Washington Update

Episode Summary

Wrestling Payments kicks off 2026 with a trip to the Hill. Host Joe Casali sits down with William Sullivan, Associate Managing Director of Government and Industry Relations at Nacha, for a wide-ranging Washington update on the policies shaping the future of payments.

William breaks down the latest twists in open banking rulemaking—including a potential reversal on whether financial institutions can charge for data access—and explains why stablecoin legislation remains gridlocked between banking and crypto interests. He offers a candid look at the political dynamics slowing progress on the Clarity Act, cannabis banking, and check reduction efforts, showing how competing priorities and election-year pressures keep even common-sense reforms stuck in neutral.

Throughout the conversation, William emphasizes that advocacy and engagement aren't optional—payment professionals need to understand these shifts and make their voices heard before the rules are written.

Guest-at-a-Glance

William Sullivan Associate Managing Director, Government & Industry Relations, Nacha Leads Nacha's advocacy and industry relations efforts, delivering actionable insights on ACH network policy, payment regulation, and legislative developments affecting financial institutions. www.nacha.org 

To hear this episode and many more like it, listen here or subscribe to Wrestling Payments on Apple Podcasts, Spotify, or anywhere else you listen to podcasts. For show notes, transcripts, and other resources visit www.wrestlingpayments.com.

Host: Joe Casali, EVP, NEACH #wrestlingpayments #wrestlingpaymentspodcast #paymentspodcast

Transcript

NEACH - Wrestling Payments - William Sullivan

Season 4, Episode 2

[00:00:00] Bill Sullivan: What if everybody can't get paid via direct deposit and all the customers leave in a 24 hour period? What are we gonna do then? we're gonna, we're looking at bank collapsing and they pretty much got it.

[00:00:10] Joe Casali: Welcome in everybody. You are listening to Wrestling Payments, a podcast where we help payment professionals contend with the challenges of modernizing their payments operations, and identifying ways to build for the future. If you are interested in payments, innovation and modernization, you are in the right place now.

[00:00:31] Joe Casali: Let's get into it.

[00:00:34] Joe Casali: Welcome to Wrestling Payments. I'm so excited. One of my favorite people in the world is on the call with us. Bill, do you want to introduce yourself?

[00:00:41] Bill Sullivan: Absolutely. Joe, thank you so much for having me back. This is an honor to be able to speak to your members and those that subscribe to wrestling payments. my name is Bill Sullivan. I lead the government and industry relations, for NACHA and advocating for the ACH  network. it's not quite as exciting as it sounds.

[00:00:59] Bill Sullivan: a lot of it is. As strictly just industry relations and working with the other trade groups and explaining. What we're doing in the rules process, encouraging them to participate and then if something goes through, making sure that our team educates them. but there is a fair amount of Capitol Hill and regulatory work that goes along with that.

[00:01:17] Bill Sullivan: And I am a registered lobbyist, but I really rarely lobby. I usually just advocate and share the news that we were up 5% in payments this year with one less processing day and things like that. And some of the cool things that the membership and the network have done to try to mitigate risk and,

[00:01:33] Bill Sullivan: I'm the mouthpiece, but really it's the 70 people behind me at NACHA that really do all the work. So I tell people I've got the easiest job in payments, but we're not gonna share that outside of this podcast today. But it's absolutely the easiest job in payments. And because we're speaking with NEACH members today mostly, and I'm dog tired from, running around all day.

[00:01:54] Bill Sullivan: This is absolutely sponsored by Duncan. So Duncan is driving this webcast today 'cause I just went before this and got a giant iced tea.

[00:02:03] Joe Casali: Excellent. I will give you the inside scoop. the law Congress has was a mystery until NACHA ran one of their, Capitol Hill days. And I got to see Bill in action. And it really is just sharing information. not out there pounding the desk and demanding changes in Congress.

[00:02:19] Joe Casali: It really is, Hey, this is how the Aach h works. This is how different things affect, what you're talking about right now. it's really good. Bill always gives us some insights. So with that, I gotta go on another one of those. I keep, something keeps overlapping so I keep missing it. what is the hottest thing on your topic today?

[00:02:40] Bill Sullivan: Okay, there, there are a lot of hot things going on right now. I think the one that I'll lead with is, a regulatory action. Because we heard something yesterday that was a complete about face from what we were told, in mid-December, and that's 1033, the open access to data. just two days ago in front of a group of about a hundred, I reported out that, CFPB, originally was gonna do what they call an interim final rule.

[00:03:08] Bill Sullivan: And really what an interim final rule is, hey, this is our final rule, until we can think of a way to make it better. and they were gonna issue that before Christmas, but then in a lawsuit about whether or not CFPB could just decline funding and almost try to put themselves outta business. there was a stay that they couldn't put anything out.

[00:03:27] Bill Sullivan: And then on December 30th, a judge ruled that CFPB is not legally allowed to decline their funding. Therefore, they had to continue to be staffed up and to work and. and I shouldn't say work, they were gonna always work, but it was gonna be a skeleton staff and, the government relations advisory group, a group Joe that you know well that you participated in, and actually several members of niche par niche participate in.

[00:03:51] Bill Sullivan: we had Jeff Grabler, who was the, on our call in December, who's the deputy Director of CFPB. And I really truly believe, because of some, some issues with the current directors, also the head of OMB that. Mr. Grabler, Jeff will eventually become the director sometime this year. so he's sitting as deputy director now, I think with the idea that he'll take the reins probably by the fall.

[00:04:16] Bill Sullivan: but Jeff had mentioned that if the lawsuit ruled against them and they had funding and staff that instead of going with an interim final rule, they might pivot and go out with a whole new notice of proposed rulemaking. So basically taking what happened under Chopra and the Biden administration and just starting all over again, which is fine because that's within their legal limits of Dodd-Frank.

[00:04:41] Bill Sullivan: so where we got is we're waiting for this notice of proposed rulemaking. Now, Jeff's said he's a smart dude and he didn't ever promise what was gonna be in there, but he hearkened on two things that I thought were key. One, he said that, he felt that there should be some form of payment for turning over this data, but they didn't necessarily wanna set a going rate.

[00:05:05] Bill Sullivan: They were gonna just encourage the two parties, the requesting party and the party providing the data to work something out. And I think that would be very favorable to financial institutions and something the financial institutions were looking for. He also hearkened or kept pounding on the fact that with the data moving.

