Systemized Success: Making FINTRAC Compliance Part of Your Brokerage DNA with Paul Therien | 017

Greg Dent: 00:00:00

Hello and welcome to another episode of The know your compliance podcast. I have a special guest with me from Haystax Mortgages. Paul Therien, am I even pronouncing your last name right there? Paul,

Paul Therien: 00:00:16

pretty close. It's Therien, yeah.

Greg Dent: 00:00:20

So I got the French blood in me, so I want to call it Tyrion, but I'll say Therien from now on. And Paul is one of the founders of Haystax Mortgages. And you want to tell us a little bit about what you're doing over there as as you start to wrap that up, yeah,

Paul Therien: 00:00:38

the concept of Haystax is essentially to Well, the best way to describe it is to bring some predictability and consistency into the experience of consumers, lenders and franchisees, and to to more closely align systems and structures so that It makes the day to day operations of our franchisees easier and more profitable.

Greg Dent: 00:01:04

Cool. I love it. I think it's and I think what's been interesting about our conversations over the last handful of months is really the you seem to grasp the problems associated with FINTRAC compliance and anti money laundering compliance, and I think that comes partly from the your view of the world, which is shape that so many things can be systemized, and without kind of burying the lead too much Here, I know that FINTRAC compliance can't be entirely systemized. And that's that's the junction where you and I have found each other and and have found some really interesting conversations, I think so I wanted to have Paul on today, because as he talking with people in the mortgage space, he's got, he's developed a really interesting view of how the mortgage sector is adapting to the quote, unquote new and we're now almost six months into being regulated, November, December, January, or February, March, sorry, five months into being regulated. And so I thought it'd be interesting to hear from the front lines, as it were, what he's seen, and we did a similar episode a few months or a few weeks ago, with a different brand, but, but Paul's view is going to be different, because he's talking with people, generally, Paul, I would imagine, and I'm putting words in your mouth here, but I suspect you're talking with people who are looking at more of a brokerage level, in terms of becoming owners of a brokerage rather than mortgage brokers on the on the on the daily. Kind of ground is that fair to say? Or am I putting too much in your mouth? There even

Paul Therien: 00:02:50

No, no, I think that that's relatively fair to say. Our conversations on the haystack side have actually been predominantly with people who are looking to enter the mortgage space in Canada for the first time. So they're looking at because our model is so highly systemized in terms of process, we have a very structured process to engineer consistency and predictability. They're looking at it in that it eases a lot of that, call it regulatory confusion or frustration that we're seeing in the industry, because, you know, the more predictable you can make a business model, the more likelihood that the franchisee will be successful. So and it's it's really just easier to manage. It's easier to manage the business, the people, the customers, the lender relationships, you know. So

Greg Dent: 00:03:47

that's the that's the McDonald's model that I mean you, if you have the privilege of owning a McDonald's franchise, you all were almost guaranteed to make X dollars just because of the fact that you own a McDonald's franchise and they've just got it so dialed in. And I'm not talking to product quality. I'm not trying to make a comparison on product quality or anything like that, just from a from a pure systems point of view, they are amongst the best of having just executed this to where you just plug and play and go and you're you're suddenly operating a fully fledged business. So I think that's a super interesting approach to mortgages or to mortgage brokerages. So what I really wanted to chat about is FINTRAC, and that's what I spent my life talking about, weirdly, what I and I was interested because you'd shared some really interesting stories about what you're hearing with respect to people's compliance. And I thought we'd, we'd start with that and kind of talk a little bit what you've been hearing from from people. Yeah,

