Jun 05 '18

Credit Unions' Acquisitions of Banks and Thrifts

So, a professor, a lawyer and a CEO walk into… a podcast? Listen to this amazing tale of a credit union growth strategy with seemingly no downside.

Holly Fearing

Hello everyone and welcome to the Filene Fill-In. I'm Holly Fearing with Filene. The Filene Fill-In is the podcast where we fill you in on what's been going on here at Filene's home base and out and about in the financial services world. So a professor, a lawyer, and a CEO walk into a podcast? No, this isn't the setup for a joke, but it is an amazing tale of a credit union growth strategy with seemingly no downside that we could find at least. This is the tale of credit unions acquisition of banks and thrifts, as told by David Walker, professor and director emeritus of the Capital Markets Research Center at Georgetown University who authored our research report and Michael Bell, the lawyer who has represented financial institutions across the US through more than 30 M&A transactions in the past five years and about 20 of the 22 or so instances of credit unions, acquiring banks. And we also hear from Gary Rigoli the CEO of Achieva Credit Union in Clearwater, Florida, the first credit union in the country to do this type of acquisition back in 2015. That's right. There's been at least 22 since that short time ago and all signs point to the trend accelerating forward. Altogether, these three tell a full story deeper than the research alone. We start here with professor David Walker. Thank you so much, David, for your time and for being here with us today, to share your knowledge with us, I'm really excited to learn more about this topic from you today. You are the author of Filene's research report called Credit Unions' Acquisitions of Banks and Thrifts. Tell us a little bit about what the research is about and what does it mean for a credit union to acquire a bank or a thrift?

David Walker

(02:02): This is fascinating to me because of the way it evolved as well as the study, which I know we'll be talking about. I was reading this summer and fall about just one article at a time acquisitions of banks and thrifts by credit unions. And it seemed like every couple of weeks there was another acquisition and so I contacted the director of research at Filene. I had done a project with the institute a couple of years ago and asked him whether or not he thought this was a project that the institute would be interested in. I got a very nice phone call back in which the content was, hey, this is really neat, but it's too soon. This is something we should probably do three, four years from now when there's much more activity. And so the took it to his research committee to brief them on the fact that at some point I would probably come in with a proposal and to his and my surprise, the committee, or some members at least, told him that we should get out ahead of this and do the study fairly soon. And so I got a phone call back saying, please do a proposal immediately and as I was told, it got unanimous support with the research committee saying, no, don't wait, get this while it's just beginning and let's be out in front of this and it's just been fascinating the whole way along. In my proposal, I knew there wouldn't be enough data points to do some fancy statistical study and so I proposed and asked for support so I could go out and meet some of the CEOs of the credit unions that had acquired institutions and that has been a fascinating part, as well as the numbers.

Holly Fearing

(03:58): Something that credit unions are definitely paying attention to is mergers. That's happening a lot in the credit union industry right now, but how is this type of acquisition different from the typical mergers we see?