[00:05:24] Bill Sullivan: All the security that is responsible for said data moves along with it, because that was another big concern that financial institutions had is how do we know our customer data will be safe? So those were the two things he really harped on. and I'm sure there's other things, but he continually brought those up in the discussion.

[00:05:44] Bill Sullivan: So I reported out two days ago, the, what I've just said, only to find out last night that the new hot rumor in Washington is. That they have done a complete about face, they being CFPB and the administration, and they will basically say there will be no fee for turning over data. Now, none of this is substantiated.

[00:06:07] Bill Sullivan: the White House is very tight lipped on a lot of these things, and often there are rumors out there that just come out of nowhere, but it seems to have a little bit of traction because a gentleman that owns a group. P or that really set up open banking in Europe has been quoted as saying that.

[00:06:26] Bill Sullivan: and there's a GR firm that I believe represents his company that has also been whispering that in the halls of Congress. Now, maybe they're doing that as a smokescreen to try to get CFPB to do but it. It's really gonna be disheartening to financial institutions if this proposed rulemaking comes out and there's no avenue to collect a fee for having to produce data, to a third party when requested.

[00:06:52] Bill Sullivan: so that is the hot off the press. I don't quite know what to make of it yet. I have calls in, but I doubt I'm gonna find anything out. I reached out to a career staffer at CFPB that was not let go. when they laid off most of their workforce. and I've not reached out to Jeff yet because I just don't know whether he's gonna tell me, and I don't want to mess a, a good relationship up because he's already agreed to come back and talk with Greg, the government relations advisory group, on several more occasions this year and into next year.

[00:07:24] Bill Sullivan: so we gotta stay tuned on that, but I do believe. If that notice of proposed rulemaking will be out within the next couple weeks. for those of you interested in 1033, something is coming, but it's gonna be starting over from scratch. In all likelihood, it'll be a notice of proposed rulemaking.

[00:07:39] Bill Sullivan: NACHA will absolutely comment on it. I'm sure all the banks will. And, if all the banks and credit unions are in lockstep on answers, they might even go in together and collectively submit one comment letter. that's very kind of generic and really at a high level. And that each one of them will submit their own individual comment level that dives deeper into their members' issues.

[00:08:00] Bill Sullivan: and if they do, depending on what the letter says, NACHA might sign off on it as well. 'cause often we join all the credit union and banking trades on their letters. So that's the hot off the press because all this stuff I found out yesterday and it blew me away.

[00:08:14] Joe Casali: I'm probably doing this out of order, but, to recap the full picture from an amateur's perspective, Dodd-Frank came out over a decade ago, had a provision that included open banking. UK had PSD2, which really opened that up a decade ago. already doing open banking. Okay. After 2020 ish, CFPB actually got down to writing a rule.

[00:08:39] Joe Casali: They got to the end of that process and then the election changed things, and they said, we're not gonna do that, but let's put something else out again and see how that's going. I imagine that ended up being the interim final rule, but now we're at just a new phase of that. Correct.

[00:08:57] Bill Sullivan: Exactly. 'cause the interim final rule was actually never issued because they had to let this funding order stay and then they just buried it. yeah. And what it was, is the Biden rule came out within and. I never quite remember this. I think it's within 90 days of an election, any rule that comes out, 90 congressional working days.

[00:09:14] Bill Sullivan: So that goes back to August, of an election. the new Congress coming in and the new president can, if they all agree, can do the Congressional Review Act, which basically strips that regulation. from being enacted or promulgated. And in this case, that's what happened with 1033 because the Republican administration and, the Republican leaders in the House and Senate wanted to take a fresh look at it.

[00:09:39] Bill Sullivan: So that's where we're at. I might as well go ahead and say it. and I, again do have no idea whether there's any validity to this or not. Part of that rumor or two was that President Trump is currently suing. JP Morgan over some de banking stuff, and I know we're gonna touch on de banking here in a minute or two.

[00:09:58] Bill Sullivan: and he knew this is a. a pet project of banks the size of JP Morgan and things along those lines, meaning making sure that they're reimbursed for the data and that's been attributed to some of this. I have no idea if that's true or not, and I don't even, I even hesitate to say it.

[00:10:17] Bill Sullivan: But we do know that sometimes where there's smoke, there's fire. And it might may not be about JP Morgan, it may just be that, they've decided they don't wanna charge fees for whatever reason. whether it's large donors have gotten to them or there's some very sensible reason that Jeff Grabler didn't mention and a call in mid-December.

[00:10:38] Joe Casali: Super interesting. I, and one more comment before we move on. you mentioned Jeff, I think you alluded to him as a really smart guy. One of the observations from the Capitol Hill Day, whether, I don't know what your politics are, but the staffers of these politicians are smart. They're super smart. it's impressively smart how these people, you ask them a question and they.

[00:11:01] Joe Casali: Just go and explain all the nuances, all the interrelations. There are a lot of smart people in Washington, including Bill,

[00:11:09] Bill Sullivan: I don't know actually. I don't know about that. But, and yeah, and on the last Capitol Hill Day, we actually did a little something different, where we started the day meeting with folks at Treasury because the president had just put out the executive order. To eliminate checks and they were happy to meet with us and by folks at treasury, political appointees, so some really big wigs and a really big fancy conference room where you had to go through layers of security to get in and talk with them.

[00:11:32] Bill Sullivan: But they met with our whole group, and it was a very productive meeting, and those guys were sharp as attack, but they absolutely loved the feedback of people that actually are on the operations side of a CH. Representing members or large financial institutions or credit unions, and it was a great experience for the members that attended Capitol Hill Day to start the day off at Treasury.

[00:11:53] Joe Casali: Excellent. that's awesome. I will, I'm definitely gonna get to the, this year's one. It's great. one of the things we talked about earlier is, you wanted to touch on the Clarity Act and what, where the status of that is.

[00:12:04] Bill Sullivan: Yeah, I know we get a lot of questions about clarity. even from our own internal staff at NACHA, as I think folks probably on the call are aware, the Genius Act pac it, passed in July. that allowed the pathway for stable coins. And I am no stable coin expert by any stretch. Joe could run circles around me on it, but the politics of those, of that act and then leading to clarity or this, the crypto industry.

[00:12:29] Bill Sullivan: Really supported Trump hard in the election and supported him with gobs of money. So this was the olive branch to the industry saying, you all supported me. I'm gonna support you. This will be a priority. So after, it takes a while when a new administration comes in to get things done.

