Credit Eco To Go

Season 4 of #CreditEcotoGo begins with an in-depth conversation about “data portability”.  Section 1033 of Dodd-Frank authorized the #CFPB to write rules around personal financial data rights. Former CFPB Assistant Director, Corey Stone, joins the podcast to discuss the goals of 1033 and whether the proposals went far enough. The data landscape has changed since Congress included this “sleeper” section into the Act. Corey believes the last decade shows us that industry has caught up to what Congress had in mind back in 2011 and therefore the CFPB's proposals may not be such a heavy lift after all. The question remains whether this will promote competition as the CFPB's narrative suggests, or will it, like most regulations, result in a “too small to succeed” scenario. Tune in…. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

The ecosystem is a circular environment. There is no beginning or end. In #financialservices, the loan origination may begin the process but the decisions made from that starting point will be impactful through the life of the transaction, especially if the loans are sold to the secondary market. This lack of consistency has been a challenge not only for the debt sale market but also for those who want to regulate it. To bring some clarity to the matter, Rebekah (Bekah) Luebcke, Vice President of Operations of Crown Asset Management, stops by #creditecotogo to discuss what entities need to know (as well as what they need to do) if they intend to sell unsecured debt into the secondary market.  The secondary market is nothing new, just look at the mortgage industry, yet there is significant scrutiny upon the unsecured debt market when debt is sold. The response to that scrutiny has been a patchwork of laws and regulations that are inconsistent from state to state. Bekah discusses her experience working on behalf of the industry to educate and inform stakeholders in order to bring much needed consistency within the space. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

As the headwinds of a turning economy impact more and more consumers, understanding how #debtsettlement fits into the credit ecosystem makes for a timely conversation. Teresa Dodson, founder of Greenbacks Consulting and the leading expert on debt settlement, stops by #creditecotogo to set the record straight about debt settlement. Consumers enrolled in legitimate debt settlement companies want to resolve their debts; they are not looking for excuses or loopholes from their responsibilities. However, the average consumer looking for assistance from debt settlement companies are juggling 6-8 credit cards at a time. A consumer can try to tackle that reality on their own but more likely it will become overwhelming, Teresa also tells us that consumers' priorities have flipped. Prior to the pandemic consumers focused on their credit, now consumers are more concerned about paying for their necessities (i.e. food, clothing, shelter and transportation). To meet these new priorities, debt settlement companies will be instrumental in bringing important services to consumers. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Ensuring #fairness at all levels in financial services is the new norm. But how do you do it and how do you know when it is achieved? Kareem Saleh, CEO and Founder of FairPlay AI stops by #CreditEcoToGo to talk about his platform and new #ai fairness methodologies, which do a better job in assessing risk, while at the same time expanding opportunities for credit access. Kareem tells us that “fairness through awareness” and machine-learning algorithms always need to be challenged and refined. Rather than settling for one result, Fairplay exposes their algorithms during model development for alternative outcomes that might not have been well-represented in the first round of data, making the data more sensitive to disadvantaged groups. Kareem hopes this philosophy will enable all financial service entities within the credit cycle, to continue to harness data for the benefit of all consumers. #financialservice #equalaccess #fintech DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

There is cautious optimism that 2022 will be the year that federal legislation will open the door to the banking of cannabis transactions. But is the Safe Banking Act the answer? On the  latest episode of #CreditEcotoGo with Joann Needleman, Peter Su, Senior Vice President of Green Check Verified manages our expectations and tells us that the real issue is the lack of “capability, capacity, and cost”. The regulatory burden of taking on cannabis customers is significant for financial institutions.  The Safe Banking Act does not address how banks will be supervised and examined by prudential regulators. Adding to this confusion, some states like New York, are implementing policies like “Justice Involved”, which allows applicants who have had convictions for minor marijuana infractions to go to the head of the line when applying for a retail license. The standard customer due diligence policies and anti-money laundering regulations do not align with these potential banking customers and in the end their banking services will cost more. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