David Walker

(04:14): Sure. In fact, one of the people who I found along the way was a man by the name of Michael Lussier in Massachusetts at Webster First Federal Credit Union who has acquired, I believe it's seven credit unions. His market area is pretty much central Massachusetts. He wanted to broaden that and he has recently acquired a credit union in downtown Boston in the shopping area, Samuel Hall, anybody from New England knows about that. I only know about it because my wife is from Boston and drags me there most of the time that we visit Boston and he was fascinating. Spent quite a bit of time with me on the phone and then proceeded to help me make the contact with the woman who actually did the very first credit union acquisition of a commercial bank. I had a phone interview with her. Her name is Tina Sbrega at GFA Federal Credit Union in Gardner, Massachusetts. She actually acquired a bank across state lines in New Hampshire and had to go through Massachusetts regulators, New Hampshire regulators, and federal regulators, both bank and credit union and we had a fascinating half hour that gave me a lot of insights. In fact, her credit union has won an award in New Hampshire for the contributions to financial education in Peterborough, New Hampshire. So that gave me a contrast talking to Michael and then Tina about the differences that they face because Michael, for the most part could deal with just one regulator and Tina was dealing with federal, two state bank regulators, and two state credit union regulators and has made a great success of this. The difference is somewhat in accounting because, and I am not an accountant, but as I understand it, and I have inquired from a number of people, if a credit union acquires a credit union, they're basically gonna take the assets, the liabilities and the equity of the institution they're acquiring and fold them right in. But when a credit union is acquiring a bank, they can't do that for a number of reasons. But number one, as many of your readers and listeners know, a credit union cannot own any shares of stock. So on the date of the acquisition, something must be done to eliminate the stock, whether you pay off the stockholders or create a goodwill account or various other technical accounting details. And then because of new accounting rules, about 15 years ago or so, when you do an acquisition like this, you cannot do what I described with the credit union, acquiring a credit union, which is called pooling. So what you have to do is take the assets of the bank you're acquiring and first of all, mark them to market and if they're not worth in the market, what they are listed on the balance sheet of the bank you're acquiring, you have to take a loss that you have to essentially subtract from the value that you're getting from the shareholders of the bank and make accounting adjustments that my accounting colleagues tell me are the subject of many court cases and research papers as to what is valid and what is not. So it's a much more complicated accounting transaction. Then you also get into the tax issue because the bank has a profit making organization is paying taxes and the acquiring credit union is not paying federal income tax. So it gets really complicated.

Holly Fearing

(08:21): Yeah, I can see. Is there anything else that you came across during this research that we haven't talked about today, but that you feel our credit union listeners should hear about from you?

David Walker

(08:36): I guess I would like to just repeat about the economies of both scale and scope, which of course, a credit union acquiring a credit union doesn't benefit from. A credit union requiring a credit union would be expanding their scale, their size, but not their product lines. The other thing is if I were personally doing one of these, the first thing I would want is an absolutely first-class accountant looking over my shoulder and evaluating the accounting transactions. I also want to mention that I had a fascinating phone interview with an attorney who has been very active in this activity, Michael Bell with Howard & Howard. I waited to interview him until I had pretty much drafted much of this study and he was able to confirm a lot of things and he was also able to point out some of the potential pitfalls, if a credit union wasn't already in good financial state.

Holly Fearing

(09:36): David advised us not to just take his academic lens on this, but to speak with the lawyer who did the majority of the transactions. So that's when we reached out to Michael Bell.

Michael Bell

(09:45): You know, sometime ago, let's say about 10 years ago, I was sitting with a credit union client and we were talking about non-organic growth opportunities, which at the time I think conventionally, everybody thought were somewhat limited and folks essentially looked to credit union to credit union based transaction. And those are wonderful. I believe in them. I think that makes sense, but they can be frustrating as they sometimes fall apart for emotional issues, like names and board seats and things of that nature. And so when we were talking about this, an idea of acquiring a non-credit union or a commercial bank came up and I looked into it and I didn't find anything that said it was prohibited, but I didn't necessarily find anything, you know, specifically that said it was permitted. And so being young and probably naive, I decided that since it was gray, we would give it a shot and take a position and see if we could do it and my client agreed knowing there was some risks, right? Some approval regulatory risks there and we took the shot and did the first ever. And then, you know, after that, it was a bit of a slow waterfall, but at the moment as of last Friday, actually, we're now sitting at my counts, at 22 transactions of the whole bank nature having been completed today.

Holly Fearing

(11:06): So how new is this type of acquisition for credit unions to invest capital and grow?