[00:12:47] Bill Sullivan: So it, it missed its mark by a couple months getting passed. But it was a pet project of the president. Lot of pressure on the Republican party. To get something passed. They worked with the Democrats. They banged out the Genius Bill. And part of the genius Bill though was how is the regulatory structure gonna be set up?

[00:13:05] Bill Sullivan: And they couldn't come to a full agreement then. So instead of having two pieces of legislation passed simultaneously. They passed genius. So Donald Trump could go back to the folks that supported him so heavily and tip his cap saying, Hey, we've done the first part of this, now we've gotta work on the regulatory stuff.

[00:13:22] Bill Sullivan: And originally all the press around it was, oh, the regulatory stuff. just two months or so, it'll fall into place. it hasn't fallen into place yet. And the big sticking point right now is the, crypto world. Supporting Clarity wants to be able to have interest and rewards attached to those stable coin accounts and payments, and the banking world absolutely opposes it.

[00:13:50] Bill Sullivan: And even on the Republican side, there's a little bit of disagreement on which direction they should go. So it's not only a Republican Democrat thing, it's a small faction of the Republican party pushing back on some things as well. Tim Scott, who is the chairman of the Senate Banking Committee, has really done a good job trying to hammer something out, but also hammering something out, not in the press.

[00:14:16] Bill Sullivan: when it appeared as if there was going to be a draft bill that, again, they kept under wraps. I even heard that the lawyers representing the different congressional offices. And anybody voting on it In the Senate Banking Committee, you had to come into a room in the Senate Banking Committee and you couldn't leave with the document.

[00:14:37] Bill Sullivan: You could review the document. You had to leave your cam, your phone, and your camera outside of the room, and you could review the document so nobody could get their hands on it before it went to get marked up. But This is Washington and people find out everything. And when Word got out right before, I think it was Jan, January 15th was the markup date, but whatever, mid-January, right before all that went down, the reward stuff came out and there was some language in the bill that was concerning.

[00:15:04] Bill Sullivan: So the ABA and the Community Bankers of America. Put together an amazingly quick reaction grassroots campaign to contact everybody on the Senate Banking Committee and express their, anger towards this and their frustrations. And, then the CEO of Coinbase, who was heavily in favor of the rewards and interest.

[00:15:27] Bill Sullivan: He pulled his support from the bill the night before. The banks pulled all their support the night before, and, Senator Scott, chairman Scott, of the Senate Banking Committee had to cancel the markup. and that markup originally was intended to. Okay. We've talked quietly, we've negotiated. This is what we're gonna do and we're gonna vote for it in committee.

[00:15:48] Bill Sullivan: And usually if something gets voted favorably in committee, the Senate votes for it because they're like, Hey, the experts are on the committee. They feel this is a good bill. We're gonna vote for it. Now, it wouldn't have been the same as the house version anyway, so they still would've had to go back to the house and negotiate some fine points.

[00:16:04] Bill Sullivan: But they had to pull the markup and. There's a lot of things going on right now, for those watching later. Today is January 30th and we're staring at a government shutdown now, albeit I think they're gonna find, get it resolved over the weekend or so, but that's taking priority. There's a housing bill that's taking priority now, so it's losing some of its momentum.

[00:16:25] Bill Sullivan: Because of other things on the legislative calendar that have been put on hold to get this done and it's not getting done. So the administration's getting very frustrated. They're putting a lot of pressure on the Republicans to do whatever it takes to get something done. And I've even been told that the president not only has shown frustration with the financial institutions that he's met with CEOs mostly.

[00:16:50] Bill Sullivan: But also with the crypto industry saying, you're getting something, you can't get everything, work it out. and that's very common for a president to try to get involved on something that's close to the finish line, but not there. I was not at the clearing house, big conference in the fourth quarter.

[00:17:06] Bill Sullivan: what I understand is that former House Financial Services Committee. Chairman, oh my God, from North Carolina, and I just pulled a blank. But anyway, he retired and, he, Patrick McHenry, sorry. Congressman McHenry retired, didn't run for reelection, so he is no longer in the house. So he is not the chairman of the House Financial Services Committee.

[00:17:25] Bill Sullivan: He, he's a FinTech crypto whiz. he was by far the smartest member on the hill on this. I guess he had a keynote address or an address of some sort at TCH and he actually said, Hey, I don't see this getting done until around Easter and it looks like he's right. even though the whole industry was saying, oh no, this will be done, if not before Christmas, it'll be done shortly, into the new year.

[00:17:46] Bill Sullivan: This is gonna be a done deal. it's not. And, The FIS and the crypto world are arguing in the halls of Congress almost as badly as it was with credit card interest rates and everything between the banks and the retailers years ago. And if you ever walked into a meeting on the hill, the staff would say, oh, thank God.

[00:18:05] Bill Sullivan: I'll be happy to meet with you. just don't wanna hear anything more about credit cards. if you're talking aach H let's talk for hours so I don't have to talk about credit cards. but we're getting to that boiling point now. So I do think something will get resolved. because again, this is a major project for the White House, but we're not as close as people think right now.

[00:18:22] Bill Sullivan: So we'll see what happens after some of these other more important bills at the moment. Takes shape. And then the only other thing to keep in mind is Tim Scott is he's, first of all, he's super well regarded within the Republican party. He was the nominee for president, this last. time and, Trump eventually took the nomination and became president, but, he is the chairman of the group that is raising the money for senate republicans reelection campaign for the midterms coming up in November.

[00:18:53] Bill Sullivan: So it's a highly coveted, very respected job. It's usually a stepping stone to being really well regarded in your party. and they ask him to do it this year. So think about this for a minute. This whole stable coin thing is Trump's pet project. They've got one more bill to set up the regulatory structure, largely giving it to the commodities, future trading commission to oversee, and he's negotiating with Democrats on the Senate Banking Committee.

[00:19:19] Bill Sullivan: And those Democrats are going like, why are we gonna hand you a victory that you can raise money off of? For all your Senate colleagues to run against our Democrat colleagues when we want control of the Senate because we're tired of being pushed around by the Republican party. So the closer we get to that reelection, the harder it's gonna be for Scott to get anyone to sit down at the table and talk.

[00:19:41] Bill Sullivan: So I think, I actually think what McHenry said about Easter was spot on because by about mid-June, late June. Congress stops and it just gets straight into, we gotta worry about the midterms. And this midterm is so contentious just because of the faction of the country and the people and the Democratic party that just do not like the president and the direction the country's going in.