Paul Therien: 00:04:51

it's interesting. So I want to, if it's okay, I want to clarify something fin track rules. Uh, although enforcement is now in place, the reality is, for anybody who works in financial services, the basic tenants of FINTRAC have applied for as long as I've been in the industry, since 91 Yeah, you know the notion that you know you're supposed to get identification, confirmed ID, government issued ID, and that's specific about which ID is acceptable or not prior to pulling a credit report. I mean, that has been a rule that's in place for longer than I've been working in the industry. It was one of the very first things I learned is you don't proceed with an application until after you've confirmed the identity of the applicants. So I think there's a misconception in the mortgage space, particularly that these are new rules that you know we didn't have to adhere to before. I think some of them are new, but, you know, I think what's really new is the reporting and the enforcement requirements. And there's also a misconception that, you know, regulators are out there to make our jobs more difficult, when the reality is they're all. Regulators everywhere in the world are reactionary. I've never met a proactive regulator, ever, you know, they they put a lot of faith in the professions, no matter what industry that they regulate, and they don't really step in with tightening the rules until such time as there's been, you know, a pattern of, call it poor behavior or not following the rules, and then they're going to step up enforcement. So I think it's really important, as we're talking about this, that we, you know, things like confirming identity, source of funds, all of those things, these are not new rules. Yeah, now you know so

Greg Dent: 00:06:54

well. It's funny because I'm reminded of one of my favorite sayings around compliance, which is good compliance is actually just good business. And I think, like, you know what, I'm kind of echoing what you're saying there, because, you know, if you go and let's go like, super brass tax, I'm a mortgage broker just trying to make a living. Don't really care about compliance. Well, okay, except if I spend 30 hours or 20 hours or 40 hours working on a file that turns out to be fraudulent. I've just literally wasted 20, 3040, hours of my life that I will never see payment for. There's just and you, in the moment, you might feel like, Oh, I'm so busy, and I'm doing the work well, yeah, but if there's never if, it was a fraudulent application at the beginning, which you would have discovered, if you had taken the ID properly at the beginning, then you would have not spent those 20 hours on a file that you were never going to get paid for. So on some level, I really believe good compliance is good business. And so I, I'm, I'm not surprised to hear you say this part.

Paul Therien: 00:08:00

Well, in order to have good compliance, okay, I mean, and this is so I'm going to go back to a long time ago, when I started my career with, you know, Eatons in home cleaning in northern Alberta, nice. I was responsible for finance and customer service, because people, you know, they would, they they were offered financing packages for this whole home, you know, care package, okay? And, you know, even back in those, you know, in the in the late 80s and early 90s, I started with them in 1990 and, you know, it's interesting, I was the youngest person working for the company, and I had 35 staff, nice I to this day, have no idea why they ever gave me that job. I was woefully under qualified. Maybe it was because I was cheap. I don't know. But, you know, we had very strict processes around, you know, credit applications, and when you know, we could decision a file, because it was all in house financing. You know, you could decision a file very rapidly, because by the time you got it, you knew what was there. It was considered, you know, everything was packaged the same when I moved to the Yukon and started with AFCO finance. And I'm saying the Yukon intentionally. I mean, the Yukon has a population of, you know, 25,000 people four seasons. And you know, maybe, maybe it goes up to 35,000 in the summers, I think now. But back then, you know, the White Horse only had a population of 15 to 20,000 and the entire territory wasn't even 30,000 I

Greg Dent: 00:09:40

didn't realize, yeah, that's sparsely populated. That's interesting. But anyhow, sorry,

Paul Therien: 00:09:43

carry Yeah, it depends when the mines are, you know, when the gold mines are operational, the population explodes. You know, very much like any other resource based, right? Yeah. But what I thought, or what I think is interesting, is that AVCO finance in in the UK. And White Horse Yukon was the single most profitable AVCO branch on Earth, and it consistently for four years in a row, ended the year with zero delinquency and zero fraud. Wow, and we didn't do anything special, other than we followed the rules. So we said, if we're going to lend money to this person, these are the steps that you must take. And the manager that I had, his name was Gilbert, was very, very focused on process and compliance. And so, you know, my busiest months with AVCO, I booked 189 mortgage or loans. Excuse me, 189 personal loans and three mortgages. My goal was to book 30 loans and to do three mortgages a year. Oh, wow. Okay, so you know, and when you follow a very standardized process, you can move through files quickly. I discovered, because it's predictable. I know I need to do this, I need to do this, and I can communicate those steps clearly to the consumer. So when I when I say that compliance good compliance is good business. It's because you're inserting, you're injecting predictability, and consumers rely on predictability heavily.

