The MoneyPot

The MoneyPot LIVE: Fintech Under Scrutiny: The Wirecard Saga with Pav Gill and Jason Mikula

Rachel Morrissey, Sheryl Chen, Ian Horne, Micky Tesfaye

Whistleblowers and scandals. What really went on behind the scenes at Wirecard? This episode of The Money Pot, live from the Money 2020 conference in Amsterdam, features an exclusive interview with Pav Gill, the whistleblower who exposed the Wirecard fraud, and journalist Jason Mikula. Listen as we uncover the early warning signs that Pav Gill noticed, including suspicious financial practices and shady backgrounds of key personnel. The conversation takes on a surreal tone, with comparisons to infamous cases like Enron, and even elements straight out of a spy novel. Jason Mikula sheds light on the banking-as-a-service industry and the spectrum of ethical behavior within rapidly growing sectors.

We tackle the intricate dynamics of governance, fraud, and risk-taking within fintech startups. The line between aggressive business tactics and intentional fraud is often blurred, and we explore how the drive for innovation and profitability can lead to ethical compromises. We examine how venture capitalists influence board governance, the pressures on pre-profit companies to meet their KPIs, and the impact of national pride on oversight failures. The Wirecard scandal serves as a poignant example of how these factors can lead to significant fraud cases, creating a cautionary tale for the industry.

Regulatory gaps in the fintech industry present another set of challenges, particularly for companies operating outside traditional banking regulations. This environment fosters innovation but often lacks the necessary supervision to ensure consumer trust and protection. We discuss how different regulatory frameworks in Europe, such as e-money institution licenses, offer alternative oversight models. Potential solutions like creating a self-regulatory organization, similar to FINRA, are also considered. This episode offers valuable insights into the ongoing developments in fintech and highlights the importance of robust governance and regulation. Join us for this compelling discussion with Jason and Pav Gill, and stay tuned for more updates on the evolving fintech landscape.

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Rachel Morrissey:

Okay, welcome to the Money Pot. I'm Rachel Morrissey. I'm one of the co-hosts of the Money Pot here at Money 2020. And we are here live at the Money 2020 conference in Amsterdam. I've got my host here, Mik Tesfaye. How are you doing, Mik?

Micky Tesfaye:

I am fantastic, Rachel. We are back in Amsterdam once again.

Rachel Morrissey:

We are and the show looks really cool. I can't wait for you guys to see the show.

Micky Tesfaye:

I've been super excited that we even have Money Pop branded mics. I know Wow.

Rachel Morrissey:

We're going to have to put pictures of this everywhere.

Micky Tesfaye:

Yeah, for sure.

Rachel Morrissey:

So we have two amazing, amazing guests. We're going to have a really fun conversation here today because we've got Pabgiel here, who is the whistleblower for the Wirecard. What do we call that? Fiasco Scandal?

Micky Tesfaye:

Story.

Rachel Morrissey:

Story. Are we trying to be nice ?

Micky Tesfaye:

I'm trying to be like the.

Rachel Morrissey:

Wirecard story, and we have Jason Mikula, who is here because he's been doing some amazing coverage of what's going on with Synapse and Evolve and a lot of the other things that are happening and how that's all intertwined, and so we're going to be talking today a lot about the nature of what's going on and whistleblower culture, how we think about some of these things and how they're going to affect the industry, the nature of how this makes us look at what's going on, particularly in banking as a service industry. And so I'm going to turn it to Mickey first, because he's going to be driving this discussion.

Micky Tesfaye:

Thank you, R rachel. Yeah, I mean, I think you know when you and I were speaking. I think part of the thing that was super exciting about having Pav and Jason on is, to a degree, there is a part of a story there around what's going on in fintech, how much progress we've made, how much are these two things, these two stories that happened five, six years apart? Are they part of a spectrum or are they different things, Right? So I guess maybe a good starting point to anchor us in the conversation is to turn to Pav. Thanks for coming from all the way from Singapore to join us as well. And maybe I just want to ask you, I guess, to start off with when did you kind of first realize things were amiss when you joined Wirecard, and how long did that take?

Pav Gill:

Yeah, that didn't take very long. I mean, if you looked at any of their subsidiaries financials, they were all loss-making, so no one understood where the money was coming from. I mean, the sales team was definitely very happy because somehow, you know, numbers were up and they weren't really selling much. So yeah, just from an objective reading of financials, 95% of the company was in the red.