[00:20:06] Bill Sullivan: So they really wanna win the House and the Senate so they can stop a lot of these actions. so Scott's really got his hands full right now, and I'm sure he probably r the day that he agreed to take over all the Senate fundraising for all these candidates that are running for reelection. come November,

[00:20:24] Joe Casali: It's super interesting. I did write down Easter right before you said it just now. again, my take on this, the genius that came in very contained, right? Very, they're working on the structure of it now. States are gonna regulate or maybe the fed, but it's very, who can issue it? How is it gonna be used?

[00:20:43] Joe Casali: Very structured. The crypto world with this clarity act, the crypto world, it, traditional banking, we un I understand right? I understand how it works. I understand what, fractional banking and where all the incentives are. Crypto developed alongside it, it developed its own loans, staking ways to make money, all of that.

[00:21:08] Joe Casali: Trying to bring those together seems monumental. Which, gonna be a lot of growing pains, I think. gonna be interesting to see how it works out, but I guess we'll wait till Easter for an update on any of that.

[00:21:19] Bill Sullivan: Absolutely. And the one thing too, and Joe, you may remember the name of it, I think didn't Facebook try to launch some sort of payment application or something

[00:21:27] Joe Casali: was it Lira or, yes. They tried it at their own currency.

[00:21:33] Bill Sullivan: Yeah. And there was a hearing on the Hill and the thing that was fascinating to me, and again, getting back to your crypto and traditional banking and the ways they develop things. And in the hearing, in the Facebook world and the tech world, you, you do things and you see what sticks.

[00:21:48] Bill Sullivan: And if something screws up, you start all over again. You reprogram it, you keep going. That's the way they were handling this whole, Facebook money platform or whatever exactly it was. And it came across in a hearing. Like the poor guy was just so unorganized and such an idiot, but it really wasn't the case at all.

[00:22:05] Bill Sullivan: This was a guy that was totally used to trying and failing and trying and failing and then succeeding and then building off of that. And it was just a different way of doing things. But these senators didn't understand that, and it was cringe worthy in the hearing, but it really shouldn't have been because it was just their way of doing things.

[00:22:25] Joe Casali: It's fascinating. I, and I always think of you in that case, not because they're clueless, but because you are educating. you're doing the background. Hey, here's the handout saying, here's the issues with that topic. so I do think of you when they ask the questions like, was my, my, my router connected to the internet?

[00:22:43] Joe Casali: Yes, your route is connected to the internet. different hearing, but I get it.

[00:22:48] Bill Sullivan: in this now, this is becoming Joe and Bill Coffee Hour. If I can tell one more story.

[00:22:51] Joe Casali: It's true.

[00:22:52] Bill Sullivan: I, when Dodd-Frank came about, I actually went to NACHA and said, Hey look, I do have a background in government relations. I think we need to create a department. I think the Aach H is missing out on a lot of advocacy and things, and.

[00:23:04] Bill Sullivan: At the time, the CEO said, go for it, create it, do what you have to do. And it was wonderful that they had that kind of a blind trust. and when I did it, again, we do a lot of advocacy and a lot of it is just like kind of collateral pieces that you leave behind about the growth and the success of the network, what we're doing to mitigate fraud, mom and apple pie, the American flag the whole bit.

[00:23:24] Bill Sullivan: shortly after my first like whole big series of hill meetings introducing staff to NACHA and who we are and what we do. We had a little collateral piece with some facts on it. I was watching a hearing and I don't even remember what Congressman, but it was the well here and I'm getting ready to ask a question, holds a piece of paper out.

[00:23:42] Bill Sullivan: Says, theACH  network, which processes eight, some gazillion billions of payments for X trillions of dollars. What do you think? How do you think this fits into blah, blah, blah? And he was reading our collateral piece and it literally. For me, I wanted to run up and down the hallways at NACHA going we're legitimate.

[00:23:59] Bill Sullivan: We're legitimate because I had no idea. Now since then, here's another inside baseball trick. We, not often, but occasionally we get calls from staffers that know us well and they'll be like, Hey, this is the hearing. Can you write us a couple questions? you're the expert on this. Write us some. So occasionally now we'll do it where we're writing our own questions, but I know those in advance.

[00:24:19] Bill Sullivan: 'cause I was asked by the staffer and this case, they just, somebody had handed their bosses collateral piece and it was in a folder and they decided to run with it. And it was so cool for me. And that was, a good 15 years ago probably. But.

[00:24:32] Joe Casali: Yep. But I still remember, we, I was more active with that. McHenry was in and we met with a, we met with a, someone from Maine. And you were talking about return rates. Yeah.

[00:24:43] Bill Sullivan: Bruce Pollock. When, Bruce was, there's a lot of paper mills in Maine and when I was trying to get Bruce to understand the significance of the, of same dayACH before we came about and got it approved by the Fed, we were already talking about it in Congress. as just a way to a subtle pressure point that Congress is supporting this and we need the Fed to support this and getting it off the ground.

[00:25:04] Bill Sullivan: And I had my CEO at the time, Jan s stepped with me. And, I don't like taking CEOs to Capitol Hill because if they're not doing it on a daily basis, they can get tripped up and things. And I turned to Jan and just said, Jan, I got the closing. I just turned to Bruce and said, okay, Bruce, it's Friday of Labor Day weekend.

[00:25:22] Bill Sullivan: And at that point, I think we were meeting a couple days before the Friday of Labor Day weekend, the big payroll, for the lumber yard. You know it, it collapses. Something doesn't go through and they find out late in the day that, oh my God, nobody's getting paid this three day weekend's coming up. I said, that's where same dayACH comes in.

[00:25:40] Bill Sullivan: He patted my CEO on the back and said, this is brilliant. I love this. And sent us on our way. So instead of all this great conversation of, oh, this is what the network can do and these are the hours and blah, blah, blah, it was just that simple example. A payroll with his constituents on a three day weekend and he sent us on our way.

[00:26:00] Joe Casali: Yeah. That, and that's what I think of you. I always

[00:26:03] Bill Sullivan: Bruce's Bruce was great. Yeah.

[00:26:05] Joe Casali: Yeah. That's awesome. so again, we talked about things before. This one was really interesting to me 'cause, it was, how do you interpret the idea of. De banking or not banking and you had some insights around that.

[00:26:20] Bill Sullivan: Yeah. here's the problem with Deban. The Republican party under the Biden administration felt that they were being, made an example of we're being, set aside and a lot of them were losing bank accounts for a variety of reasons. Now, banks have their reasons for de banking somebody.

