Episode 7

Navigating eCARs: A Compliance Opportunity

In this episode of The KYC Podcast, host Greg Dent is joined by Zahra and Catagay from the ReallyTrusted team to discuss the intricacies of the Electronic Compliance Assessment Report (eCAR) - a crucial tool used by FinTRAC to assess compliance with anti-money laundering and counter-terrorist financing regulations. The conversation delves into the purpose and structure of the eCAR, the types of questions it encompasses, and the potential challenges reporting entities may face when completing this assessment. Importantly, the hosts highlight the opportunity the eCAR presents for proactive compliance, emphasizing the benefits of honesty and transparency when addressing any identified deficiencies.

Key Takeaways:

  • eCARs are electronic questionnaires used by FinTRAC to evaluate the effectiveness of reporting entities' compliance programs and identify potential risks.
  • The questions cover a wide range of topics, including business practices, transaction types, and the five pillars of a compliance program.
  • Challenges may arise if the compliance program is not well-documented or if there are gaps in policies and procedures.
  • Honesty is crucial when completing the eCAR - voluntary disclosure of non-compliance can be a valuable tool to address deficiencies.
  • FinTRAC generally prefers a collaborative approach, providing opportunities for reporting entities to remediate issues and improve their compliance posture.

Resources:

  • Contact the Really Trusted team for guidance on navigating the eCAR process and strengthening your compliance program.

Connect with Greg and ReallyTrusted at:

https://reallytrusted.com/

https://www.facebook.com/ReallyTrusted/


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Transcript
Greg Dent:

Hello and welcome to another episode of The know your

Greg Dent:

compliance the KYC Podcast. I'm super excited today to have

Greg Dent:

Zahra and Cagatay from the Really Trusted team, joining me

Greg Dent:

to talk about ecars or shrax. Doesn't have go as well. But the

Greg Dent:

the what might be the first phase of heading towards an

Greg Dent:

examination. So before we get into it, let me give you guys

Greg Dent:

each an opportunity to introduce yourself. Zahra. Who are you?

Greg Dent:

What do you do?

Zahra Sunderani:

Yeah. So I'm Zara. I am the anti money

Zahra Sunderani:

laundering operations here with really trusted I have experience

Zahra Sunderani:

in like the FinTech, bank, credit union realm now real

Zahra Sunderani:

estate, and then soon to be mortgage broker. And, yeah, I

Zahra Sunderani:

just am excited to talk about this, because we've seen an

Zahra Sunderani:

uptick in it. So that is me chatting. What about you? Well,

Cagatay:

yes, the program lead for the finch space program. So

Cagatay:

basically all our friends out there who have already had their

Cagatay:

face to face meetings with me. Know that I create your

Cagatay:

compliance programs and ensure that your FinTech obligations

Cagatay:

are put in place, etc, and hence I'm always here to have help

Cagatay:

lending hand for you guys.

Greg Dent:

Awesome. Thank you so the the supervisory risk

Greg Dent:

assessment questionnaire, srac, or the ecars, which actually,

Greg Dent:

does anybody remember what ecar stands for, electronics

Greg Dent:

compliance assessment report? Ah, thank you, sir. All right.

Greg Dent:

Or ecar, depending on on what you get, they're essentially the

Greg Dent:

same thing. First of all, those two sets of abbreviations. But

Greg Dent:

Cagatay, can you give me, like a Cole's notes on what that is?

Greg Dent:

Let's start there.

Cagatay:

Yeah, exactly. So as you know, Finch rack is the

Cagatay:

regulatory body for all AML CFT issues in the country, and hence

Cagatay:

everybody needs to abide by those rules and regulations. And

Cagatay:

what the E car is actually is a tool for to ensure that the

Cagatay:

regulator entities are complying with these regulations. So, as

Cagatay:

the name suggests, they're electronic questionnaires, and

Cagatay:

Finch, once they forward these and request them to be filled,

Cagatay:

that has the opportunity to ensure they are able to assist

Cagatay:

the victim. This are the regulated, regulated entities

Cagatay:

compliance program, and also try to understand whether they can

Cagatay:

identify any potential risk in terms of money laundering or

Cagatay:

terrorism financing.