Greg Dent: 00:11:33

Yeah, well, and I think the other thing that I I want to pick up on, that you just said, that's super powerful is, if you keep doing the same system every single time you're gonna you're gonna be able to prevent problems that consumers are going to have in the next step by giving them information a step before they know, before you know they need it, and even though it's not even on their radar. And I think that's when these systems become really powerful is when you can say, Okay, well, I know that. I don't know I know that. So my background is as a realtor, and so I know that once you've removed your subjects from the contract, you've got to move in your future. And so if as soon as you remove subjects, I can get you all of the information about your Canada Post, mail change and a list of movers you might choose to use and a list of utility bills that you should consider moving. If I get that to you the day you remove subjects, then I'm previewing your problem. I'm going to solve a bunch of problems for you as well as for me, because now you're not going to have the questions for me. So it does become a much more it becomes more efficient of a process when you can when you do have a process, and when you do use some version of checklists and a set of systems to make sure you're complying with your own, with your own, whatever your own rules are. So yeah,

Paul Therien: 00:12:54

yeah, no, yeah. And I think mortgage brokers have access to such finite, or, you know, really finite detail about their customers that most service providers don't have. You know, if you think about a realtor, you know, a real estate professional needs to know that the client or the consumer, the buyer, is approved for a mortgage, but you don't need to know the details of that individual's financial circumstances, you know. But in order to get approved for a mortgage, you know, you're, you're literally lifting every rock and the garden type thing and looking for hidden issues, right? Because, because mortgages are typically the largest finance vehicle that any consumer will have, you know, with the exception of maybe you know, somebody like Bill Gates or Elon Musk, but for most of us, we don't, you know. I mean, the reality is, is that the home is the biggest purchase, and so we know a lot of information. Yeah, we know a lot about our clients, more than most banks do know about their clients. And so compliance, to me, is also protecting the customer, yeah, and making sure that you know, our customers aren't subject to identity theft and straw purchases and that kind of stuff. And over the years, I've seen a lot of situations where, you know, identity theft could have been very easily prevented with just asking the right questions and doing the due diligence. So I think we need a mind shift, maybe in the industry towards compliance, to understand why compliance is important and how it protects not just the consumer, but it protects ourselves individually. I mean, what is it? What one of your team said to me the other day is, you know, are you $138,000 confident in your compliance?

Greg Dent: 00:14:49

Yeah, exactly average

Paul Therien: 00:14:50

fine being levied in the real estate inside, right? Yeah. And I, you know, I can say with all confidence at hay stocks, yeah, I'm, I'm the. Million dollars sure that we're compliant, yeah,

Greg Dent: 00:15:03

and I think it's interesting, because I, I'm, first of all, I'm glad to hear you say that, but also I want to, I want to look at what you've just said around this idea that identity theft, fraud in general, hurts you as a business and hurts the consumer, the part that people don't always draw, but I think is really interesting and powerful is the societal impacts of of that fraud. And you know, the lens that I look at the world in as is, I want to make it harder for the person who is I look, I'm you and I are in Vancouver, so I'm going to make a very Vancouver reference, but I want the person who is selling fentanyl at the corner of Maine and Hastings to make it to be for it to be very difficult for that person to profit from their activities, because I don't want them to continue to make decisions to sell fentanyl, because it has massive, huge consequences for our society. And for those of you who don't believe me, drive through the intersection of Maine and Hastings and tell me there aren't massively bad things that are happening to our society as a result of fentanyl. And why am I picking on fentanyl? Well, because the person involved in the creation of the fentanyl, the person who involved in the distribution of the fentanyl, the person involved in the selling, the street level selling of the fentanyl, all of those people are making money. That's why they're doing it. They're not doing it because it's a fun pastime. They're doing it because it's a lucrative business, and if we can make it a less lucrative business, because they're they have all this cash that they can't use in the legitimate marketplace, then I am all for it, and that's where I get really passionate and really excited about what we do as a company for for a living, because it allows us to make a bit of a dent. And look, I think all the Preventing of fraud is equally important, don't get me wrong, but I think if, like, if we can multiply that impact, if we could get every mortgage broker and every real estate agent really on board with why we're doing anti money laundering, I think we'd see our we'd See it be a lot more difficult for the fentanyl dealer, for the human trafficker, for the for the assassin, to go really like dark for a second, but all of these crimes that's where, like, that money, that laundering of money, and I know it's hard to see it for some people, but that tie in is really, truly there. So Well,