In the last decade, the CFPB has tried to tackle the question of innovation through partnerships and No-Action Letters. First, there was Project Catalyst which resulted in very few collaborations and a small amount of No-Action Letters. Then there was the Office of Innovation which stood up the Compliance Assistance Sandbox which approved only 3 applications. Now the newly re-tooled Office of Competition and Innovation looks to continue these innovation partnerships but will it succeed? Nat Hoopes, VP and Head of Public Policy and Regulatory Affairs at Upstart stops by #creditecotogo to talk about the challenges of a regulatory partnership. While a No-Action Letter can offer a fintech or financial services entity an opportunity to “innovate in plain sight”, the time and available resources may not be attractive to many companies. For Upstart, the experience and collaboration with the CFPB was very positive but others may see that the juice is not worth the squeeze. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Text and email are not digital versions of a letter or a telephone call. There has to be a strategy that includes consumer consent but also a willingness by that same consumer to continue the conversation. Enter Quanta Credit Services, a new innovative digital-first solutions provider that manages communication strategies. Aleks Whitchurch, CEO and Co-Founder of Quanta stops by the next episode of #creditecotogo to talk about the nuts and bolts of the digital communications journey and the many paths that journey can take. Aleks tells us this is not a volume game but a problem-solving game. Quanta's data shows that how you treat the consumer and customize the conversation can make a measurable difference. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

In a very crowded #fintech market, #CreditEcotoGo welcomes Sedric to the podcast. Voted the Most Promising Fintech Startup of 2022 by #Citi and #Visa,  Sedric is an AI solution which systemically implements the most critical part of a financial institution's compliance management system: risk detection and remediation. Rather than wait a week or a month for the results of an audit report, Sedric identifies risk and provides on-demand real-time training in order to remediate the risk. Our guests tells us that you don't have to sacrifice consumer protection for growth, rather consumer protection ultimately protects the financial services system. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Financial services reporters, Kate Berry, American Banker, Jon Hill, Law360, and Evan Weinberger, Bloomberg Law stop by #CreditEcoToGo with Joann Needleman for a year-end recap and forecasting for 2022. Our guests provide their insight and historical perspective of the #CFPB during this past year and where the agency is headed under recently confirmed Director, Rohit Chopra.  The politicization of the CFPB remains and all agree it may have gotten worse given that the Director now works at the pleasure of the President. Each guest makes the case for why industry should expect a wild ride in the coming year. Big-Tech will clearly be in the cross hairs but the consensus is that all financial services verticals will be subject to extensive supervision and enforcement. The recent riff at the FDIC and the CFPB's efforts to influence banking policy will make for a tumultuous 2022. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

It may have taken a pandemic for banks and financial institutions to finally understand and embrace the value of technology and social media. Shondell Varcianna knows this first hand. As the owner and founder of Varci Media, Shondell has successfully guided financial institutions communicate with their customers. Having worked as lender and underwriter for several banks, Shondell quickly realized that consumers do not seek financial advise from the banks where they have a relationship, and banks do not do a good job communicating with their customers outside the four walls of the branch. Meeting consumers where they are has been the key Shondell's success. As Shondell tells us, banks and financial institutions should spend less time pitching specific mortgage or financial products and more time providing useful information about buying or decorating a home through social media and blogs. This is meeting consumers where they are and results in consumers getting their financial questions answered. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

The Consumer Financial Protection Bureau (CFPB) has always been curious of Big Tech and its penetration into the financial services sector. That curiosity took center stage last month when the CFPB ordered six (6) of the most well-known technology companies (Google, Apply, Facebook, Amazon, Square and PayPal) to turn over information about their “products, plans and practices” when it comes to their payment platforms. Dan Smith,  Executive Vice President, Head of Regulatory Affairs at the Consumer Bankers Association stops by #Creditecotogo to discuss and forecast how the CFPB will use this data collection to shape policy about consumer-authorized use of financial data. As a former Assistant Director at the CFPB, Dan reminds us that back in 2017 the CFPB issued a set of Consumer Protection Principles around data sharing and aggregation. Like the Rime of the Ancient Mariner, 2022 will reveal how the CFPB will navigate this sea of data.  DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