Greg Dent:

Yeah, and I think the lens that I would look at the E

Greg Dent:

car, slash, let's call it an E car, because it flows off the

Greg Dent:

tongue easily for today, the lens that I would take these

Greg Dent:

electronic things from is that, much like your FINTRAC

Greg Dent:

compliance program should be risk based, this FINTRAC uses a

Greg Dent:

risk based approach as to when and where to do further

Greg Dent:

examinations. And I think the way I would look at it, this is

Greg Dent:

their first filter that they might apply is to decide whether

Greg Dent:

to go deeper or not, with your bro, with your with your

Greg Dent:

business, with your reporting entity. So as you start to see

Greg Dent:

this questionnaire, is there what what would be like some

Greg Dent:

really high level, broad things that I think would be important

Greg Dent:

for our compliance officer reporting entity to to start to

Greg Dent:

consider, I

Zahra Sunderani:

mean, just with regards to what they would see,

Zahra Sunderani:

something that they would see in the E car, yeah,

Greg Dent:

maybe, actually, you know, you're right, maybe we

Greg Dent:

should start by describing the questions and the lay of

Greg Dent:

questions that they're going to get. Let's, let's go with that

Zahra Sunderani:

first. Yeah, yeah. So, yeah. I mean, just as

Zahra Sunderani:

a basic they generally use Canada Post for information

Zahra Sunderani:

sharing, just with regards to just some of the recent hacks

Zahra Sunderani:

we've seen. So not a bad thing that they're choosing to do that

Zahra Sunderani:

kind of thing. But anyway, so it would be through Canada Post.

Zahra Sunderani:

And so if you get an email or something like that, don't,

Zahra Sunderani:

don't worry, it's not out of ordinary. But then the type of

Zahra Sunderani:

information that they would be asking for, basically, is just

Greg Dent:

sorry before you join to us by Canada Post, you mean

Greg Dent:

the electronic Canada Post, not the to your door Canada Post,

Greg Dent:

but carry on. Sorry,

Zahra Sunderani:

absolutely. It is not by paper. It is, for

Zahra Sunderani:

sure, ecart electronic. Yeah, thank you for considering that.

Zahra Sunderani:

So it would be kind of like either a PDF document or an

Zahra Sunderani:

Excel, and they would be asking you about your business, just

Zahra Sunderani:

your organization in general, specific to how your business

Zahra Sunderani:

practices are, like, what, what you know, types of transactions,

Zahra Sunderani:

that you accept, agents, very, very basic questions that you

Zahra Sunderani:

would be able to actually answer, just based on what you

Zahra Sunderani:

know about your business. And then the other types of

Zahra Sunderani:

scenarios. And then there's also a part of of it, which asks

Zahra Sunderani:

about your compliance program. These are all questions that are

Zahra Sunderani:

based off of the five pillars that they actually give as

Zahra Sunderani:

guidance for the real estate entities and brokerages to be

Zahra Sunderani:

able to comply to FINTRAC. So they're going to be asking

Zahra Sunderani:

various questions. Questions about, yeah, I mean, what type

Zahra Sunderani:

of transactions you accept, who you do business with, geographic

Zahra Sunderani:

risks, various things. But these, these questions are going

Zahra Sunderani:

to be ones that will generally be in your policies and

Zahra Sunderani:

procedures, if that's something that you have in place already,

Zahra Sunderani:

and so, depending on where your compliance program is these

Zahra Sunderani:

types of questions could be very, very easy, and then on the

Zahra Sunderani:

opposite side, they could also be slightly challenging,

Zahra Sunderani:

depending on where you're at with your compliance program.

Greg Dent:

So couple of thoughts for that come out of that. I

Greg Dent:

think, as you're completing this, it's, I think, I think to

Greg Dent:

go some to kind of go further into something you just said,

Greg Dent:

everything that's in here should be written in your compliance

Greg Dent:

program should be in there. Like, I just think that if you

Greg Dent:

have a good set of program, policy, procedures, risk

Greg Dent:

assessment, the answers to, okay, so the operational answers

Greg Dent:

to your questions might not be in there, but the policy side of

Greg Dent:

the questions should be in there, and you should be able to

Greg Dent:

point to where in your documentation these are. And as

Greg Dent:

a best practice, my tip on this would be that that's exactly

Greg Dent:

what you would do now, as you're doing that, what are i What are

Greg Dent:

the things that we've seen people are really struggling

Greg Dent:

with? Can What Are either of you guys have feedback on where

Greg Dent:

they've really where people have struggled with the with the SAR,

Greg Dent:

with the car questions?