Micky Tesfaye:

And it was just like instantly. You were like as soon as you kind of, because you went in as part of the legal team and I guess you're kind of looking at all of the paperwork and maybe even accounting data, and then it was just very visible to you immediately and did you have to start thinking about how to act very immediately too.

Pav Gill:

Yeah, it was strange because I was told to get to know the guy that was running finances. His name was Ido. He's an Indonesian chap with a dubious background. Cv-wise.

Rachel Morrissey:

That's always a good sign. Dubious background CV You're always looking for that when you're coming to a payments company.

Pav Gill:

One of his first few introductions to me was that he's married to a drug dealing family in Jakarta which has the red flag as it gets for.

Rachel Morrissey:

NFI.

Pav Gill:

I mean, he was super flexible with numbers, to put it mildly.

Micky Tesfaye:

I don't know if that's what you want from your accountant right, that kind of flexibility?

Rachel Morrissey:

Super flexible Until you get to your tax account.

Micky Tesfaye:

No, I'm kidding.

Rachel Morrissey:

That is hilarious. I love that.

Micky Tesfaye:

I mean, okay, it sounds like yeah, very instant.

Rachel Morrissey:

Well, and the other thing about the Wirecard thing is, the more people dug into it, the more kind of absurd it became that people didn't realize this faster. I mean I think back on previous scandals that sort of resembled it. I mean I know it was compared to Enron a ton, and it had a lot of echoes of that kind of a group of people that had some dubious backgrounds. So you're like how did these people convince anyone this was a good idea? And then, uh, and then the stuff on wirecard that broke about possibly a russian spy, and you're just sitting there going. This could not get any more. I mean, this is made for a movie. I can.

Micky Tesfaye:

Can't wait until the movie comes out. I mean Netflix were licking their lips when they saw the story breaking live, I think. And I remember, like you know, I was an analyst at Business Insider and I remember reading the story on the FT being like this is the most surreal story to read on the FT, because it's like a spy novel.

Micky Tesfaye:

I'm like you know, jan, and so before I go to that, you know I'm gonna go to jason with a question. I've set you up with it. I know it might not be like that, but I mean you've been in the news yourself lately, which I think is probably interesting. As a journalist as well you've been, you know a big part of what's going on, uncovering those stories. Are you seeing any similarity with what's going on in the banking as a service industry where there is fraudulent practices, or is it more to do with just an industry that's growing and there are missteps that occur naturally?

Jason Mikula:

Yeah, I mean, I think in any industry you're going to have a spectrum of sort of how ethical or how morally and legally some of the players act right. So, whether you're talking about tech broadly. We have plenty of examples Theranos, which was an outright fraud, real estate I'm thinking specifically of WeWork, which was not a fraud per se but was kind of a ridiculous situation, which I watched all of the Hulu and Netflix and whatever.

Rachel Morrissey:

I know you watched all of the documentaries.

Jason Mikula:

I think there was like two or three different ones, and my partner and I excitedly watched all of them.

Rachel Morrissey:

Yes.

Jason Mikula:

And so I think you know there's no difference in banking as a service right or the banks that partner with those middleware providers and fintech companies.

Jason Mikula:

I think, you do want to be careful about painting with too broad of a brush and saying. There's a risk of saying, oh, this entire model doesn't work, everyone is a bad actor. We should just clamp down on this. I think that would be a mistake from a public policy standpoint because there are benefits both to the banks that work in this sector as far as having a viable business model as things move away from geographic banking to more digital, as well as to consumers who use these products. If you look at a lot of what fintech in the US is, it is very geared towards consumers who have not been well-served by establishment banks. Think of Chime and Vero and some of these earned wage access or cash advance kind of things. If you clamp down on everybody, there are consequences to that. To try to specifically answer your question, I think in the Synapse case, there's a lot of unanswered questions about what happened here.

Rachel Morrissey:

Yeah, we're in the middle of that here. Yeah, we're in the middle of that. Yeah, we are in the middle.

Jason Mikula:

I've been very careful in how I write about it to try to highlight, you know, what a lawyer says in a court filing, or what a lawyer says in court is a representation. It is not a fact, right. And so we have, you know, evolve, saying one thing, synopsing something else, and even as well-informed outsiders, I don't know what's true.

Rachel Morrissey:

Yeah Well, and you can't. The other thing that's interesting here to me is okay, so we have Wirecard, we're talking about some stuff that's going on right now that we're in the middle of uncovering. We're not actually sure about whose story is actually pitching out, and it could be somewhere in the middle, right in all probability. And then and then we've had other scandals that have happened.