Paul Therien: 00:17:40

yeah. I mean, we do have a money laundering issue in this country, and we do have fraud issue, and it's one that is recognized globally. I mean, let's I mean, this is not a point of pride, and nor should it be a point of pride for anyone, specifically or particularly, if you work in any sort of financial services. But the fact that Canada is is, you know, listed as one of the, you know, mortgage fraud capitals of the planet. And that, you know, there are actual, you know, the Vancouver plan and the in the Canada plan, these are actual money laundering plans that are promoted model organizations, yeah,

Greg Dent: 00:18:25

model it's a thing. Yeah,

Paul Therien: 00:18:28

it's a thing. And and, you know, that should cause all of us concern, because those types of attacks on the intent on the integrity of our financial systems negatively impact all of us in both the short term and the long term. So, you know, short term, of course, you know, if you've got somebody who's in a straw buyer situation, you know, as an example, very often the people that are being forced to be that straw borrower are doing their it's coercion, absolutely criminal networks

Greg Dent: 00:19:04

for a gambling debt, or for immigration debt, or what, what immigration debt? I should put that in massive but, yes, carry on is,

Paul Therien: 00:19:12

but, you know, I mean, they use criminal and they use it for human trafficking. It's, you know, so it's, they also use straw borrowers as a way to legitimize you know, of course, too long totally. So, you know, people say, well, as long as the mortgage is paid, it doesn't really hurt anyone. But that isn't strictly true. So what I think most of us forget is Who finances most of our mortgages in this country, and it's our it's the bank security divisions. So, you know, there's a there's a lot of misconceptions, I think, about where our money comes from and how it's funded. But for example, you know, RBC securities, TD securities, it's the securities divisions of these banks that are really the backbone of the mortgage industry in Canada. And. Because they finance, you know, most of the big lenders, or they buy their mortgage backed securities. So if I have a bulk package of deals that I've securitized, I'm selling them as MBs and and I have to get insurance, bulk insurance, in order to sell those MBs. Well, if I'm a lender, like first national or cmls, very often there are restrictive covenants on the MBS that I sell that stipulate if there's any fraud or anything that is not in alignment, in alignment with compliance or regulations, then as the lender, I get penalized. So not only am I required to buy that debt back, so let's say, you know, it's a $500,000 mortgage, I have to buy that $500 $500,000 mortgage back, and I've sold them a full security, so I now have to pay a penalty. And I've heard of penalties, as you know, in my experience at the lender side. I've heard of penalties as high as, you know, $200,000 Oh, interesting. And yeah. So, you know, those penalties have to be recouped somehow, and so it results in higher costs over the long term. Because, you know, banks, lenders, are looking at it purely from an origination standpoint. But those securities division are not. They're looking at it because for them, it's an investment. Yeah, it's not. It's got nothing to do with the guy or the person living in the house making the bills they they really that's got nothing to do with it. It's this is an investment we have promised a specific return to our investors, which is you and me and our pensions and our mutual funds.

Greg Dent: 00:21:46

You know, I was just going to say, it's funny how it actually ends up being full cycle, because really a lot of that is, is pensions and and the like that are that are funding all of this, rsvs, etc. So, yeah, yeah. So,

Paul Therien: 00:21:58

you know, fraud, straw borrowers, although there may not be an immediate societal impact, there is a long term impact. And we have proof in Canada of the long term impact, actually, mortgage brokers, every single mortgage broker in Canada today has proof of the impact that this has, okay, the fin track regulations that have been applied.