Cagatay:

Well, I've seen in the questionnaire that basically, of

Cagatay:

course, this basically pulled down many on, you know, whether

Cagatay:

the various scenarios that they have asked Where have happened

Cagatay:

or seldom happened or never happened. So those are cool down

Cagatay:

menus. So in that regard, I don't think there is any issue

Cagatay:

for anybody to answer them, but perhaps more difficulties may

Cagatay:

come up in regards to the compliance program questions

Cagatay:

itself, hence they need to have a good understanding of exactly

Cagatay:

as just duly pointed out, as what the compliance program is

Cagatay:

actually covering. And in that regards, you know, you have all

Cagatay:

sorts of things like payment methods accepted your business

Cagatay:

and, etc. There are sanction controls, etc. You're reporting

Cagatay:

requirements, etc. You're doing this. You're doing that. I think

Cagatay:

French rack here is basically trying to understand, you know,

Cagatay:

do you have a grasp on your policies and procedures, or just

Cagatay:

or it's just a pretty document that's sitting at your brokerage

Cagatay:

on your desk, kind of thing? So, so it's basically, you need to

Cagatay:

have a good grasp on this. You need to understand what these

Cagatay:

registered requirements entail. And hence, then just go with the

Cagatay:

floor in regards to answering these questions, go

Zahra Sunderani:

and, and I think I was also, I just just to

Zahra Sunderani:

tail on to that with the other part that I think some people

Zahra Sunderani:

have challenges with is if they feel that their compliance

Zahra Sunderani:

program isn't well rounded off. And so even, even if they

Zahra Sunderani:

they're trying to answer these questions, they don't know how

Zahra Sunderani:

to and it's only just because they might not have policies and

Zahra Sunderani:

procedures in place, or they might not have gone through a

Zahra Sunderani:

risk assessment, or whatever the instances, and in those

Zahra Sunderani:

instances that can become a little bit difficult. But yeah,

Zahra Sunderani:

so it's, it's it's good. FINTRAC is doing their due diligence to

Zahra Sunderani:

figure out what the brokerage what stage they're at, really,

Greg Dent:

I actually just thought of something as we've

Greg Dent:

been talking this through that I think is interesting when, if we

Greg Dent:

think about a formal examination, that process starts

Greg Dent:

with a call, right the the fintra, FINTRAC phones, the

Greg Dent:

compliance officer says, Hey, we are beginning in an examination

Greg Dent:

of your business. You'll be receiving a letter detailing

Greg Dent:

what we need to see. You have 30 days to respond, etc, etc. The

Greg Dent:

interesting thing is that this is not a formal examination, and

Greg Dent:

where the opportunity is is if you are looking through this and

Greg Dent:

you realize you have a deficiency. FINTRAC has a

Greg Dent:

process for that. You have what's called a voluntary

Greg Dent:

disclosure of non compliance. There's a C at the end of that.

Greg Dent:

No, no, that's right, voluntary disclosure of non compliance,

Greg Dent:

VD, noc, process where you can self disclose that you have some

Greg Dent:

sort of a deficiency. I think the opportunity when you use

Greg Dent:

these ecars properly, if you're feeling like you have a

Greg Dent:

deficiency, this might be what causes you to realize you have a

Greg Dent:

deficiency, which be the greatest get out of jail. Free

Greg Dent:

card, by the way, when done properly, How's that for an

Greg Dent:

opportunity out of what might be an initially scary process,

Greg Dent:

thoughts on that?

Cagatay:

Yeah, I think you're pointing at a appropriate thing

Cagatay:

here. It's a good approach. But on the other end. Shouldn't be

Cagatay:

a, as you mentioned, that the jet Get Out of Jail Free card

Cagatay:

thing. I think it shouldn't be just the easy way out.

Cagatay:

Nevertheless, no, yeah, because eventually the legislative

Cagatay:

requirements are important, etc. And FINTRAC is, I think when

Cagatay:

they first make this contact and they want the E car

Cagatay:

questionnaire to be filled out. They want to ensure that the you

Cagatay:

know the business does understand its risks. What is

Cagatay:

doing to mitigate those risks, etc. And hence, all the answers

Cagatay:

properly compiled in that questionnaire are reflecting

Cagatay:

upon the knowledge awareness of such legislative requirements.