Rachel Morrissey:

Um, and I'm I'm kind of curious because I sort of think I wonder a little bit about the um, the exception proving the rule. Basically, I mean, we could paint the whole industry with a broad bush, but maybe the fact that we did, we were able to fish out a possible problem or a possible bad actor. It may not be an indication of the business model itself, but just that there are going to be bad actors in every single sector. There are going to be people that take advantage of these notions of innovation to kind of capitalize for themselves right away. I mean, the Wirecard one sort of proves that the payments industry has got tons of actors. You know lots of people that are very good and very well regulated and their books are clean, and it's not an either or right. So it sort of was an exception to prove the rule because it made the news.

Pav Gill:

Yeah, I mean, that's true, and a lot of times you can put as much regulation as you want, it doesn't work because you know, at the end of the day, you still rely on people to adhere to those regulations right and at the same time, you also rely on people to tell somebody that you know someone else is not following those regulations right so I think that's where the balance lies and that's where I think companies need to also think about things, because, you know, just because something bad is happening, it's not going to mysteriously disappear on its own right.

Pav Gill:

Someone also needs to, you know, confront that and deal with it in a sensible way.

Rachel Morrissey:

And that actually. So when you guys are looking at these stories right, I mean you're from the journalist perspective. You were inside and going. I've got to get this story out. I've got to figure out who to tell. How did you figure out who you were going to tell?

Pav Gill:

I mean I did and my mom did. Mom for the win. That's where the difference is. And I think also, I was forced into a whistleblowing case because when I was in the company as the head of legal for the Asia-Pacific region, I was actually instructed to investigate an internal whistleblower that came to me. So that's what I was doing. I was actually doing my job. It's just that when the board found out, they were very upset and we know why.

Micky Tesfaye:

So you were actually hired to find out who is a potential whistleblower by wirecard.

Pav Gill:

I was already in the position of being the legal person in apex yeah, someone came to me from the finance team, fearing for her life, and so I was supposed to investigate it and protect that person's identity.

Pav Gill:

so eventually the board found out, they tried to shut it down. They did all kinds of stuff over three, four months to, you know, try to damage me. And eventually they even tried to kill me by sending me on a attempting to send me on a one-way ticket to Indonesia which I didn't go for. So that's when the company finally, after four months, had a legitimate reason to say okay, he did not follow instructions, so we can finally fire him, which is great. So I said, okay, Wirecard, you enjoy a fraudulent ways, I go find another job. But they didn't stop. They were still sending people to follow me and my mom and all that stuff. So that's when my mom got really upset, because she's a single parent and I'm the only child. And that's when she decided, from the sofa of the living room, to reach out to journalists. And one day she just told me hey, by the way, we're meeting the Financial Times this weekend and I was like what are you doing?

Micky Tesfaye:

Wow, mum for the win.

Rachel Morrissey:

This is my favorite whistleblower story ever.

Jason Mikula:

It makes me want to go scrub my address off anything on the internet ever.

Micky Tesfaye:

This is a warning for you, jace. I mean this story. I have to say I'm sorry, but this is truly a story like stranger than fiction Because again, I remember reading it and you're thinking FinTech is not. You know, fintech is FinTech. I mean, how dark can it get? And I'm just like where is this going to stop?

Jason Mikula:

I think that this illustrates sort of the most extreme end of the spectrum of intentional fraudulent behavior.

Jason Mikula:

But there's also a whole lot of gray area of I learned this working in the lending side and the banking side what sometimes feels like black and white from a legal or compliance perspective, when you're actually working in those roles you realize most of it is actually a gray area where it's like, well, your advice from counsel is X, but if you're comfortable taking that risk, you can do it. And it makes you wonder how many of these situations is it intentional wrongdoing versus incompetence, versus an overly aggressive business posture?

Pav Gill:

Something.

Jason Mikula:

Pav mentioned that I think is very relevant to the entire startup space is board governance. I think the VC attitude has shifted a bit, but for a long time the emphasis particularly when VCs were competing for investments was to see how founder-friendly can you be? And if the founding team, the CEO, has control of that board, there's not a ton. Even if VCs have a board seat, they might have visibility, but they may not be empowered to actually do much of anything, and so there's a legitimate governance question here as well.

Micky Tesfaye:

And I think that piece is super interesting because it does turn around. The idea of a board is to be the governing institution for a company, but I think the VC model has kind of turned it around where, as you said, founders are now because VCs, because they want to kind of secure the founder where there's a lot of competition. It's actually all about how can we get that, see, how can we have control, and that's really reflective of where we have been as an industry.