[00:26:38] Bill Sullivan: I don't think anybody can tell them who they should or shouldn't bank. I also don't know that there really were that many examples of it. I think it's one of those things that just caught fire brewed up. But that was a big deal during the campaign. And even on inauguration day, the president mentioned it and.

[00:26:56] Bill Sullivan: Immediately con, Congress wants to act, wants to, what are the priorities of the incoming administration? So there was a rush to introduce bills on things that he had mentioned either on the campaign trail or in his inauguration address, or just the days after the inauguration. And there was a 2019 bill that got dusted off and introduced in the House and Senate on Deaking. The bill never, ever saw the light of day. It was poorly written and it actually had a clause in there that if you were found to illegally de bank somebody, your institution can be denied Federal Reserve services to theACH  network. So we find out about that. And needless to say, there was a lot of, running around in the office and a lot of scurrying because the bill never went anywhere.

[00:27:49] Bill Sullivan: In 19, we didn't even know about the bill. Quickly got on the hill, quickly, got in front of House Financial services, got in front of some influential members of Senate Banking Committee. They all assured us, oh my God. No. we're sorry. No. Yeah, we just introduced the bill to, introduced the bill to have a placeholder.

[00:28:04] Bill Sullivan: but you still always wanna make sure, and a lot of it was the point we would make is, if you're gonna deny him access to Fed, does that include Fedwire? Does that include processing checks? What about Fed? Now, they're trying, here, they are trying to grow fed now, and you're denying access.

[00:28:20] Bill Sullivan: And then all you have to do is say, and is this gonna be a Silicon Valley bank situation?

[00:28:24] Bill Sullivan: What if everybody can't get paid via direct deposit and all the customers leave in a 24 hour period? What are we gonna do then? we're gonna, we're looking at bank collapsing and they pretty much got it.

[00:28:34] Bill Sullivan: And, even though the Senate bill still sits out there somewhere, no one's acting on it. this is also where. We are really fortunate because when Congressman McHenry, retired, and again, he was the FinTech guru, supportive of the things we do, but really was more of a fintechy guy.

[00:28:53] Bill Sullivan: the New House Financial Services Committee chairman is French Hill, representative Hill from Arkansas. I would say of the 535 elected members in Congress, a hundred senators, 4 35 congressmen and women. French Hill understands theACH  network as good as, or better than anybody else. And he's also the biggest cheerleader of the Aach H network.

[00:29:15] Bill Sullivan: So having French run the House Financial Services Committee, where that is the one thing, 'cause again,ACH isn't sexy. I'm not, we're not, we don't have a pack, we're not donating money to candidates. But that is the office that I can call anybody in that office and almost get an immediate return call.

[00:29:33] Bill Sullivan: so Hill's staff was like, yeah, this is never going anywhere. Don't worry about it. we got you. don't worry about it. But even a little story about Congressman Hill was he actually wrote a letter, he wrote the letter before the NSS. Expansion rule came out a couple years ago from the Fed at the time, just urging the Fed to act and that theACH  network, particularly same day a CH, was very important to the economy and to, everybody it serves, whether it's the government, whether it's corporates, or whether it's the citizens.

[00:30:07] Bill Sullivan: and a really nice kind of positive,ACH  letter, right about the time they were gonna send it to Chairman Powell. the rulemaking came out, but instead of just burying the letter, like U usually happens, they actually redrafted it to think. Chairman Powell for doing this, but also to encouraging them to seek ways to make sure that theACH  network continues to be able to thrive in this environment because of the ubiquity of the network, and the rules around it that are gardened by the private sector NACHA, but they also are very consumer friendly.

[00:30:41] Bill Sullivan: Now, here's the great thing about Chairman Hill. You normally a Republican from Arkansas isn't necessarily gonna be best friends to consumer groups. When they were starting this letter, he reached out to me, he being his staff, and said, can you gimme the connections of some of your consumer groups you deal with?

[00:30:59] Bill Sullivan: I wanna call them and talk to them about how important this is to them. And he actually reached out to consumer groups, had them read the letter to make sure it read, it, read well. And even if you remember, especially during the last administration. Republicans and Democrats weren't talking at all, and even the House and Senate weren't talking very much.

[00:31:18] Bill Sullivan: He actually got signatures from Democrat, senators, Republican senators, and Democrat members of the house on this letter to Powell. So if that isn't just a huge friend of theACH  network, I don't know who is, but

[00:31:32] Joe Casali: Yeah. That's awesome.

[00:31:33] Bill Sullivan: honesty banking thing. So where we're at now is no, they're not gonna take away a CH.

[00:31:38] Bill Sullivan: Quite honestly, I think they realized they really can't make somebody, not de bank someone. But then the Wild Card came out about a week or two ago, that the president is suing JP Morgan because he feels that his corporation was unfairly, Deb banked, and I can't remember the dollar amount, but it's some dollar amount that even Powerball isn't gonna pay out most times.

[00:32:03] Bill Sullivan: It's a huge dollar amount

[00:32:04] Joe Casali: it's a starting point.

[00:32:06] Bill Sullivan: Yeah. and I have no idea where that's gonna go. A lot of people think that court case will drag on into the 2030s. I'm not a lawyer. but that's just made it even more contentious and I don't really think a de banking bill's ever gonna get by because I just don't know what they can put in the bill that would have any teeth at all on something like this.

[00:32:25] Bill Sullivan: But it is something we're watching for because. We didn't even know about that 2019 bill. And I don't even remember who told me when it came out because, there's always a slew of stuff when there's a new administration in there and we're just trying to figure out how to get back on our feet and who we have to call and who we can deal with.

[00:32:40] Bill Sullivan: and somebody called me one day and I was like, you're kidding me. And then they faxed the fact, emailed the letter to me, sent the letter to me in a PDF, the bill, and I was like, oh my God. And we freaked out. But, de banking isn't. Isn't really going anywhere right now. I think also that they know that they Congress, the White House, the powers that be.

[00:33:01] Bill Sullivan: So there've been a couple of kind guidance documents from OCC and FDIC. and there wasn't an executive order from the president that, again, didn't have a lot of teeth to it on de banking, but I'm not really sure if this is going anywhere, but at least we know if it does go somewhere, theACH is not gonna be included at it.

[00:33:19] Bill Sullivan: 'cause if that was, and it went through, I don't think I'd be talking to you today. I'd be unemployed.