Cagatay:

So I they never come an instance where this volunteer disclosure,

Cagatay:

etc, you know, has happened, at least in my past experience,

Cagatay:

etc. And hence, what the consequence would be for the

Cagatay:

business eventually, when Finch wreck receives such a thing,

Cagatay:

exactly. But nevertheless, it's beneficial, of course, because

Cagatay:

you'll be honest, and that's what's most important about

Cagatay:

these questionnaires as well. You have to be honest. There

Cagatay:

should be no faking any answers. There should be no, you know,

Cagatay:

amending or, you know, fraudulent, you know, replies,

Cagatay:

things like, whatever it is, it is. I mean, as you do the point,

Cagatay:

I agree. If it's if you feel like there's deficiency in your

Cagatay:

program, stated, don't go and say, I have this. I have that,

Cagatay:

because Finch, they come in and then they find out that you

Cagatay:

actually don't have it, that you're then you're in real

Greg Dent:

trouble. Absolutely, you want to talk. You want to

Greg Dent:

Yeah,

Zahra Sunderani:

this actually reminds me of, Are you guys

Zahra Sunderani:

familiar with the panopticon? I feel like I talk about it often.

Zahra Sunderani:

It's, I think it was Adam Smith, but it's basically just this,

Zahra Sunderani:

this idea of a jail that had been created a long time ago

Zahra Sunderani:

that's fully circular, where there's only, say, one guard,

Zahra Sunderani:

just at the top watching, and the rest of the the jail people

Zahra Sunderani:

are in their cells, and they're in a circle. And basically the

Zahra Sunderani:

idea is that there's only one person that's actually looking.

Zahra Sunderani:

They're not able to look at everybody at the same time at

Zahra Sunderani:

all. But because of this, the idea, or the threat that there's

Zahra Sunderani:

somebody that could possibly be looking whatever you're doing at

Zahra Sunderani:

the time, you are self governing yourself, and I think that that

Zahra Sunderani:

really lends, lends it to this, because it's that idea that

Zahra Sunderani:

that's kind of what FINTRAC is doing. I mean, they're, they're

Zahra Sunderani:

sending these e cars, and they're saying, okay, you know,

Zahra Sunderani:

this is our kind of spot check. If we have a bunch of people

Zahra Sunderani:

that come out and voluntary disclose that they don't that

Zahra Sunderani:

they're out of compliance, it's actually really good because,

Zahra Sunderani:

yeah, that would be such a win, because they're now seeing,

Zahra Sunderani:

okay, great, you're you're actually basically auditing

Zahra Sunderani:

yourself. You're seeing that you're able to see those gaps

Zahra Sunderani:

and you're going to be able to fix them. It doesn't mean that

Zahra Sunderani:

they're not going to look away from you. It just means that

Zahra Sunderani:

you're doing the work for them

Greg Dent:

well, but but to be clear, like if they decide that

Greg Dent:

if you submit this, there's, there's, there's kind of three

Greg Dent:

possibilities, I see it. Look we can all agree, everybody,

Greg Dent:

probably everybody watching this, but certainly the three of

Greg Dent:

us can all agree that the best thing would be that you have a

Greg Dent:

program on policy, a procedure, a risk assessment that's

Greg Dent:

actually doing all the right things, that would be the

Greg Dent:

perfect situation. The real world is such that that's not

Greg Dent:

always true. And to be clear, like there's always room for

Greg Dent:

improvement no matter how great your program is you. That's why

Greg Dent:

effectiveness reviews are a part of the regime. That's why these

Greg Dent:

are living, breathing documents these. That's why this the

Greg Dent:

training needs to amend itself. That's why the regulations

Greg Dent:

change. So like even the best case, it is possible for you to

Greg Dent:

identify some deficiencies at some point. In fact, you should

Greg Dent:

be occasionally. But let's go to the the other possibilities.

Greg Dent:

There's a possibility where you are trying, but as a result of

Greg Dent:

receiving this E car, you realize that there's some

Greg Dent:

questions that you just don't even know how you're going to

Greg Dent:

answer. Well, I'm going to suggest to you that you have two

Greg Dent:

POS, two options here. One, you commit fraud, and I would never

Greg Dent:

think that that's the right approach, and I would hope that

Greg Dent:

that's never the approach that anybody would take. Or two, you

Greg Dent:

use a mechanism that FINTRAC has specifically set out for this

Greg Dent:

exact situation where you realize you have a piece of non

Greg Dent:

compliance. You disclose that through the through that

Greg Dent:

channel, there's a there's an email address, there's a there's

Greg Dent:

a process. I think it's an actual email address, in fact,

Greg Dent:

at this point. But anyhow, you disclose that process through

Greg Dent:

that process, and then as you file your ecar, you would go and

Greg Dent:

say, Look, we filed a V doc on this. We are going to work

Greg Dent:

towards remediation of this. And as a in all of the interactions

Greg Dent:

I've had with FINTRAC, that would be almost as good, if not

Greg Dent:

better, honestly, than than just being buttoned up in the first

Greg Dent:

place, because that now you're showing that commitment to

Greg Dent:

compliance. The third possibility is, and probably the

Greg Dent:

worst of them, I think, is you go and you fill out the SRA Q,

Greg Dent:

and you're deceptive or misleading, or you. Kind of just

Greg Dent:

ignore some of the questions, or don't answer them in detail, in

Greg Dent:

enough detail, and then FINTRAC is going to want more

Greg Dent:

information, and then they come in and they find some

Greg Dent:

deficiencies. Now you're you kind of put yourself into this

Greg Dent:

hole all of a sudden. So I think the the opportunity to use this

Greg Dent:

as a free effectiveness review, for lack of a better way of

Greg Dent:

describing it, is a pretty decent one thoughts on that?

Zahra Sunderani:

Yeah, 100% I 100% agree. I think, I think

Zahra Sunderani:

people rightfully so, because the amounts that are the fines

Zahra Sunderani:

that are given out are terrifying, but I think maybe

Zahra Sunderani:

people also don't have the perspective that FINTRAC really

Zahra Sunderani:

like they're just trying to get people into compliance. And so

Zahra Sunderani:

if they're seeing that you have that intention, if they're

Zahra Sunderani:

seeing that you want to do that, generally, they're actually

Zahra Sunderani:

going to be relatively your friends, like it's not, it's

Zahra Sunderani:

it's kind of like a tutor relationship, where they're only

Zahra Sunderani:

going to scold you if you are cheating on the test, you know

Zahra Sunderani:

what I mean. But if they're seeing you're really trying hard

Zahra Sunderani:

to figure out that math equation, they absolutely will

Zahra Sunderani:

say, okay, great, that's awesome. You got to see plus.

Zahra Sunderani:

But next test that you have, let's work on it from there on

Zahra Sunderani:

and and I think that's something that maybe a lot of people don't

Zahra Sunderani:

have that that perspective on, because the fines are absolutely

Zahra Sunderani:

yeah, they're terrified,

Greg Dent:

yeah. I mean, it's a lot of money. I like, yeah,

Cagatay:

it's a lot of money. And why is that money when you

Cagatay:

can just do your homework, basically, I mean, yeah, you can

Cagatay:

invest that money into your own business or whatever. I mean,

Cagatay:

it's simple, I mean, and as you to point out, Greg, and I mean,

Cagatay:

if you are not able to do this by yourself, you know, just seek

Cagatay:

assistance, seek help. And I'm not sure whether we're allowed

Cagatay:

to advertise here, but our

Greg Dent:

podcast, we can do

Cagatay:

it. Really. Trust it. Guys,

Greg Dent:

no, it's our podcast. And I think it's totally fair to

Greg Dent:

say, Look, guys like, if you're listening to this and you've

Greg Dent:

you've received an E car and you're not sure how to respond,

Greg Dent:

it's not too late, reach out. We can help. We will happily walk

Greg Dent:

you through. We've done this before. We can walk you through

Greg Dent:

what we think are some of the better practices in terms of

Greg Dent:

responses. And if your program is completely missing

Greg Dent:

everything, this is a really good wake up call for you,

Greg Dent:

because if you're receiving the E car and you don't want to

Greg Dent:

commit fraud, which I'm going to assume is the case for most

Greg Dent:

people, then your best bet is to start to resolve this problem,

Greg Dent:

and we're going to help you with all of that. So that's

Zahra Sunderani:

and if you if you are a client and you're

Zahra Sunderani:

listening to this, that is also awesome, because we would have

Zahra Sunderani:

access to your compliance program. We would be able to,

Zahra Sunderani:

we've been helping shape it, and so we would be able to actually

Zahra Sunderani:

give you direct feedback on kind of guidance with this

Zahra Sunderani:

specifically. So for sure, reach out whether you're a client or

Zahra Sunderani:

you're not. Please

Greg Dent:

don't go it alone. Yeah, yeah. Okay. Well, with

Greg Dent:

that, thank you very much, shatai and Zara both for your

Greg Dent:

time. I appreciate you coming on and talking about ecars, SRA

Greg Dent:

cues and whatever other Ford letter acronyms comes up with in

Greg Dent:

the next iteration. Sorry,

Zahra Sunderani:

should we, Greg, just quickly touch on what

Zahra Sunderani:

happens after or once we send it, is there? Is there? Or is

Zahra Sunderani:

that a completely different it's possible it could be a

Zahra Sunderani:

completely different podcast. No, I

Greg Dent:

mean, we could talk about that for sure. Like, go

Greg Dent:

ahead, that sounds good. Well, yeah.