Rachel Morrissey:

Right the, for a couple of years their vc money was flowing. There was a lot of competition actually amongst vcs with to get certain founders right. So as money has tightened and now there's more competition for the money, there's a lot more of a flip of the founders having to compete for the VC money. That kind of changes the nature of that too and what you can do for that board of governance and how much influence or control you can assert right from the beginning. I think one of the things that you mentioned there is you know, you can do certain things if you're willing to take on the risk right. So, and in an industry that encourages innovation, that encourages this idea, risk-taking is sort of part of the formula. You can't people will tell you you can't be a successful entrepreneur if you're not willing to take risks. And that's where the area gets super gray because you're taking risks in certain areas.

Rachel Morrissey:

So when your legal team or your board of governors comes, in and says you can't take those kinds of risks, or you shouldn't take those kinds of risks, but your whole drive and you've been rewarded basically for being somebody who takes risks. You're less likely to take that to heart, I think.

Jason Mikula:

Well, and something I would point out again, particularly about sort of venture-backed startups, is almost universally these are not profitable companies, and so the time horizon and the risk tolerance can be very different than a mature, large private company or public company, because if you're operating in the traditional 18-month VC fundraising cycle and you know I have to hit certain targets so I can put it in this pitch deck and go back to investors and raise more money, otherwise it's all over.

Jason Mikula:

you have a lot of pressure and a lot of incentive to all your stakeholders, your employees, your existing investors, which might include friends and family who invested early on. There's all sorts of pressure and all sorts of incentives to make sure that you're able to show those KPIs and go raise more money, because otherwise the party's over. To try to be a little empathetic, it's understandable how that might engender some questionable behavior.

Micky Tesfaye:

Especially because I think, as you mentioned, a lot of it is pre-profit, a huge amount of it is predictive right. So a lot of it is up for debate really and truly, and I think that's the challenge. I guess one of the things that I'm thinking about with wirecard again, um, to your point, pav is what we were discussing earlier, and how much of the wirecard situation do you think is also a result of the broader way in which fintech, and even in europe and germany, wildcard was a real success story. It was built up. You know, I think a lot of it and there's my opinion to you right a lot of it was kind of made it bigger than it would have been, because I think at some point it was as big as deutsche it had a bigger valuation than deutsche bigger valuation, and it was, I think.

Micky Tesfaye:

So I wonder as part of it, did you? Do you think part of that was to do with just this desire for Germany, as well as a country, to look like, hey, we're also a big fintech player. There's this kind of desire to get payments as an industry, to be a big player. There's also there was a weird desire to have companies really competing with banks and established players, without always necessarily thinking about the underlying piece. Do they have all the things in place? How much do you kind of?

Pav Gill:

for sure. Uh, wirecard was like the paypal of germany right and 24 billion market cap is not a small amount, uh.

Pav Gill:

So I think there was a lot of pressure to not want to look to some extent. And the argument is strong. I mean, if you're a company, you're doing all these fraudulent things, you're telling investors why are you whining? I'm making you money? Telling everyone else, like, do you want to listen to random people saying we're doing bad stuff, or do you want to look at the big four that just signed off on our audit, right? So who do you want to look at? The big four that just signed off on our audit, right? So who do you want to listen to?

Pav Gill:

And we've been growing for 20 years, we are listed, we've got due diligence requirements on us, so how could everyone in the industry be wrong, except for a few people that are saying we're doing bad things? And I think, going back to the earlier point as well, from an executive standpoint, like a CEO standpoint, there is a very strong tendency to not want to hear bad news, especially if you're in a very successful company. So you could be the CEO that tells everyone I don't want to hear bad news, I don't care how you do it, just give me the numbers and hit the targets. So that kind of instruction and mentality might be taken the wrong way. That look, we don't want to disappoint the boss, we don't want to disappoint our superiors. We've got KPIs, we've got OKRs to meet, let's just do it.

Jason Mikula:

I mean, I think it's really easy to ignore red flags when everyone is busy counting their money right. I mean out of industry, and I'm not saying that this company is fraudulent, but I think Tesla is the perfect example of it right when it's like well, look at the market cap and Elon Musk says, well, if I'm doing drugs, I should keep doing it, because all the numbers are going up and it's just like a complete abject.

Rachel Morrissey:

I don't know if that's the lesson to take away from this. Drugs are good.

Jason Mikula:

But just a complete and abject failure of board governance, because everyone is too busy counting their own money.