[00:33:25] Joe Casali: Yeah. I think it's fascinating. I saw a hearing around it had a bunch of crypto guys up there, implying that it's tough for them to have access to services. I always thought it would be a, an after the fact thing because, sorry, maybe it's naivete, but, I, they do get banking, I figured it'd be a lawsuit saying.

[00:33:46] Joe Casali: You didn't give us banking. it really disrupted our business. I didn't think of, I didn't think of it as a law saying you must bank any company that comes to you in an account. It's whoa, we, whoa.

[00:33:58] Bill Sullivan: And I think it gets back to the whole point where you were saying too, how crypto is a totally different world. And the banking world probably doesn't fully understand the risk model there or things like that. And again, we're getting into operations now and that's whew. But I think there's a lot of truth to the point you made earlier about not understanding it.

[00:34:16] Bill Sullivan: But a lot of these things are, they're ventures. they're, some of 'em are set up to fail or to be bought out or, to, Hey, I came up with this idea, it's really not all that great, but then Joe's gonna take my idea and make it a whole lot better. and I get it where banks don't want to get that get tied up in that stuff,

[00:34:32] Joe Casali: Yeah, we've gone as far in the office here as saying. if you do an analysis and the risk says no, you shouldn't be banking them. How do you say? Yeah, we'll bank 'em. I, we just, that's how far we get. excellent. really interesting topic. oh my secret. My secret topic that, I think I said that the wrong way, but, I keep hearing that.

[00:34:55] Joe Casali: and I think it was Trump said, maybe we'll look at de or not deregulating, but changing how cannabis is identified as a drug.

[00:35:06] Bill Sullivan: Yeah, there is talk that, and ironically the Biden administration had done this, but again, it came out within a certain number of days of the new election. So they stopped it to reschedule cannabis from a cla I believe it's a class one narcotic to a class three narcotic, and it doesn't really add any benefit to the banking industry.

[00:35:26] Bill Sullivan: What it does allow though, is cannabis businesses can now easier get loans they can easily or easier take tax breaks and a couple things that might actually grow the business and make, take a little less pressure off the business. It also, obviously if you're caught with it, you're not, gonna spend 50 years in jail and wherever.

[00:35:45] Bill Sullivan: But, a lot of it I think has to do more with how it would help the cannabis corporates out and those, that run dispensaries. In terms of cannabis banking legislation, it really hasn't seen the light of day yet in this administration. And there are a couple reasons why House Speaker Johnson is adamantly opposed to any cannabis banking and senate banking or senate banking.

[00:36:09] Bill Sullivan: Senate leader, Thune is also not a big fan of cannabis banking, so what's happened is you have the leader of the house and the leader of the Senate. That don't really ever wanna see a vote on this. So it then trickles down. And it's not a priority for French Hill and House Financial Services Committee or Tim Scott and the Senate Banking Committee.

[00:36:29] Bill Sullivan: So if it's not a priority for them, the bill hasn't necessarily been resurrected. It had a lot of bipartisan support, particularly in the house. it is just not going anywhere. And if it does and say somehow it, gets introduced, it gets the support, it passes out of committee. It won't see a vote on the floor of the Senate or the House.

[00:36:47] Bill Sullivan: So I can't even tell you where the president stands on this because it's never really come up because under Thune and Johnson it's not gonna happen. So maybe when, if the midterms shift blew her and the House and Senator controlled by Democrats, they might. Be able to get something through and then force the president to either accept it, which would be a Democrat win if it was their, house and their Senate that got it through.

[00:37:14] Bill Sullivan: or fight it and risk some alienation there. But particularly in an election year, cannabis banking has always been seen as a Democrat thing. I don't think the Republicans would even touch it, even if they wanted to, before midterms. 'cause they don't want to hand the Democrats a victory.

[00:37:30] Joe Casali: Oh yeah. That whole victory thing. That's right. from an apolitical view, we've talked, for many years about. The guidance is around it. If it's official guidance and not guidance. Do you know, and I, and you may not know, so I can just, Mary in our office is a, is an expert. is it still true that some of these, cannabis dispensaries and we have those in Massachusetts, they're making their tax payment with cash, literally having to take cash to city hall and say, here.

[00:38:01] Bill Sullivan: That, that is what I understand. I was fortunate enough years ago PA event that had multi PAs, and it was a really impressive group. It was like two thirds of a day of cannabis banking stuff. And originally I was supposed to be the number two speaker. the keynote was. The treasurer from the state of Washington, and he got hooked up or had trouble with the Zoom call.

[00:38:22] Bill Sullivan: It was during COVID, so they flopped me and I went first until he was ready to go. And then I just introduced him to make it look like that's how it was always planned. But he talked about the receiving tax payments and cash, robberies that have happened on the way to pay, said tax payments or any business tax.

[00:38:40] Bill Sullivan: and some of the problems around that. So I think that's a real problem. and I also, again, can't begin to even explain it, but, the banking across state lines, if you have a kid that mows your lawn and it's your bank and you pay him, but you've got a cannabis customer, you, and, in a state that doesn't allow that, if you pay 'em, is that the money you're paying him with and things like that.

[00:39:04] Bill Sullivan: It's so murky now. I don't think this administration's prosecuting anybody, but they did get rid of the Cole memoranda that the Obama administration had that basically said, we won't prosecute you. and they don't haven't done it, but I don't, I think they're basically abiding by the Cole Memo, but they don't want anything with Obama's name on it, so they got rid of it.

[00:39:23] Bill Sullivan: so that's where we stand with cannabis.

[00:39:25] Joe Casali: Interesting. I am, I'm always interested in, it's the ca it's that cash part. It's the inability to actually use the services that everyone can use, direct deposit cards. And I know there's some spots out there, card providers that interact.

[00:39:39] Joe Casali: But just, the idea of showing up with boxes of cash that smell like marijuana, which is. Weird. So interesting. in our modern world. I think that was all the real hard topics, but any other things going on, regulatory changes.

[00:39:55] Bill Sullivan: Yeah, there, there are a couple regulatory matters and these can be real quick hits, so it won't take a lot of time. and also, I don't know, the folks that are, gonna go back and listen to this podcast, watch this podcast. I don't know how much. Attention. They pay to request for information notices and proposal rule making, whatever.

[00:40:13] Bill Sullivan: So I'll go through quickly. one, the one that really got the industry jazzed up was a request for information that came out of the Fed last spring. And it had a very long comment period. In other words, they knew this is a robust topic and we really want you to take your time. And so many comments.