ARM industry start-up, Spring Oaks Capital, set out to do things differently, but it had no idea that it would launch a new company on the cusp of a worldwide pandemic. Jay Collins, Co-Founder and Chief Operating Officer at Spring Oaks Capital, stops by #Creditecotogo to highlight the successes his company has had despite the challenges of COVID. Jay's story is a lesson to all in the financial services industry, as well as any industry, that establishing a team approach to your workforce and assuring that all players (employers and employees) must commit to the mission is a recipe for success and to lead with compliance.    DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

In celebration of the one year anniversary of Clark Hill's #CreditEcoToGo, and its 50th episode, we discuss the digital transformation of the collections industry with Dave Hanrahan, CEO and Co-Founder of Kredit, a next generation software platform that lets consumers interact with all their creditors, and those collecting for them, in one place. Kredit creates options for consumers while empowering them to make decisions about their own financial well-being in a global and holistic way. At the same time, creditors and debt collectors who connect with the platform must vie for the attention of the consumer; those who are responsive and provide the best customer service will likely be the ones who will see recovery first. Kredit is looking to not only build tools for those who need it the most but to also empower consumers to be in control over their own information.    DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Michael O'Neill, VP and Bank Secrecy Act Officer at Safe Harbor Private Banking stops by #CreditEcoToGo to talk about his experience building the right compliance program to bank the cannabis industry. Michael tells us cannabis bankers do not grow on trees and building the program goes beyond well beyond ordinary due diligence. Rather it is an ongoing commitment to ensure that the law is followed at every step and banking staff is educated and trained to bank the way regulators want. Safe Harbor is actively banking over 500 cannabis-related accounts and accepting more every day. Since 2015, they have been examined 15 times by state and federal banking regulators and in their latest examination, there were zero findings. Safe Harbor's success has been from the inside-out.  DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Congress, the states, and regulators have been scratching their heads for years when it comes to fintechs. Balancing consumer protection around innovation has been the source of contentious debate. Garry Reeder is the CEO of the newly launched American Fintech Council (AFC), an association that is looking to foster responsible innovation in financial technology. Navigating the “in-between spaces” of the traditional banking system and fintechs is one of the priorities of AFC and its members. as well as establishing a more outcomes-based regulatory scheme that takes into consideration a consumer's experience. Garry also tells us that defining fintechs will be important because there really is no true definition rather a broad focus on the speed and delivery of financial services. Ultimately, if fintechs are going to be regulated, then AFC will be advocating to ensure that the benefits and protections offered to traditional financial institutions be made available to its members as well.   DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Since the start of the pandemic, the financial services industry, including the accounts receivable management (ARM) industry, has predicted that the use of technology to contact consumers will grow exponentially. That prediction came true, but Firstsource Solutions,  a leading provider of business process solutions to more than 100 global businesses, has been using email and text to contact consumers since 2017. Arjun Mitra, President of Global Collections, stops by #CreditEcoToGo to discuss the success of his company’s platform. The results show that consumers are far better off in resolving their financial issues on their own terms.  Arjun reports that RPC or open engagement rates from consumers in a response to an email or text are far superior than any response to a traditional telephone call. Additionally, the platform can fully adapt to a consumer’s response allowing users to constantly adjust and tailor the messaging in order to continue the successful consumer engagement. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Todd Kleperis has spent his life taking risks. From military veteran to Harvard University, Todd never shied away from a challenge. It's no surprise that Todd now makes his living serving high-risk industries in the financial services eco-system. The founder of PayZel, Todd assists financial institutions with the implementation of their bank secrecy and anti-money laundering compliance policies while taking on high-risk depositors. Todd will tell you that banks with innovative boards utilizing sound governance policies can effectively manage this risk and slay the dragon.  DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Francis Creighton, President and CEO of the Consumer Data Industry Association (#CDIA) stops by #CreditEcoToGo to talk about the core fundamentals of the credit reporting system and the challenges ahead for 2021.  While state and federal regulators have been laser-focused on credit reporting accuracy, Francis tells us there are two bigger challenges. First is ensuring that more people can be included in the credit reporting system in order to gain better access to credit, Second is the policing of fraudsters who are preying on consumers with poor credit and promising them the removal of accurate information from their credit reports. Accuracy ensures that lenders make informed decisions about creditworthiness. The desire to remove negative information or not report negative information, even if accurate, is not a benefit to either the consumer or the lender. If we want the credit ecosystem to work, the truth must be told. #creditreporting #financialservicesDISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