Micky Tesfaye:

That's such a good point too. I think you can't be doing due diligence only when things are bad. Right, due diligence needs to be consistent across the board. I think that's a really good point. I guess the's a part of the narrative, right, if you kind of take some of that at face value, where it wasn't necessarily fraudulent from the beginning but it was like a slippery slope and how much of the wire card story I know you started.

Micky Tesfaye:

You told us there's red flags from the beginning, I know, but I wonder how much of that was, you know, partly not necessarily big planned out fraud, right, but a slippery slope. And how much of that was, you know, partly not necessarily big planned out fraud, right, but a slippery slope. And how much of we've been? You know, we talk about um, svb or even some of the stuff that's happening in banking as a service where you don't necessarily always need to be doing intentionally fraudulent activity, right, sometimes just by mistakes, and then by not looking, by not wanting the bad news, by looking away, and then you kind of start fostering that culture. How much of it are we?

Rachel Morrissey:

or you're fostering a culture of overly creative solution.

Micky Tesfaye:

Yeah, flexible accounting what I mean.

Rachel Morrissey:

I think that people are like if I can delay the bad news, right, if I can, I can find a way to fix it before it's a real issue. And then they get caught in the middle of fixing it right, and I think that there's a certain amount of that going on. So it doesn't have to always be nefarious. I think Wirecard seems pretty nefarious.

Micky Tesfaye:

The Wirecard one yes.

Rachel Morrissey:

The others. I think you're right, yeah.

Pav Gill:

I mean from a fintech standpoint, and also crypto. The issue with these industries is that regulation is always playing catch up. You can't keep up with the tech. Even banking as a service is one of those same things as well. So when that happens and a fintech is getting a lot of easy money, it's showing profitable numbers or good numbers. There's a lot of tendency to use the same argument which Wirecard also used for 20 years, which is we are a victim of our own success. Can you please give us time? These regulations are coming up here and there. We know we need to invest in corporate governance, in legal compliance and risk, but just bear with us. We are a victim of our own growth. So I think a lot of companies, including FTX, for example, they were playing that same card. It's really cops and robbers in that way.

Jason Mikula:

I think a common thread in a lot of these stories is the tendency to say no, this company is different because it's doing something special and innovative. That was definitely part of the FTX story, Sort of presenting no, you don't understand why this company is so special and so profitable. It's new, it's complex, it's innovative. You just don't get it. I feel like there was a kind of similar sentiment around Wirecard versus some of the more legacy players in the payment processing space, and we also see that in banking as a service, maybe to a lesser extent. It's like no, no, no, you just don't understand the business model. That's why you're so skeptical. I think that should probably be a red flag.

Rachel Morrissey:

I can't understand the business model. You just don't understand it, maybe that is a flawed business model I mean it should be explainable.

Micky Tesfaye:

I've lost my headphones because of how excited I've gotten.

Micky Tesfaye:

This is a great conversation, but let me both ask you, jason and Pav, because one thing I keep on thinking about is, as an industry, how much are we responsible in terms of the language we use and the way we think about things like regulation? Right, like in tech broadly, the idea of break things move fast and in some areas of tech, of course, we've seen where there's results as a result of that, you know for lack of a better word, but I wonder, within financial services, given the impact of it, given you know how much it could transform people's life, when you've got money locked up in ftxy I got all of these things people you know could lose their lives, even right. How much should the industry as a whole be responsible in the way we think about the language and the way we even talk about regulation, as because regulators a lot of the time maybe I feel a little bit bad for them. We're like how the hell is it? Should we be kind of like, hey, we might need to?

Jason Mikula:

I don't think it's a coincidence that a lot, particularly in the US market, a lot of what you've seen in fintech exists outside of the banking regulatory perimeter. On the one hand, I understand that in the sense that it is arguably easier to innovate outside of a bank than inside of it, for a lot of reasons.

Rachel Morrissey:

Or any company. Sometimes it's just easier to go outside and just innovate. That's just true of companies.

Jason Mikula:

But on the flip side, that also means there is a specific lack of supervision. So, using the Synapse case as an example and to illustrate some of the end impacts of that, users of these products that were built on Synapse companies like Yotta, which is kind of a neobank, juno, which was kind of like crypto plus a neobank they saw websites and app store pages that said FDIC insured. Your funds are held at Evolve Bank and Trust and one of the things I think the Western banking regulators, including the UK, and Netherlands but also the US have been very successful in doing is as a consumer, you don't have to worry about where you put your money.

Jason Mikula:

You could put it at JPMorgan Chase, or you could put it at local rando credit union.