[00:40:29] Bill Sullivan: Comments we're doing in September. And that was ways to reduce fraud, payment fraud, and. All the trades got together and put letters in. NACHA put a letter in. A lot of our members wrote letters. it's crickets from the Fed on what they're doing with all those letters. Now I know they got a lot and I know there's a lot of detail and they gotta go through 'em.

[00:40:48] Bill Sullivan: I will tell you, we've got a meeting coming up with, fed board payment staff, I think in three or four weeks. I'm gonna ask them then Hey, what's going on with this? I was fortunate enough today to my CEO, myself and Mike Kurt, who oversees our, the network administration part of the A CH.

[00:41:06] Bill Sullivan: for the first time I ever met with Governor Waller this morning. And, I didn't ask him because we had other topics and we only had a half hour, and it was right at the half hour when I unmuted my microphone and I was gonna ask him, 'cause even if he didn't have an answer, I figured he'd put a bug in somebody's ear.

[00:41:22] Bill Sullivan: Hey, NACHA's asking about this. What's going on? So didn't get a chance to ask him. I might mention it in a thank you note that I usually send a day or two after we meet with somebody. So that one I don't know anything about, but that's, I think, gonna be critical to the industry, especially if the Fed responds and said, these are the things we're seeing and we think are really effective.

[00:41:41] Bill Sullivan: Because that's almost kind of information sharing without information. so we've got that. The other one, and it's, this is out now and the comment period is due I believe in very early March. And that is the Fed very strategically is looking at what are the future of checks? Where are we going with checks.

[00:41:56] Bill Sullivan: checks are very costly. The Fed doesn't price them according to their cost. the number's dwindling, but it hasn't gone away. they really want to try to come up with an industry plan, so it's not. it's not, enacted by Congress. So somebody doesn't say, oh, we're gonna put a bill out there to eliminate checks in five years.

[00:42:15] Bill Sullivan: they'd rather have the industry kind of work with them to come up with the solution is now it's still a ways away for the comment period, so I don't know what my colleagues in the banking trades. Saying yet, but I know we're gonna take a very measured approach. 'cause of course you would normally think the aach h is gonna say, yeah, get rid of 'em, kill 'em all, blah, blah, blah.

[00:42:32] Bill Sullivan: but we understand there are consumers out there that still rely on checks. and some banks, it's still a bit of a profit center for them, I think. and we've not drafted our letter yet, I would think that we may just say Federal Reserve, you should at least price for the true cost. Of processing that check.

[00:42:49] Bill Sullivan: The pricing needs to be in line with the effort and work it takes to protect that check from fraud and to process that check. I know that some of the other trades I think are probably gonna say something similar. I don't think anybody's ready to say, yeah, 10 years from today, we get rid of 'em.

[00:43:05] Bill Sullivan: But I think that's gonna be the underlying theme that yes, we need to continue to do what we can to eliminate the check, but just let it die a natural death. There are other, one that's coming out that was the conversation with, governor Waller today and some of his staff is these payment accounts or skinny accounts as they're called.

[00:43:25] Bill Sullivan: And that comment period is due very soon. I think it might even be next Friday. and it's not crystal clear, they're trying to create these. Payment accounts. and even though now this is not the governor, this is Bill Sullivan speaking here, I think it might be a result of the custodian case.

[00:43:45] Bill Sullivan: And even though that case was ruled in favor of the Fed, maybe they were like, Hey, we've got a lot of actors out there that want to get involved in this space. Maybe we should put something out that we can control, that we know we can do and see what happens. And it's basically accessing, fed payment services, with the proper risk mitigation that goes along with it, but it doesn't allow for any service that doesn't do daylight overdraft.

[00:44:12] Bill Sullivan: So they're not giving credit to any of these companies or anything along those lines. And the one thing Governor Waller did say that. me was he said he didn't think this was gonna be a big boon to Fed. Now he thought it was gonna be a big boon to Fedwire because what they wanna do is settle all this crypto stuff multi nationally, as quickly as humanly possible.

[00:44:37] Bill Sullivan: So he, at least when he talked with us, he shared that he just thought that Fedwire was the real reason that there's so much interest in something like this. It wasn't fed. Now because of the daylight overdraft stuff. FedACH isn't even an option. so we'll see what happens and we are gonna file a comment letter, understanding that reallyACH is not gonna be part of their plans.

[00:45:01] Bill Sullivan: and I'm, I was pleased to hear that actually a lot of fintechs wantACH too to be part of it. but it just doesn't make sense in this particular model because there's not the credit option. With availability of Fed credit in, in a situation like that. I personally think Fed now will see a big uptick.

[00:45:17] Bill Sullivan: he doesn't, and he's the governor or a governor and I'm not. so I'm gonna go with him. but this'll be one to see, and I think we're gonna get some quick action on this because I think they realize we don't want to go through another custodial lawsuit. and we don't want some of these states that are a little bit maverick when it comes to the cryptocurrency regulations to jump on something.

[00:45:39] Bill Sullivan: so they're gonna try to get out in front of this quickly. So the comment period ends, I believe, next Friday or a week from Monday, somewhere around there. And I would think the Fed is gonna act very quickly on something like this, like the skinny accounts.

[00:45:51] Joe Casali: let me comment tell me, please, if on track or completely off track, the fraud one. I really have no, comment on. It's. We've done this exercise several times and how do it needs something breakthrough to solve this problem? 'cause I've seen a little bit, I've seen, we need a group to get together and talk about, we have groups to get together and talk about fraud.

[00:46:14] Joe Casali: So I'd love to see if something breakthrough comes out of that. the check really fascinating. from a, again, I told you before, but say it for the audience. I thought I was listening to a Saturday Night Live, live skit, because, checks check 21 made the image of the check, replacement to be a valid check as well as the original check.

[00:46:37] Joe Casali: so we see a lot of digital transactions that are checks, It's a check, it becomes an image. It goes back to being a check. Makes all sense. Fed went from, 22 operating centers to one or two. but when you listen,I think I'd love to, for you to confirm or deny this.

[00:46:54] Joe Casali: I've heard that the government is doing a really good job getting rid of checks just because they said we're getting rid of checks. But from a, the sad night live perspective, I was in a meeting with an other payment association and they said, oh yeah, we have Amish people that, that need the checks.

[00:47:10] Joe Casali: And I thought they were kidding. They were not kidding. The Amish don't have mobile phones. they need checks. So it was very interesting that there is a need. But I would agree, the cost is not, the cost of the operation is probably not being born. And I'll give you the final piece before I go on.