Michael Bell

(11:14): I feel like even though we've been doing this for awhile, approximately 10 years, nine, 10 years, it's been so few, you know, there was 1, 2, 3, 4, maybe in the first three or four years, kind of one a year that it was relatively unknown. I will say that this idea, I now believe it's reached a critical mass, both in the credit union space and then in the bank space. You know, most of the professionals that sell banks or parts of banks now have come to see this as a real positive and that has helped increase the deal flow or the amount of sellers out there. I will say that it continues to evolve. You know, there are more things now recently that I've had clients purchase that are unique, whether it's real estate or realty type companies, you know, first mortgage operations that are not depository in any nature. They're not even a bank. They just use money and originate mortgages. We continue to evolve on the types and kinds of things that you can buy. So that continues to grow. But again, that transaction and its idea has been around long enough so that a credit union today can rest comfortably in that their peers, have essentially done this before and there's precedent out there for almost every kind of transaction

Holly Fearing

(12:31): With what you're seeing in increase in acquisitions of many different types, are you seeing any cautions or roadblocks that you would want credit unions to be aware of before they walk into this space?

Michael Bell

(12:50): Yeah, so I can, you know, I can give you a long list of reasons why these are wonderful and I think be very compelling, you would almost think I was a salesman, but I will tell you, there's certainly some reasons why you would never want to do this, absolutely. And I think there's really three main that I have found. The first is this will involve, you know, a significant, most likely significant spend of your capital. You're going to write a check probably larger than you've written before. And I think that there are plenty of credit unions I've spoken with that, you know, you can show the models and the numbers and prove that the transaction works and that it's good and advantageous, but in the end they just are not comfortable engaging in a strategy that spends capital and, you know, a significant amount of capital and I understand and respect that. That's reason one. Reason two, you know, the credit union management team, whatever that means to that individual credit union, that management team I believe has to be ready and have the desire and bandwidth, let's say to work on an extra project that is significant because they certainly will have their day job. And then, you know, once this gets moving and we close the deal, that's going to be supplemented with a lot of work. You know, there's definite management involvement here that you can't hire vendors to do for you when it comes to certain pieces of these deals. I mean, vendor, you can leverage vendors a lot, me being one of them and we can be very helpful, but in the end it does fall on you pretty hard. And so again, I've met with credit unions where we've examined this and they agree that it's great, but then they decide that they just don't have the management desire or bandwidth to do it. And then the third reason why you wouldn't want to do it, you know, at the moment there are a couple credit unions I work with that their organic, their internal growth machine through whatever that might mean for them, their loan originations, et cetera, is moving so quickly and growing so fast, they cannot keep up with it. And at this moment, the last thing they can afford to do adding assets to the books or growth, through one of these non-organic transactions, they just don't, they just can't do it at the moment. The math doesn't work and it's not a wise idea. And so if your organic machine is so wonderful at the moment, we would have to pause on these transactions as well.

Holly Fearing

(15:13): So is there an ideal type of credit union that's best positioned to receive success in this effort?

Michael Bell

(15:22): Sure, I think there's some common attributes, certainly. You know, currently I work with, let's just say approximately 150 credit unions across the country, of all shapes and sizes in general and each has their own culture, but I think there's a common thread that's weaved throughout that group that is in this space. And, you know, you certainly have to have capital. It's not like you have to have an abundance, but you have to have capital to put to work. And then, you know, you have to have sophisticated management and I don't mean fancy management. But you do have to have management though that is desirous and willing to take a step that maybe isn't identical to what they do every day and ready to take on that challenge and have kind of a management team and a board that is supportive of, the word innovation gets overused and this really isn't innovative in that it's factual and it's doable and people have done it before, but it is operationally probably innovative for a lot of credit unions. They have to be willing to embrace that and do it and I think that's the thread that weaves between the various clients I have that are doing this.

Holly Fearing

(16:33): And what advice would you give to credit unions that are just thinking about this, that haven't yet started the process.