Zahra Sunderani:

I mean, so just just once, once you're done

Zahra Sunderani:

filling out the e car, usually you get a time, a time frame to

Zahra Sunderani:

fill it out and, and so you send that back. And we've seen where,

Zahra Sunderani:

literally, that's it. That's that it just goes into the

Zahra Sunderani:

ether, if in track and you never hear back, and that is likely

Zahra Sunderani:

the best case scenario, because that means that they're really

Zahra Sunderani:

happy with your responses, and maybe not even really happy.

Zahra Sunderani:

It's just that there aren't enough red flags for them to

Zahra Sunderani:

say, Okay, we need to look at your compliance program, which

Zahra Sunderani:

is awesome. So if you don't hear back, that's great, but then

Zahra Sunderani:

it's possible that, I don't know timeline wise, it really depends

Zahra Sunderani:

when track is kind of a little bit, yeah, they kind of have the

Zahra Sunderani:

curtain there, but, but if you do hear back then, then there's

Zahra Sunderani:

a next step. And still, there are a couple other steps before

Zahra Sunderani:

they decide to formally, actually audit you. But they're

Zahra Sunderani:

just, it's just a continued continuance of gathering of

Zahra Sunderani:

information. Yeah,

Greg Dent:

I think, I mean, I thanks for bringing this back to

Greg Dent:

that. Because I think it is important to realize that this

Greg Dent:

is one of many things that FINTRAC is doing to monitor

Greg Dent:

their reporting entities and their gather this is just

Greg Dent:

information gathering for them. So you may not hear back. That's

Greg Dent:

not unusual for FINTRAC. That's not a bad thing. Might be a

Greg Dent:

preferred option, honestly.

Cagatay:

And perhaps one final note, time frame for. Actually

Cagatay:

submitting your responses. I've come to understand that Finch

Cagatay:

are quite, you know, lenient in providing extensions to all

Cagatay:

those you know who receive these questionnaires. So normally,

Cagatay:

you're given 30 days to provide the feedback, but if for one

Cagatay:

reason, as you have a pretty good excuse of, you know, not

Cagatay:

being able to you can apply to them, and they will provide you

Cagatay:

an extension as well. The key

Greg Dent:

to that, of course, is don't ignore them. Ask your

Greg Dent:

extension.

Cagatay:

Definitely. If you

Greg Dent:

go to them two months later and say, Oh, by the way,

Greg Dent:

we want an extension, they're going to say, Wait a minute.

Greg Dent:

This was due a while ago,

Cagatay:

and ensure you're like checking out your email inbox

Cagatay:

here, and then, because sometimes they may just get

Cagatay:

lost, that's a real other things.

Greg Dent:

That's a good point and a real life story that we

Greg Dent:

can kind of touch on, which is that they their contact

Greg Dent:

information isn't perfect. So you know, if you've had an email

Greg Dent:

address out there that make sure you're checking those ones that

Greg Dent:

you set up years ago when you first set up your business.

Greg Dent:

Because if that goes, if that's where the E car goes, that might

Greg Dent:

be where the E car goes. So

Zahra Sunderani:

but then even to that, right, if, if there's a

Zahra Sunderani:

legitimate, justified reason for why you never got that, use it

Zahra Sunderani:

at all. Fin tracks, they're not extremely unreasonable. They're

Zahra Sunderani:

not, they're somewhat reasonable, you know, no, no,

Zahra Sunderani:

they're absolutely, if

Greg Dent:

you like, if you didn't get it, and you say,

Greg Dent:

Look, guys, we didn't get it, but we'll have it to you within

Greg Dent:

30 days of now, they'll say, Okay, well, that makes sense.

Greg Dent:

You just got it like you got 30 days. I mean, I can't guarantee

Greg Dent:

that, because they get to do what they want to do, but

Greg Dent:

that's, that's what we've seen, and that's what I would expect

Greg Dent:

to continue to continue to be the case

Zahra Sunderani:

So, yeah, totally.

Greg Dent:

All right, well, thank you once again. Really

Greg Dent:

appreciate you guys taking the time and thank you for

Greg Dent:

listening, folks to another episode of the KYC podcast. I

Greg Dent:

know your compliance podcast. Please join us again soon. Take

Greg Dent:

care.

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Know Your Compliance (KYC)

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Greg Dent