[00:47:27] Joe Casali: I'm glad you said it. the skinny accounts, in my mind, I go right to the crypto and I'm glad you actually connected those together. I did not know that connection for the settlement part, but it's the same question. and again, it's that battle of tradition banking, you're now bringing maybe a non-bank into the fold.

[00:47:48] Joe Casali: at the same time you say, would Amazon be able to support an account at the Fed? they probably would be able to afford an account at the Fed. So it's all very interesting. am I off track on any of that or any

[00:47:59] Bill Sullivan: No, you're not at all. Now. I will pick up on, when you were talking about the government being very effective at eliminating checks. They are, they're going to a lot. Of effort to do what they can. And, just the other day, the IRS put out kind of guidelines for this tax season they talked about, really pushing direct deposit, direct payment if they get paid.

[00:48:20] Bill Sullivan: No, hold on. If they still will accept a check if they have a refund that doesn't provide. TheACH  number, and I guess somehow in this year's reporting, you're gonna be forced to put in a routing number and a bank account. if that isn't done and they have to pay, they are going to send the, recipient who's getting a refund, a letter that said, please fill out your routing number and account number and send it back to us.

[00:48:47] Bill Sullivan: You'll be paid by direct deposit immediately. If they do not get that. They are holding the check for up to six weeks before mailing a check. So they're trying to disincentivize people by you might have filed on February 1st, but you're not gonna get paid until St. Patrick's Day or something.

[00:49:04] Bill Sullivan: and that was real interesting. It was buried in. a slew of great information that they put out. The other thing is, I've noticed that the Bureau of Fiscal Services, which is really the payment, the payables and receivables unit for the federal government, they're doing all sorts of cute little like Facebook stuff.

[00:49:21] Bill Sullivan: On get paid byACH don't pay by check and everything. And, when I scroll and I come across those, I always smile and usually try to share them with the few people that are my friends on Facebook and, look at that. But they are doing a good job. I know the other day, and I didn't even know.

[00:49:37] Bill Sullivan: Customs and border enforcement issued refunds. I'm not even sure for what, but they announced an interim final rule. And again, going back to, it's a final rule until we can come up with something better to say. they're putting out an interim final rule that takes effect on February 6th, that says all their refunds will be paid out electronically.

[00:49:55] Bill Sullivan: They are no longer paying a check. And I suspect those are more to corporates and governments and things like that, that have the ability to receive. Electronic transaction, but you have to be able to receive it electronically. They will not pay it out via check, and I don't think that's gonna be a blip on theACH  radar, but that's the type of things that agencies are starting to do.

[00:50:16] Joe Casali: And, the benefit of being old, one of the stories is the. Adoption ofACH by the federal government was one of the reasons. it got some feet and grew from the beginning. when the government says we're not doing checks anymore, that it, and interesting, again, being related to NACHA, related to NACHA being in, part of, being part of NACHA, I don't know what the right phrase is, but being associated, ah, being associated with NACHA.

[00:50:43] Joe Casali: You hear about, payment news and other geographies. Europe, the EU makes mandates, boom, mandates. We don't really do mandates. So by raising the cost of check processing, that may be a way to make the market say that's not attractive anymore. But really do mandates, interest.

[00:51:05] Bill Sullivan: Exactly. And two, two things on that real quick. One, when you were talking about the kind of growth ofACH and everything, coming along and the federal government, is the largest user I asked at the time, the gentleman whose name was Walt Henderson, and his whole job was to get people off of checks to electronic payments for social security benefits.

[00:51:26] Bill Sullivan: And I said. Walt, you're doing great. the numbers go up every year. How are you gonna get across the finish line? And he, and again, Walt was the sweetest, nicest guy in the world. He was not trying to be a smart ass. He basically said We have to wait for them to die. and, but now that, social security benefits are like 99% direct deposit.

[00:51:46] Bill Sullivan: and he really was right. so that's interesting. The other one, when you were talking about the mandates. I was fortunate enough years ago to be in a very quick, short meeting with the head of payments in the uk. He was coming into DC for a series of meetings in Washington, but I think he kinda wanted to sightsee, so he came in on a Friday.

[00:52:06] Bill Sullivan: And used, I'm gonna meet with NACHA and talk about theACH as a thing to then kick off his weekend with his wife, being able to sightsee and do all the things that you would if you're coming from Europe to dc. and we had a chance to sit down and talk with him a little bit and he said, yeah, I don't, we don't understand banking lobbying in our country.

[00:52:24] Bill Sullivan: Because we just tell them what to do and the banks don't spend their money fighting us or trying to get us to change our mind. They spend the money in acting what we tell them to do. And it's actually that one was like, that might put me out of a job, but darn, it does make a lot of sense. you think about all the money that goes into K Street lobbying and all the bankers and all the fintechs that are running up and down the aisles of Congress or, in and out of, different agencies and departments.

[00:52:51] Bill Sullivan: if that money all went away, think about all the good use that could be put towards.

[00:52:56] Joe Casali: For open banking.

[00:52:57] Joe Casali: wouldn't be talking to you today, but maybe that's not a bad thing either, No, it's great. You, it's always great. Are you kidding me? excellent. thank you for joining me today. I can't wait till we, the next meeting we have, whether it's a conference or another podcast. I will keep my, feelers out to see if Easter, maybe we can try to tentatively plan for Easter just in case clarity Act passes.

[00:53:19] Bill Sullivan: Yeah, clar Clarity will hatch on Easter according to Congressman McHenry.

[00:53:23] Joe Casali: There we go. Excellent. Ooh, that might be my lead in to the episode. Awesome.

[00:53:28] Bill Sullivan: Okay. Joe, thank you so much and thanks to everybody it needs for continuing to support NACHA, theACH  network and particularly what I do. You guys are the best.

[00:53:37] Joe Casali: Excellent. You too. You are, no, you are alright. Thank you very much.

[00:53:42] Bill Sullivan: Jill. Have a great one.

[00:53:43] On behalf of NEACH, your trusted resource and payments and our guests, I'd like to thank everyone for tuning into the podcast. If you've enjoyed this episode and want to hear more about payments, innovation and modernization, you can find The Wrestling Payments Podcast on the podcast page of NEACH.org or wherever you subscribe to podcasts.

[00:54:05] Just search for wrestling payments in your podcast app. Thanks for listening.