On this episode of CreditEcoToGo, former CFPB Deputy Director, Tom Pahl, stops by to talk Regulation F. Tom has been the point person on #debtcollection policy while serving at both the FTC and the CFPB. The final debt collection was a decade in the making and Tom talks about the challenges faced by the Bureau and the evolution of the process which resulted in the final rule. Tom does not believe the rule will be rescinded or repealed but certainly changes could be made once a new director is installed at the CFPB. The final rule is not the end of the process. Tom encourages industry to continually engage with the Bureau to ensure that the regulations fulfill its promise of protecting consumers while at the same time ensuring that industry can comply.DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Industry expert, Cristy Ward, Chief Strategy Officer for Mortgage Connect stops by Clark Hill’s Credit Eco To Go to discuss the state of the mortgage industry during and after the pandemic. The mandates of the CARES Act and the rush to refinance created unique struggles for the industry. However, Cristy explains that overall the industry did a great job weathering the storm by embracing technology which ultimately benefitted borrowers and will continue to be a positive for consumers going forward. Cristy is also the Founder and Director of the Women Empowering Women executive council – a group of leading Mortgage Banking women who serve the industry through peer-to-peer collaboration, executive coaching, and mentoring for women in banking. A fitting guest for our month-long celebration of #womenshistorymonth2021.DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Credit Eco to Go concludes #womenshistorymonth2021 with a long overdue discussion about the Paycheck Protection Program (#PPP). Kathryn “Kate” Rock, Partner at Guidehouse, incoming President of Women in Housing & Finance and one of the foremost authorities of the #PPP, stops by the podcast to talk about this transformational government program. For borrowers, the PPP was a business lifeline to get through the economic struggles brought on by the pandemic. For lenders, the PPP was a mixed bag of operational challenges and confusing regulations. At the same time, it was an expansion of business development opportunities for new and existing customers. The PPP is now in its second iteration. However as Kate tells us, the next challenge for lenders will be the servicing of these loans over the next five (5) plus years. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Credit Eco to Go welcomes Amy Mertz Brown to the podcast to continue our celebration of #womenshistorymonth2021. Amy was one of the first hires at the CFPB where she helped establish and build the agency’s in-house legal department. Amy worked closely with initial CFPB leadership including Elizabeth Warren, the Bureau’s first confirmed Director, Richard Cordray, and with Rohit Chopra, who is likely to be confirmed as the next Director in the coming weeks.  Amy shares her insights about Chopra’s leadership style and what she believes his priorities will be as the Bureau develops under his direction. Spoiler alert: policy will drive Chopra’s agenda, so industry needs to be engaging the Bureau now. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

The celebration of #womenshistorymonth2021 continues. Subject matter expert, Alma Angotti, joins the podcast and provides our Credit Eco to Go listeners with a much-needed education on cryptocurrency and blockchain technology. Cryptocurrency is not a substitute for hard currency but the infrastructure behind it; blockchain technology has the power to disrupt traditional financial services. Blockchain technology is immutable, meaning it can’t be changed, so it is easier to trace. Think of a chip on your cell phone that provides your location. This technology coupled with cryptocurrency provides instantaneous value with little settlement risk, unlike traditional banking. However, the unknown of “crypto” is valuation. So before you buy that Tesla, it's best to know what your “coins” are worth. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Clark Hill’s Credit Eco to Go kicks off Women’s History Month with best-selling author Mary Shores. Mary’s unbelievable journey from overcoming incredible odds to successful business owner to industry expert is inspirational. Along the way, she developed and unlocked the science to effectively communicating with consumers about their financial reality. As Mary says, “All consumers want is to be heard and to be understood.” Mary is hopeful that expanded technology channels, especially in the debt collection space, will help consumers achieve this goal. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Clint Lotz, President and Founder of TrackStar stops by Clark Hill’s Credit Eco to Go to talk not only about data, but he weighs into the debate of data regulation. More and more states are enacting laws that give consumers more control over their own data. Industry opposes a fragmented regime and instead favors a national standard. Clint disagrees and sees states being in a better position to align their privacy laws with the needs of their constituents. At the federal level, Clint sees agencies like the CFPB weighing into the regulation of data, especially when the economy starts to recover and lending increases. Ultimately the consumer needs to know whether their own data will be their friend or foe. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