Michael Bell

(16:40): So without being dramatic and you know, putting everybody's hair on fire, I do need to emphasize that now this moment, this year, earlier in the year, going forward, would be the moments to do this, if you want. This is always relevant. It's going to be relevant the next 10 years and there will always be transaction. But what I'm saying is this moment, the pricing is such, the amount of sellers are out there is such, that the economics of this transaction are not getting better. We're not necessarily going to get worse per se, but they're not getting any better. Another way to think about it is if you're at a stop light, you know, you're the second car and you're in a rush to get somewhere and the one in front of you is sitting there and the light turns green and they don't move. You think to yourself, boy, person, it's not getting any greener, you know, go! That's what I'm translating now to listeners is that this is appropriate and relevant always will be, but to take full advantage and have the best choice among things to buy and the best pricing, it was now slash yesterday. So that's the key takeaway in my opinion.

Holly Fearing

(17:53): Wow, so the light is green is what you're saying?

Michael Bell

(17:56): Yeah, and it's not getting any greener. And I think folks will understand, right. There are cycles in every industry, you know, cycles and honors, and, you know, they've experienced that in their own way with their own products, right? Auto lending is wonderful and then it kind of sinks awhile and it's wonderful. Mortgages, same thing. Well, this also is cyclical and so we're on the top end of the curve with this type of deal right now.

Holly Fearing

(18:21): What would indicate if that curve is starting to dwindle? At what point would we know, no longer is the light green?

Michael Bell

(18:30): Well let me just be clear, he light's always green, for sure. But I think that if you look back historically and you looked at bank pricing, you would see that in 2006 and 2007, the pricing was at its highest level. The recession came and pricing died, and it's now building. It hasn't reached those 06, 07 levels, but it's certainly reaching the 03, 04, 05 level, it's getting up there. And so I think if we see pricing continue to rise and deal flow and the amount of deals to continue to increase, it's pretty reasonable to expect that that will have a cooling off in the near term. And right now we're at a frantic pace. It's a wonderful thing right now, it's the best time, but you have to be pragmatic to understand that it won't always be the best time.

Holly Fearing

(19:22): And what have those results been so far that you've seen with those that have done this?

Michael Bell

(19:28): Yeah so, and I'll tell you, I would encourage people to speak to those that have done this, they are happy to share, first but second, I'll tell you that to a credit union, I can't think of one that has done us and said, I'm never doing that again. In fact, almost all of them have said, let's do this again. You know, it's been great for us, whether it was a gain in talent, a gain in geography, a gain in assets or liabilities, you know, loans and deposits. In fact, I think now three credit unions that have done this have already purchased a second and are looking for more and others I know are actively continuing to look, even though we haven't got a second deal yet. So to a client, I believe it's been, you know, wildly positive.

Holly Fearing

(20:13): And the other thing we've seen in our research is that this really helps credit unions live their mission a little bit more of serving deeper into the community and serving those that maybe don't have a lot of other financial options. Have you seen that to be the case with your clients in this work as well?

Michael Bell

(20:32): Yeah, I think it absolutely is. I mean, so beyond the business case, because there's a strong one, I mean, the numbers on these are beautiful, the return on investment is great. So beyond that, the numbers case, I think there certainly is a clear case for the strengthening of the movement. And I think that matters and we measure our members and how many we gain and this, though may seem a trickle, is actually substantial. If you look at the 22 transactions that have been done, that's a substantial gain in credit union membership and this is a direct way to make that happen. And I'll be honest, it happens overnight, right? We close and then on what's called legal day one, typically a Saturday or a Monday, those either 1000 or 10,000 bank customers become members overnight. So there is a story there that's real and tangible, I think it's important.

Holly Fearing

(21:29): Yeah, that's really interesting because when you're a member of a cooperative, you own the business. So in a way for those people, they become business owners overnight and that's a really interesting story, I think, for credit unions to be able to tell.

Michael Bell

(21:44): That's true. Absolutely.

Holly Fearing

(21:46): Is there anything else that you want our listeners or credit unions out there to know about this trend or what you've seen in your work through the acquisition of banks by credit unions?