Greg Dent: 00:22:22

Yeah, well, I suppose that's, that's, that's, that is true. I mean, yeah, that's, that's how we got to FINTRAC consider or treating mortgage brokers as a reporting entity. That's and, and to your point, around proof, the estimates, and these are estimates, but they're probably about, right? Is that and like, if you want to go really like society, well, if you want to go direct impact, the estimate is that housing pricing is up by about 5% because of money laundering, like the prices and we're in a housing crisis. There's no question, across the country, 5% is a meaningful chunk of money. It doesn't sound like a lot, but $50,000 on a $1 million home, which on $1 million home, I don't know where you're getting that, but it isn't in Vancouver, anywhere. So, so that's, that's a lot of money, like, that's, that's an annual salary for some people. And so I, well,

Paul Therien: 00:23:19

you know, put it into even more perspective, though, right? Like 5% of the outstanding mortgage volume of $2.2 trillion yeah, that's a scary thought. A point 2 trillion That's a staggering amount of fraud. Yeah, staggering amount of money. I mean, 5% of 2.2 trillion is, what? $110 billion

Greg Dent: 00:23:48

yeah, yeah. That's a lot with a B people,

Paul Therien: 00:23:52

yeah. How many people in Canada have a net worth that even comes close to approaching

Greg Dent: 00:23:57

that? I'd be surprised if it was more than five. I actually don't know the answer, to be honest with you, but it's not, there's not a lot of billionaires. So

Paul Therien: 00:24:05

no, there's not, you know. I mean, you think about, you know? I mean, Elon Musk is worth $335 billion so we're talking at least the last report. I'm sure he's worth more, but, you know, I mean, that's a third of his worth.

Greg Dent: 00:24:18

I want to, I want to fact check ourselves. There are 57 billionaires in Canada, okay, but, but I suspect most of, and I don't know exactly, because I'm fact checking on the fly here, I willing to bet that most of those 57 darn in the double digits of billions, let alone the triple digits of billions. So

Paul Therien: 00:24:38

yeah, I mean, there's not a lot of 100 billionaires in the world

Greg Dent: 00:24:42

here, actually, here we go. Number one in Canada is 37 sort of 38 billion, essentially. So that person alone doesn't have enough to cover the amount of fraud. So yeah, and you

Paul Therien: 00:24:55

have to consider too that when we look at outstanding mortgages. Because, you know, people forget too that on the conventional side, particularly with the monolines that aren't carrying balance sheets, they're reselling that debt as mortgage backed securities. And so, you know, that has a knock on effect, because fraud is fraud is fraud, and whether somebody's making the pay. I mean, just because a criminal makes their payments doesn't make it not a crime. It's, you know, it's like, well, if I shoot someone and I don't get caught, am I still guilty of murder? Of course, you are you broke the law? Yeah, just because you didn't get caught isn't an excuse for doing it. Or just because you think the rule is stupid doesn't mean that you get to ignore it, you know. I mean, so we've had a lot of issues, you know. And I think that, you know, housing affordability is a huge discussion. I my opinion about why we have housing affordability and issues varies greatly from what most people think in the industry, but that's, you know, my personal opinion, so but when it comes to fraud, we have so many measurements and metrics that clearly demonstrate the impact of it, the societal impacts. And you know, if we take all the consumers out of it, we take all the lenders out of it. We just talk about mortgage brokers. You think about the fraud that occurs hurts all of us because the regulators have no choice but to step up regulation. Yeah, so because they there's no way for them to police us on a day to day basis, like no regulator has the resources to audit every mortgage brokerage once a year. They're just, it's not possible. Wouldn't put up with it? And

Greg Dent: 00:26:48

thank goodness too, by the way, because at that point they should just run our programs for us. Is would be my response to that. I'm super curious. I so I'm super curious on your view on the mortgage, on the housing crisis. I, for the record, I don't think money laundering is the number one reason. I think the number one issue is a lack of supply and an overwhelming demand for internationally, for Canadian real estate. That's, that's what I think actually drives most of it. But I, I'm curious there's not really topical, but I want to go down the path for a second, if you would.