Rachel Morrissey:

Anything that's got that logo, that label on it.

Jason Mikula:

And you don't have to think about is my money going to be there when I need it, to pay for this wedding, to pay for university, whatever? That is a big success. That is not true in every country, however. The flip side of that is, I would argue, that fintechs, again particularly in the US context, have unfairly benefited from that trust. And so somebody thinks well, if I leave my money in Cash App or Venmo, or if I use Yotta, it says FDIC insured, so I'm fine, it's safe. And what we've learned is that is not the case. And for those end users who don't understand what is deposit insurance, what does it protect me against? They're understandably frustrated and angry and want answers because they think the government, the FDIC, is here to protect me. And again, in this specific case, the Federal.

Jason Mikula:

Reserve Board, which regulates Evolve, gave a statement that was basically this is not our problem.

Rachel Morrissey:

Like you said, that is a success story, right? People misusing that. It's hard to always govern, like it's hard to always check on how people are misusing it, because we get very creative with our language and we say things that are half true.

Jason Mikula:

As a recovering marketer, I've been on the other side of it. What is the furthest?

Pav Gill:

I can push this without legal implication.

Micky Tesfaye:

Without giving Pav like oh stop.

Rachel Morrissey:

Before Pav goes the line is behind you.

Pav Gill:

No, the irony is that I'm a lawyer, so I could be coming up with these.

Micky Tesfaye:

He's like this is how you do it.

Rachel Morrissey:

Exactly. So you come up with the exception phrases that allow for you to do this kind of thing, and I think this is where the industry itself has probably got to worry, because, as you're saying're saying, fintech has benefited from this, whether they actually have that guarantee or not, and things like Synapse, things like Wirecard these are not necessarily indicative of how the industry as a whole runs, but it does give people a picture or allows people to paint with a broad brush, as we were talking earlier about the industry as a whole. And so what do you think the industry? Is there anything that the industry should be doing, that sort of pushes back on that and says, no, we should have some practices or we should have some things that are accepted that allow for us to you us to be more careful here.

Pav Gill:

Yeah, I mean, I spent three years in the crypto space before I founded Confide and I saw the exact industry issue there. So everybody was pro-crypto at some point. They're like let's move away from banks, let's get rid of the middleman, let's just go into crypto. And then we saw how crypto played everybody out for one and a half years, including the industry, including consumers and the effect of that was ironic because it went the other way. People started saying, okay, maybe we just can't trust these companies. Let's go back to banking.

Pav Gill:

Let's go back to putting money in deposit accounts or under our mattresses or something. There's legitimacy that comes with it.

Jason Mikula:

I would think to try to also include the European context, since we're sitting here in Amsterdam Having thought a lot about how things work in the US versus how things work in the UK and Europe. I do think one of the big differences and improvements is these alternative kinds of licenses. So e-money institution, payments institution. So if you're a BAS operator, I'm going to be in this podcast booth tomorrow talking to Swan.

Jason Mikula:

Swan has an e-money license, so it is a directly regulated, supervised entity on its own, and then it supports embedded finance for its customers. In the US context, the regulators, specifically acting comptroller Sue, has been very clear that there's going to be no fintech charter forthcoming. They're not going to bend the rules to try to entice fintechs inside the regulatory perimeter, and so a lot of these companies Synapse with an asterisk, because I owned a broker-dealer, which is weird but for the most part, these fintech companies middleware exist outside of that regulatory perimeter. They don't have anyone directly supervising them, and that does create these kind of gaps. Now, what are possible solutions? I've been talking about this with Simon Taylor, who I think is running around here somewhere. Is there an opportunity for something like a FINRA, like a self-regulatory organization? I think there's possibilities. None of them are simple, surely?

Rachel Morrissey:

No, none of them. Well, this has been an amazing discussion. We have run out of time, which is always these favorite words of any podcaster, but I want to thank you guys so much, jason and Pav, for being here with us today. This has been amazing. I'm sure we'll keep talking in other instances about all of this and what's going on. This is going to be an ongoing story with Synapse for a while. I don't think that's going to stop anytime soon. We'll probably be talking about it in October for the next 2020.

Micky Tesfaye:

Probably and you might need to start using Confide for some of your whistleblowing.

Jason Mikula:

Yeah, I might. I'm on like a single channel so I'm going to have to check out Pound Startup.

Rachel Morrissey:

Okay, so thanks to all of our listeners, you can find us on the Money 2020 website and you can find us wherever you listen to podcasts. We love our fintech nerds.

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