Michael Bell

(22:01): You know, I don't think additional to anything I've said so far, except I think there's some emphasis here that's helpful and it's something that I've been trying to kind of spread and get known and I think we've done that, but the key emphasis is that this is not a maybe or an idea or something crazy or risky. You know, this is a fact and your peers have done it and they are doing it again and again. And so this is absolutely real, just as real as starting up a credit card program or getting indirect lending. I mean, that's how real, this is absolutely something you can do. And then second is, I mentioned the financial, the math on this is extremely strong. And then the soft considerations that are also just as important about the movement and membership are just as strong. So it's got those two great things going for it. And it's nice to know there is this tool that can supplement the great things the credit unions are already doing. This is not something that you say, okay, I'm going to do it and it's the only thing I'm doing no, it's just a supplement or a bolt-on is a word you hear out in the mergers and acquisition lands. So your credit union, its model, its mission, its organic program all stays the same, nothing changes. This is just in addition to it to supplement that and what's happening and it does a really nice job.

Holly Fearing

(23:25): Michael recommended we also speak to a credit union that has done such an acquisition firsthand. So we did that too. Here's Gary Rigoli.

Gary Rigoli

(23:33): There's a certain amount of courtship that's involved. We had to meet the CEO and president and I, they had a CEO and a president and two different individuals and I met and we introduced ourselves, talked about the concept and it took a while for us to get to the point where we could answer a lot of the questions in our minds. And of course we had to, we had to get the state involved because we didn't know exactly how the regulators would look at a transaction like this merger purchase. And we knew what the bank's preference was. So we talked to them and their legal department found out that it was possible and really just proceeded from there to talk about the potential. And then of course it led into a letter of intent non-binding letter of intent. And then we started talking about a definitive agreement and that's where most of the work happens on the front end, at least for the transaction to happen, agreeing on all the different components of a definitive agreement.

Holly Fearing

(24:42): And what have the results been so far or what have you learned going through this process several times?

Gary Rigoli

(24:50): Oh my, we learned, yes, we learned a lot. First of all, this is only our second, so it's not like we've done dozens of them, but we've learned that the transactions maybe mechanically are very similar, but each financial institution is different. So you can rely on the mechanics from previous experience, but the people involved are different, so the dynamics change. We learned that in 2009, we merged a credit union and we learned that the banks tend to look at this as a business transaction. So you probably heard other folks say that there's a lot less emotion in a bank purchase versus the credit union merger, because at least in our two experiences, there's been no interest in continuing the bank name, board seats, the executives at the acquired financial institution understand how these deals work and they may or may not have a job when it's finished. So the dynamics in that way change. But on the other hand, there are some differences in how credit unions operate, not from a product and service standpoint necessarily, but just we have a different mission and vision and so it's just different. But I can say that the community banks that we've talked to and the two, the one that we merged and the one we're talking to about merging now, their cultures were very similar to credit union culture. So as far as the people were concerned, they understood that there's an importance placed on high levels of service in both types of financial institutions.

Holly Fearing

(26:42): And that's really interesting point about it being emotional or less emotional. How does that work when the two businesses have different structures, as far as a credit union, being a cooperative, did the customers of the bank then become members or how does that work?

Gary Rigoli

(27:03): Well in Florida, the Office of Financial Regulation require us to get an opt-in agreement signed by every bank customer. So basically they are opting into credit union membership and so that's the process that we went. It's a very simple form, but the task was, we have to have everyone sign this within six months of the deal actually closing. So that was a big task for us to accomplish. And fortunately we were able to do that, but it took a lot of effort, especially on the part of the employees of the acquired institution to have conversations with their customers and help them understand what a credit union is and what that meant and the fact that this is something that we had to do. But on the other hand if the deal didn't close or if something happened, they were certainly not being held hostage, they could close their account and leave just like any other financial institution.