Paul Therien: 00:27:23

Well, you might be opening up a can of orangey regret opening. Look Canada, we have we're the second largest land mass country on Earth. We have ample land. The what we're seeing, though, is a push from all sides, all political spectrums, to de ruralize Canada. You know, smaller cities are struggling over COVID. They saw booms because people were moving there, but there's no employment because, you know, governments across all spectrums or parties across all political spectrums are, you know, they promote industry in that but they don't promote really small town growth the way they used to do, like pre World War Two, small town growth was a big push. So you're seeing people consolidating in major centers, and as that consolidation happens, you see people challenged to find land. You know, Vancouver is a perfect example. We've got, you know, ocean, OCEAN, Ocean, and then another city like Vancouver is quite literally out of land, unless, you know, we start reclaiming land into the ocean. There is no more land in Vancouver, yeah. So, you know, we have no choice but to go up. But as you know, we have more and more population. Of course, land values go up, but I believe that it's a symptom of the fact that, you know, and I think it's also a symptom of our low per person GDP. We're not promoting growth outside of major centers in this country. You know, everybody wants to live in Vancouver, Toronto, or Montreal or Calgary now, yeah,

Greg Dent: 00:29:04

finalist, I guess, you

Paul Therien: 00:29:07

know? I mean, it's just, it's not, you know, we have a huge amount of land, and we, I mean, there's no excuse in my book. We have the land, we have the financial ability. We are not a poor country. We have 41 million people that, you know, we're one of the g7 we are not poor by any stretch of anyone demands imaginations. We simply lacked the will.

Greg Dent: 00:29:33

Yeah, no, it's interesting. No, that's this is this is good. I'm I think you're right. And I think my supply demand analysis might be an abbreviated version of kind of the same thought, which is to say there is more supply than I think we treat it as. That's interesting. Anyhow, yeah,

Paul Therien: 00:29:56

anyway, yeah, yeah. But I also think that. You know, the lack of, the lack of of mitigation in terms of fraud and that kind of stuff. I do think it contributes. I think it's a smaller amount, but I do believe that it contributes, because, in my experience as a lender, if somebody gets away with something once, okay, the second time, every time you get it gets a little bit easier, yes. And you know, you skip the rule. You skip the ID, just this one time. It's not a big deal. And then, you know, I know the person really well, I went to school with them, whatever. So then the next time you do it, and you think, well, I'll just get the ID later. But, you know, as we allow this to happen, and I don't, you know, no, but I believe that 99% of mortgage professionals aren't out there saying, How can I screw the system? Most of us are just, you know, people are just wanting to make a living. But I think that it's, it is a statement, not about regulators, and it's not a statement about mortgage professionals individually. It's a statement about the businesses and the brands, the brokerages and the brands, because as a leader, it's my role is to ensure that my franchisees and agents are protected, and the best way that I can protect them is ensure that they're compliant.

Greg Dent: 00:31:22

Yeah, no, that may that makes sense to me. I I was reminded about so my dad's a lawyer. His office does a fair bit of real estate conveyancing, and he's got a sign at his front desk. I'm going to paraphrase it and probably get it slightly wrong, but essentially it says, you know, don't be offended when we ask for your ID. If my mother were buying or selling, I would need to ask for hers. And conceptually, I think that's a really great framework, which is like, I don't care how much you think you know somebody, you still have to go through the process and and whether you like that or not, is part is one thing, but the The truth is, it does actually protect you, your business, and ultimately, the entire Canadian economy. How's that for, for big