There is much speculation that 2021 could be the year that Congress enacts meaningful legislation to allow marijuana related businesses (MRBs) to access financial services. Steven Kemmerling, CEO of CRB Monitor, stops by Clark Hill’s Credit Eco to Go to discuss what banks are doing now to manage risk for their current depositors who may only have remote or indirect ties to MRBs. Although the data from the Financial Crimes Enforcement Network (FIN Cen) suggests several hundred banks are currently servicing cannabis customers, that number is deceiving. In actuality the number of banks who are knowingly servicing cannabis customers is quite small. According to Steve, federal legislation will not remove the high risk element of cannabis banking. Like other high risk yet legal industries such as gambling and gun sales, banks will still need to invest in a costly compliance infrastructure passing that expense along to the depositor. Only when the federal government takes a wholistic approach to cannabis banking, will banks be willing to wholly adopt and provide financial services on a large scale. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Kevin Kelly, leader of Clark Hill’s Government and Regulatory Affairs Group stops by Credit Eco to Go to discuss the changes in Washington and what financial services entities need to do to prepare for the days ahead. Kevin tells us that the priorities for the Biden Administration will be focusing, among other things, on the economic crisis and passing COVID relief in the form of direct stimulus as well as housing and rental assistance. However, the financial services executive branch agencies will be bringing a fundamentally different approach, focusing more on a populist agenda. With support from Sherrod Brown, who now will Chair the Senate Banking Committee, and Maxine Waters retaining her status as Chairwoman of the House Financial Services Committee, access to credit for underserved people and ensuring fairness and equity in the financial system will drive their agendas. Look for policies that will reflect “recovery for all” and initiatives that ensure the financial services industry is working for everyone. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Georgetown Professor Adam Levitin stops by Clark Hill’s Credit Eco to Go to provide his objective perspective on the CFPB's Final Debt Collection Rule. Overall Adam supports a having clear rules of the road, regardless of whether you agree with the rule itself. He agrees that having a rule that provides guidance for debt collectors to navigate the electronic ecosystem is very important and was glad to see that a model validation was finalized but believes it will be tweaked over time. Adam does have concerns about the frequency limits with regard to attempts to communicate by telephone and worries that repeated and unwanted calls find their way into harassment. Finally, Adam was very surprised that the CFPB did not move forward with a final rule on time-barred debt but suspects the issue may still be addressed down the road, maybe in a UDAAP rulemaking. The conversation about debt collection and the debt collection rule may be headed into extra innings. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Ralph Liberio, President and CEO of NCB Management Services, Inc. stops by Clark Hill’s Credit Eco to Go to discuss the CFPB’s new debt collection rules and the power consumers now have to resolve their debts on their own. NCB’s self-service web-based portals allows consumers to make payments on their own terms and to set their preferences of when and how they want to be communicated with, including opting-in to receiving emails and texts. Ralph tells us that consumers are more responsive and engaging when they have control over the rhythm, flow and “beat” of the communication. When it comes to debt collections, consumer like to dance on their own. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