Holly Fearing

(28:01): Did you get any sense of whether this was overall seen as a positive transition for the existing customers of the bank and the employees of the bank? Or was it neutral or how do you feel it went culturally?

Gary Rigoli

(28:19): Culturally, I think it went fine. The employees tell me that they're very happy, Achieva employees, but on the other hand it's change and some folks handle change better than others. So there was a lot to learn, a lot of systems and processes and procedures. And anytime you take a new group or a group of employees and take them off of one system and put them on another, there's bound to be some angst and angst can lead to different outcomes. So we probably experienced what I would consider an average amount of turnover, not too high. There was some, but on the other hand, their customer base for the most part, they like having a broader array of products and services, especially on the consumer side where, what we learned though, we learned a lot about ourselves on the commercial side. So we're commercial lenders and our business deposit services were weak and so we had a lot of growing pains on our side in those two areas.

Holly Fearing

(29:34): And how about your organization from Achieva side, the existing employees and the existing members, what kind of communications did they receive and how did this acquisition change or maybe not change the way your organization already existed?

Gary Rigoli

(29:57): No, it really didn't because we were, not that everything is dependent upon the size of the institutions, but we were a billion plus credit union and they were $165 million bank. So it didn't impact our organization enough for the members to feel it. Now, I will say that a lot of our members who have been members for a long time and who are paying attention to what we're doing, were concerned that we were going to take on a bank charter and so they were saying, well, we don't want our credit union to become a bank. So we had a little bit of a communication job to do with the Heritage members assuring them that no, we're not becoming a bank. This is a unique transaction, but in fact, what we were doing was acquiring some branches in a part of the field of membership, where we had no representation and then they were fine with it.

Holly Fearing

(30:53): One of the challenges that credit unions often have when it comes to marketing themselves is just around awareness of what a credit union is and the language around what it means to be a member and to have dividends and things like that. Do you feel that there was a learning curve for the customers of the bank to understand what it was like to now be part of a credit union instead?

Gary Rigoli

(31:20): Absolutely. We had some folks saying I don't want to join a union, so yes. That wasn't a lot, but those were some vocal folks and they realized, we realized that we had some educating to do. And I'll be honest with you, some of the employees didn't know what a credit union was, so we had education to do from day one. And even in this transaction that we're working on now, I don't think that even some of the executives at the bank realized that for instance, our board members are volunteers and they don't get paid. So, yeah, there's a lot of education that has to happen from A to Z.

Holly Fearing

(32:01): And what kinds of things are you doing to help with that education?

Gary Rigoli

(32:05): One of the things that really helped, not just from an industry education standpoint, but also learning our organization and even our procedures we developed, or our team developed a sort of a buddy system. So every one of those bank employees had at least one employee that was a Heritage Credit Union employee, long-term credit union employee, that they could pick up the phone and call or email if they had any questions. And so we pretty much had a buddy system that worked real well.

Holly Fearing

(32:36): Oh yeah, that's a great idea, I love that. How have you seen this? You mentioned that your organization is a billion plus credit union and you acquired a substantially smaller bank in asset size. So how has this affected your business bottom line?

Gary Rigoli

(32:57): Well, it's been an improvement to our bottom line. We invested $23 million in this transaction and our ROI on that investment right now is looking like it's going to be a 10 or 11% this year. So from a return on investment standpoint, we feel pretty good about that and we think it could obviously even go much higher.

Holly Fearing

(33:18): That's great. And is that what you expected or is that, is that something that you feel is common?

Gary Rigoli

(33:23): Yes, in fact, if we hadn't seen that, I mean, certainly we did our homework beforehand and we ran several versions of performance and that sort of thing, but we actually had a pretty good idea of what we should be able to expect going in.

Holly Fearing

(33:39): So what advice would you give to other credit unions that are looking to take on such an acquisition?