Paul Therien: 00:32:13

well, and you know, there's so some of the online discussions that I've been seeing are, you know, it's not fair, because banks don't have to do this. When? When was the last time, you know, those to those people, I would say, when was the last time you walked into a bank branch to talk to a teller, and when was the last time a teller said, yeah, don't give me any idea. I'll let you withdraw money from that bank account. Like, I mean, you know, now I understand the argument about, you know, if they're dealing with their bank, they don't have to get the bank statement. Statements. Well, of course, they don't. It's the bank's bank statements. The banks have access to it. It's there. They're an existing customer. So you know, if I'm a RBC customer and I'm getting a mortgage from RBC, and all my investments and everything are with RBC, well, they've already got all my data, so of course, I don't have to provide it to them again, but that would just be, well, it would be stupid. Why would I print something from Royal Bank to give to Royal Bank? It's just dumb. But if I'm going to a new lender, that new lender has no idea who I am.

Greg Dent: 00:33:14

And if you go open a new account at a bank, they're going to go through the entire actually, I would say two things. One, if you go open a new account, they're going to go through. They do have the same obligations for for the record, I just want to be clear, anybody who believes they don't is just wrong. But so where you see that most is when you open a new account at any sort of a financial institution, money services, business, etc. But you also see it as a consumer. Once you start to know, know what you're looking for, you'll also start to see it in odd places where you might not have occurred to you every year, all of your financial institutions, most of them now, if not all of them, do a survey to update their records, and you're asked to attest to your politically exposed, politically exposed person status, and you're asked to reconfirm your occupation. It's part of their risk decisioning. It's an ongoing process that I think people either don't see or don't realize that that's just an anti money laundering practice. You go into a bank I had this week and a half ago, two weeks ago, I went into a bank, and I forget exactly what the teller asked me, but, but I said to him, ah, you are fulfilling your fin Troy, your AML obligations right now. And he looked at me, which, by the way, in and of itself, me knowing that could have been an indicator that I was laundering money. So I then had to explain that I actually run an anti money laundering compliance company so as to not have a suspicious transaction filed against me, but, but you can, if you start to look for it, you'll see that, oh no, they are very much subject to the same regulations. And in fact, are doing it so well that you might not see it happening, is what I would say, so

Paul Therien: 00:34:54

well. And there again, that is the argument about pro. Process, you know, the more so banks, major financial institutions, have very strict and stringent processes for their employees that their employees are required to follow. So an underwriter, this is your job, right? And so that process becomes ingrained. It's just part of your job. You just do it. It's second nature, and that is your compliance. So if you if it's built into your process effectively, it's not a burden, it's just part of what you do, and the results are proven that that works. I mean, it's been and it's not just with fin track and AML. I mean, there isn't a business that exists in the world that is successfully capturing strong market share and growth consistently in that when everybody's kind of doing willy nilly whatever the hell they want. Yeah, it doesn't exist. So, you know, no, we struggle to compete with the banks in this country, partly because of the experience of the consumer is so inconsistent and so you know, I mean to know that in 2025 mortgage brokers are seen by the majority of Canadians as where you go when you can't get approved at a bank, still 80 plus years after our industry started, that's, you know, it's a broader discussion, but to me, it's all about that consistency and predictability of process, which always starts with being compliant in my books.

Greg Dent: 00:36:36

Yeah, no, I agree. It's crazy to me. In fact, that that's still a challenge that mortgage workers have when, when you understand the the financial services sector and realize that the person you're talking to at, and I don't want to pick on any one rank, but the rep, the quote, unquote representative at the bank who's trying to help you, help you with a mortgage, is actually just selling you one of their products, and by definition, you are then captured in their ecosystem, and they're not subject to the market where you might get a better result. And I'm not just talking about rates, talking about their whole part of a mortgage, and you can only get that by going into the market, which you're not doing when you walk into your local branch and talk to the person at that branch. So anyhow, the fact that that the mortgage, sec, the mortgage, mortgage brokers still happen to overcome that is surprising and shocking to me. So, yeah, yeah. Well,