A financial services system must work for everyone. But how is that goal achieved? In 1968, President Johnson formed the National Commission on Consumer Finance (NCCF) which later issued a report in 1972 with recommendations of ways to change and improve a growing consumer financial services industry. Over fifty years later, the Consumer Financial Protection Bureau (CFPB) formed a Task Force on Federal Consumer Financial Law. The Task Force was charged with putting together a report which would offer recommendations to meaningfully improve consumer protections and the financial marketplace. Todd Zywicki, Chair of the CFPB’s Task Force and Professor of Law at George Mason University stops by Clark Hill’s Credit Eco to Go to discuss the Task Force’s report and recommendations. The core themes of the report: inclusion (credit access), education, research, and regulatory coordination, are not surprisingly the same themes discussed by the NCCF many decades ago. Todd tells us that members of the Task Force hope this report can bring about an important dialogue around consumer financial services, the role of credit and the appropriate regulatory framework. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Addressing the student loan debt has taken on even greater urgency since the advent of the COVID crisis. Several stimulus proposals call for the cancelation of all or up to $50,000 of student loan debt, but would such relief help or hurt the economy? Mark Goldwein, Senior Vice President and Senior Policy Director for the Committee for a Responsible Federal Budget (CRFB) stops by Clark Hill’s Credit Eco to Go to discuss his latest article “Canceling Student Loan Debt is Poor Economic Stimulus”. Mark acknowledges that while getting rid of debt can be helpful for debt holders, it is not the appropriate vehicle for economic stimulus. For one it does not change people’s cash flow very much and research shows that for every $1 dollar of student loan forgiveness only $.23 cents is returned to the economy. Mark is a proponent of direct economic stimulus and offers some suggested alternatives to help student loan borrowers both in the short and long term. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Ray Peloso, CEO of Katabat stops by Clark Hill’s Credit Eco to Go to talk about the CFPB’s final debt collection rule and its effect of giving consumers more power when it comes to communicating about their debts. Katabat is a fluid platform that allows users to develop and design a consumer’s experience in order to adapt to their specific preferences. Ray agrees that technology will be a critical and necessary component to ensure the regulations are implemented to achieve its goal of allowing consumer to “think with their feet” when it comes to debt collection. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Last week New Jersey, Montana, Arizona and New Jersey voted to legalize recreational marijuana, while South Dakota approved legalization for both recreational and medical. Only 6 states in the country do not permit any use of marijuana with a handful of states permitting only limited medical use. While the majority of states will be benefitting from additional revenue through licensing and taxes, many of these now-legal businesses will still not have sufficient access to financial services and basic banking opportunities. Justin Fischer, CEO and Co-Founder of RiskScout, stops by the next episode of Clark Hill’s Credit Eco To Go to discuss the challenges small and community banks continue to have attempting to serve these legal businesses. RiskScout is a platform that streamlines the compliance process in an attempt to level the playing field for community banks. As Justin tells us, challenges also exist in the hemp space, which was legalized at the federal level under the 2018 Farm Bill. Many farmers are turning to hemp as an alternative crop only to be shut out by their local banks, especially community banks, because they do not have the infrastructure to manage the compliance risks. RiskScout provide these smaller entities a chance to compete. Unless the basic function of banks fully utilized, states seeking to expand their cannabis and hemp footprint will only see their efforts go to waste. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Isaiah Goodman, stops by Clark Hill’s Credit Eco To Go to talk about his new app, MoneyVerbs; a gamified platform which simulates and allows users to make decisions about money without risk. Financial wherewithal is not taught, rather it is a skill that needs to be honed. Many consumers are not only uncomfortable talking about their financial situation but making commitments to put aside current resources for the future. MoneyVerbs allows users to practice their decision-making about money while at the same time providing resources to build a personalized financial literacy community. MoneyVerbs was just accepted to Techstars Chicago, one of the largest international incubators, where its app will be able to launched on a broad scale. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Mike Ginsberg, CEO from Kaulkin Ginsberg returns to Clark Hill’s Credit Eco To Go to discuss Business Revolution Week (BRW) which will talk place November 9th-13th, 2020. For the financial services industry, like many others, attending conferences and meeting with clients is a critical part of business development, networking and education. The pandemic has put brought those interactions to a grinding halt. BRW not only looks to reconnect all financial services stakeholders virtually but its platform will allow participants to continue the conversation well after the virtual conference is over. Revolutions happen over time but they start with sudden change. BRW will be that catalyst for change. Information about BRW can be found here https://bit.ly/2HYsla2 DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