Gary Rigoli

(33:47): Well, do your homework. It's a process and the bank that we're currently working to purchase, I've been talking to their CEO for almost five years, so it's not necessarily something that's going to happen overnight. This bank, the second one certainly is in very good financial condition so they weren't as maybe urgent as the first one was, but nonetheless, give it time, develop the relationship because in the credit union merger or in the bank merger, it still comes down to a matter of trust and it has to start at the very top. So I would advise the CEOs of credit unions and community banks to take your time, get to know each other and make sure that the fit feels right and then move on from there. Second of all, prepare your team for a lot of work. I tell our team that I'd get to do the easy part, even though it takes a long time. Once we get past filing the application with the regulators, assuming that we get their approval, you can imagine that there is a lot of work to be done to integrate data and records from a bank system into your core system. And people have day jobs, but they have to get it right, because you can certainly mess a lot of things up. So it's a lot of work. It's a years worth of work, just doing that part of it. And if you don't have the team that has the stomach for it, or has the drive or the passion for it, then that's something to think about. Our team is the type of team that they like challenges. They like change. They know they don't have much of an option sometimes with me here, but nonetheless, we have a team that says, just tell us what we need to do and we can get it done. So there are a lot of considerations. It's not just a flip of a switch by any means.

Holly Fearing

(35:51): Yeah, I think that's a really great reminder that it isn't a quick fix and it might not fit into a one-year business plan if that's how you're looking at making the change happen. So is there anything else that you discovered during the course of your experience in acquiring a bank that you feel like is worth mentioning to others or lessons learned or anything that you would want them to know?

Gary Rigoli

(36:17): I would suggest that you have to be able to get past that, and I even hate to mention this, but you have to get past that bank versus credit union discussion that's happened for decades. If you're talking to a community bank, you might be surprised how similar their business philosophies are. Now, there are certainly differences on the structure and there needs to be a lot of learning, but, at the end of the day, you've gotta be able to get past that. And if you can't then maybe this isn't the right type of transaction because the bankers don't like it, the bank trade associations, I should say, the bank trade associations, don't like credit unions purchasing banks. That only seems to, in their minds, only seems to give them more fuel for their fire. But at the end of the day, what we're trying to do is serve consumers and small businesses and if a person can buy into that philosophy, then there'll be fine.

Holly Fearing

(37:18): That's a really great point that, you know, the credit union mission is to help consumers and small businesses with their financial needs. It's not just in and of itself to support the concept of a credit union, so anything that helps.

Gary Rigoli

Yeah, let me throw one other thing that was kind of an aha for me. The community banks have similar opinions of the great big banks, the big three or four, especially similar opinions as do credit unions.

Holly Fearing

Oh wow, yeah. I wouldn't have thought of that, but that makes total sense. They're feeling the same pressure as credit unions around competition against those large banks too.

Gary Rigoli

And regulatory compliance is costing them a lot, just like it is us. So there is a lot of, there are, there are several areas of common ground.

Holly Fearing

So working together can help you both.

Gary Rigoli

And at the end of the day, we like I'm repeating myself, but at the end of the day, what we're trying to serve consumers and small businesses.

Holly Fearing

(38:27): All right, that's it for the Fill-In folks. Thanks again for listening. This episode of the podcast was sponsored by our research team to give Filene members and listeners an opportunity to go deeper into our latest report on an important issue that we're keeping our eyes on. I want to take a moment to give one last huge, thank you to David, Michael and Gary for taking the time to share their vast wealth of knowledge and experience on this topic with us today. And of course, to our amazing research team at Filene for pulling it all together so beautifully once again. If you liked this episode, please do rate us on Apple Podcasts so more people can find us and make sure you're subscribed to the Filene Fill-In podcast so you can keep up with what's going on at Filene. You can find us on Apple Podcasts, Stitcher, SoundCloud, Google Play, or wherever you get your podcasts. If you want to get in touch about today's show, email me at [email protected], or find us on Twitter at @Fileneresearch. Until next time. Thanks everyone.