Paul Therien: 00:37:27

I mean, and I think again, it speaks to a larger again, it's, you know, I'm going to beat this drum probably till the day I die. It's about consistency and predictability in business. You know, if you think about, well, let's look at what's going on in the world right now, today, right? The stock market has been taking a beating, okay? Why? And people show, oh, it's the tariffs. It's not that the tariffs are not it's the unpredictable nature of we're going to have on them. We're not, then we are then we're not. So if the broader business community says unpredictability is bad in every other aspect. And how is, how does that not apply to us? You know, how is? How is having non consistent experiences benefiting mortgage brokers? It's not,

Greg Dent: 00:38:16

yeah, a buyer, a buyer, regardless of the sector the market, whatever that is, they're buying or selling, transactions happen when you have confidence, and if you're if you're not confident, you human nature is to freeze up and wait until you have certainty before you make a decision. And so no, I fully agree with you there. Well, listen, we're running tight on time. Is there anything that you hoped we would have covered that we haven't talked about as a course, as a part of this conversation?

Paul Therien: 00:38:49

No, I think the only thing that I would like to kind of close with is I would hope that mortgage professionals in Canada would recognize that, you know, the importance of implementing these processes just as second nature in their business, you know. And let's take some examples of an industry from what they're doing in other countries and what other businesses in financial services in Canada have successfully accomplished with having those processes and compliance and predictability built into their business going online and and complaining about the regulations going online and, you know, some of the stuff that people are talking about, yeah, I don't know that That's a topic you should be sharing, you know, but I think we need to be a little bit more cautious, because, you know, let's face it, regulators go on social media, right? They're going to monitor those, those mortgage broker groups, and I know for a fact that most of them do, because I've had conversations with some. Regulators. So we need to be we need to be seen as supporting compliance. We need to be seen as an industry, as supporting AML, supporting why these rules are coming into place, and understanding that. And we need to understand and recognize that they're in place because we've had a handful of bad actors that have made a lot of press. You know, Greg Martel, you know, I find it extremely one of the things that I find fascinating is everybody in this industry who's been in for more than a decade is very familiar with the home trust scandal. And, you know, none of those brokers ever really received any sort of real, meaningful consequences for their actions. And yet, you know, there are people at home trust whose careers were destroyed because of the actions and those types of things illustrate to regulators that we can't govern ourselves. And so, you know, it's like children. If you put kids and you give them instructions and they ignore you, you're going to micromanage them. It's no different for us. If the rules are in place and we're not enforcing them ourselves, the regulators have no choice, because we also the last point I'll make, we have to remember, regulators aren't there for us. Regulators are there to protect the consumer first, and that's it. Their job is not to make our lives easier. Their job is not to, you know, let us just do whatever we want their job is specifically to police us and protect consumers. So the more we do to protect our customers, the less regulators will have concerns.

Greg Dent: 00:41:53

Wow. And in the spirit of the rest of the conversation, the more you do to do it properly. You might find it helps grow your business as well. So thank you so much, Paul. Really appreciate your insights. This has been a really fun conversation. I I always enjoy jumping on and kind of bantering around. We went to all sorts of different areas. I didn't think we'd get to but, but thank you for playing and enjoy spending the time with you and look forward to chatting more in the future. Have a Yeah, I

Paul Therien: 00:42:25

really enjoyed being here. I think, you know, we probably could go for at least another hour on comply. I mean, we can easily. It's just about compliance easily. But I really appreciate it. And I have to say that I think that what you're doing with really trusted and having this podcast and whatnot, I think it makes a really big difference, because education is critically important. And you know, you're a you're a strong proponent of that. And I certainly, you know, from a haystacks perspective, the partnership with you guys made no sense, right? So I'm just going to throw a plug out there. Hey, anybody who's listening to this, every single hay stocks mortgage automatically gets full, really trusted compliance process included in what they pay hay stocks, no,

Greg Dent: 00:43:17

well, thank you. Thank you for for there's, there's a certain amount of That's awesome. Well, thank you again, Paul, appreciate your time.