How do you lend responsibly to a generation that is wary of credit? On the next episode of Clark Hills’ Credit Eco to Go, Carl-Alain Memnon, the Co-Founder and COO of Grain Technology, Inc. discusses how his new application (app) looks to solve that problem. Access to credit is a challenge for millennials and Gen-Zs. Rather than looking backwards, Grain seeks to obtain a more current snapshot of a borrower’s credit capability by offering reasonable lines of credit, similar to a debit card. The app recently graduated from the Arizona Fintech Sandbox where it beta-tested 30 borrowers. Grain looks to build long-term relationships with their borrowers while at the same time improving their financial health. Think of it like an “accountant in your pocket”. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Data is driving the expansion of financial services. But how do you build data sets that are unique for each financial institution? Scott Ferris, CEO of Attunely, Inc stops by Clark Hill’s Credit Eco to Go to dissect and demystify the world of big data. The goal is to achieve efficiency and effectiveness by giving machines access to the data so they can learn for themselves. Scott reminds us that data cannot solve every problem but historical data is a good predicter of future consumer response. “The financial services industry is just going through the same evolution that other vertical industries have gone through” when it comes to the consumer experience. Ensuring that the data is used in the right way and for the benefit of the consumer will be the key. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Contact centers and the technology providers who support the financial services industry were thrown into the front lines during the pandemic. Boris Grinshpun, General Manager of the CRM Group at LiveVox stops by Clark Hill’s Credit Eco To Go to talk about these challenges and experiences. These new and instantaneous set-ups have not only created better ways to manage and monitor call center employees and operations but it has also resulted in transformational ways contact centers are communicating with consumers. Communication channels are now being re-defined to not only follow the consumer but to achieve the same personalization the consumer expects as if they were in-person or speaking to a live person. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Credit access will continue to be a challenge for many consumers as the country navigates out of the pandemic. In addition to underwriting challenges, small dollar borrowers often have to work with financial institutions that are not capable of credit reporting. Elisabeth Johnson Crawford from Credit Builders Alliance (CBA) stops by Clark Hill’s Credit Eco To Go to talk about her organization’s partnership with Community Development Financial Institutions (CDFIs) which is enabling them to report these small dollar and micro loans to the credit reporting agencies. By assisting and training CDFIs with their credit furnishing activities, low and income borrowers are able to build positive credit and better credit access. As Elisabeth comments, “Credit reporting should be more than just reporting bad debt”. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

The financial services is a demanding practice area for attorneys. Client needs are constantly changing with fluctuating regulatory expectations. Dara Tarkowski, founder member of Actuate Law, shares her journey from lawyer to innovation strategist, by helping her financial services clients, not only with legal advice and counsel but with technology. Dara started Quiontec to incorporate technology into the delivery of legal services. Quiontec’s first product, ARM Communications Advisor, merges the most updated law and regulatory requirements into compliant disclosures and communications to consumers. Technology will never replace attorneys, but attorneys who practice in financial services will need to appreciate that technology can make them serve their clients better. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Amy Traub is the Associate Director of Policy and Research at Demos, non-profit public policy organization. Amy has proposed a Public Credit Registry to replace the established credit reporting agencies like Equifax and Trans Union. Her proposal was recently adopted by Joe Biden’s presidential campaign. On the next episode of Clark Hill’s Credit Eco To Go, Amy discusses the details of this proposal and how it would be implemented by the CFPB. Amy tells us that the goal is ultimately transparency but also to achieve more equity and accountability in the credit reporting process. A must listen for industry. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Nicole Kontrabecki has been general counsel to some of the most well-known fintech companies. On the next episode of Clark Hill’s Credit Eco To Go, the future of alternative lending takes center stage in light of the recent settlement by the Colorado Administrator of the Uniform Consumer Credit Code with Marlette Funding and Avant. Nicole highlights the significance of the settlement which puts into place the elements of what the legitimate fintech/bank partnership will look like going forward. This is a win for both industry and consumers. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Stewart Stockdale, Chairman & CEO Rellevate, Inc. stops by Clark Hill’s Credit Eco To Eco to talk about his company’s new payment platform that helps lower income and gig workers access financial services. 32 million people in this country lack a bank account or are underserved by their banking institutions. Rellevate’s mission is to provide consumers with access to their money at a fair price. A monthly subscription based service provides consumers with a variety of financial services including a checking account, bill pay services and earned wage advances. Rellevate sees themselves as a tool to improve cash flow and access to capital, something traditional financial services have struggled to provide for this portion of the population. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Nicholas Smyth, Sr. Deputy AG for the Pennsylvania Attorney’s General Office stops by Credit Eco to Go to talk about the Dodd Frank legacy on its 10 year anniversary. Nick was one of the architects of Title X which created the CFPB and he tells us that the Bureau’s impact can be felt today as financial institutions are better prepared for the potential economic crisis resulting from COVID-19. Nick is also the Assistant Director of the Consumer Protection Unit, the first such “Mini-CFPB” in the country and he discusses its impact upon Pennsylvania consumers and how other states, like California, will soon be following suit. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Bryan Filkey from PCMA stops by Clark Hill’s Credit Eco To Go to discuss the state of the mortgage lending industry. Dodd Frank established the qualified mortgage (QM), a safe harbor for mortgage lenders. Currently over 90% of the residential mortgage loans originated are not only QM but now are government-backed, leaving little room for the private lending market. Bryan also talks about the pending lapse of the QM-Patch, the implications that could have on the mortgage market as well as home prices and the CFPB’s proposal for a “seasoned” QM.DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

