00] , thanks. , what are we gonna do next time? Is, is the, the question to ponder?

Sarah Stapp: Oh, well think about it. We'll, we'll come up with something good, Joe, don't worry.

Joe Casali I love it. Yeah. We'll turn this into a monthly show. Excellent. All right. Thanks. , let me

Sarah Stapp: Joe.