The OCC is expanding its footprint with the intended goal of being the regulator of choice for fintechs. Why are they doing this? John Barrickman, President of New Horizons Financial Group stops by Clark Hill’s Credit Eco To Go and provides some answers. John points out that the OCC’s universe is getting smaller and they are trying to find ways to stay relevant through funding and otherwise. The logical target is fintechs and the OCC is trying to create a symbiotic relationship by addressing the needs of fintechs with proposals for uniform licensing, standardized interest rates and a potential payment charter. However, John points out that the OCC’s primary competition at the moment is from state banking regulators, who are also developing their own licensing scheme and are pushing back on the OCC’s proposals. This tug of war will continue especially if there is a change in administration after the election. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Sheila Monroe, CEO of TrueAccord Corp, stops by the next episode of Clark Hill’s Credit Eco To Go to talk about the credit ecosystem from the consumer perspective. TrueAccord has been a disrupter in the accounts receivable management industry. Instead of viewing consumers as individual debtors, their approach has been to guide consumers through the life cycle in part by tailoring technology to customize outcomes as well as to build goodwill so consumers will ultimately succeed financially beyond the payment of a debt. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Small and regional financial institutions have always struggled with the implementation and development of regulatory compliance and risk models. Many lack the resources to incorporate technology into this process. On the next episode of Clark Hill’s Credit Eco To Go, Ryan Canin, CEO of Docfox, talks automation and the new technologies that are advantageous for smaller institutions. Ryan also discusses the new opportunities that may exist under the proposals being considered by the FDIC which will simplify and standardize the bank/fintech partnership.DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

In the age of COVID, digital payment systems became the life line for many consumers. Ed Bills, COO of PDCflow stops by Clark Hill’s Credit Eco To Go to talk about his company’s wholistic view of payment processing both as a delivery system and a customer engagement tool. Payments are only one part of the consumer interaction. Looking forward, Ed believes that payment platforms will need to be more configurable in order to ensure that consumers will have more control over their personal information. This will build trust, prevent fraud and provide the necessary security for all parties involved. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Rozanne Anderson stops by Credit Eco To Go to talk about the journey of reinvention. For years, Ontario Systems has been one of the leading providers of collection software to the ARM industry. In an effort to serve their clients better, Ontario has positioned itself to “see” opportunities much less “seize” them. In doing so, they became one of the few payment facilitators in the financial services industry. That reinvention not only solved a problem for their many clients but at the same time opened the doors for Ontario to serve a variety of verticals in the financial services space. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/