The Biggest Compliance Challenges for Mortgage Brokers with Mary Gronkowski

Greg Dent: 00:00:00

All right, welcome to another episode of the KYC podcast, the know your compliance podcast. I am excited to be back after a bit of a break here, and excited to be having a conversation with Mary pronkowski from DLC mortgages. Mary's the National Director of compliance, and that's, I think, a really fun job, probably not for everybody, but so Mary, welcome to the show. Oh,

Mary Gronkowski: 00:00:28

thanks for having me. And you're right. It's never a dull moment in the world of compliance, that's for sure.

Greg Dent: 00:00:35

Yeah, I have come to appreciate that. Actually, it's part of what, what I think is really interesting about this kind of a job where every day quite, quite literally, and we'll talk about this in a few minutes, I'm sure, quite literally. This morning, a change to the regs dropped, and we knew it was coming, but it's, it's bigger than I was expecting it to be for a drop, for a drop, that's in effect, three days from now or four days from now. So,

Mary Gronkowski: 00:00:59

yeah, March, anyhow, yeah,

Greg Dent: 00:01:01

yeah. So let's look today. I, from my vantage point, I get to work in in real estate brokerages and in mortgage brokers, but it's very high level. And why I wanted to invite you onto the show is that you get a little bit more of the day to day questions. And the question I really wanted to explore today with you was, now that the mortgage sector has been a reporting entity for four and a half months, how's it going and what is that looking like? So yeah,

Mary Gronkowski: 00:01:36

well, first of all, it's been a very slow process, getting our brokerages registered as reporting entities. But, you know, FINTRAC has a systematic process, and there's a few that have already been signed up, but very, very few. So out of the over 500 brokerages that we have, there are now about, I would say, around 20 that are officially signed up and registered, and their onboarding process has been very methodical, so they do send out an email just asking you to answer some simple questions, and then they send out a supervisory assessment questionnaire, and then, based on that questionnaire, they will meet with the compliance officer, owner, and go through any gaps and and make sure that they have everything set up. It's been, it's been fairly simple and more of an educational process, which is really good, not as daunting as we thought,

Greg Dent: 00:02:36

okay, oh, that's good. That's yeah. I mean, I remember chatting with with brokerages, kind of in that, you know, August, September period, and people were lighting their head on fire at one point. So,

Mary Gronkowski: 00:02:50

yeah, I've stressed out people, for sure.

Greg Dent: 00:02:53

Well, it's actually one of the really fun insights that we've realized as we've worked more and more in the sector, is that mortgage brokerages. Mortgage brokers in general, are actually, like, very comfortable with and used to having a bunch of compliance in their lives. And so for one more set of compliance procedures, okay, they'll, they're, they'll, you know, there hasn't been as much grumbling as we've observed in perhaps some of the other sectors we work in, perhaps, yeah, and

Mary Gronkowski: 00:03:25

you're right, we're very heavily regulated in each province, and we have to have compliance. And, you know, even ID verification that was already baked into a lot of our mortgage broker acts across provinces. But yeah, it's, it's, um, it has been a little bit overwhelming just trying to get all the processes in place, because there's just so much involved, right? There

Greg Dent: 00:03:49

is, for sure, and, and it's a whole new language for, for most of the Di's, it's a whole new language, right? Like, it's, it's just they don't speak fin track,

Mary Gronkowski: 00:04:00

right? We have a lot of acronyms on the mortgage side, but I can't believe how many acronyms there are on the fin track compliance side. Incredible.

Greg Dent: 00:04:09

I've, I've, I've joked when I, whenever I go to, well, to AML, CTF conferences, anti money laundering, counter terrorist financing conferences, we actually joke about how many acronyms we're throwing around all the time because, yeah, it's mind blowing, as have, yeah, yeah, exactly. So I thought it'd be interesting. I'm glad to hear that it's that the general view is that it's going well. What I thought would be really interesting for our listeners would be to do a bit of an exploration on tales from the trenches, some of the pain points that we're starting to see, and maybe ideally some patterns of the pain points, because I think that would be the most helpful for for people. Now you and I had talked a little bit off air, just kind of listing out a few. So was there one in particular you you wanted to to start with? Yeah, yeah. Well, was. Situations

Mary Gronkowski: 00:05:00

are popping up now, right and and they're difficult to respond because we're getting a ton of questions. We're trying to help our brokers, our compliance officers, as much as possible, and give them proper advice. So there's one situation that came up, and it came up a few times where a client name was found on a UN sanctions but cleared Canadian sanctions list. And this has happened a couple of times. And the the broker working with the client, it was a past client that they had initially worked with at the bank when they, you know, when they were an employee at the bank. So they've known this client for quite some time, and they're providing all sorts of documentation and getting extra ID. How do you then verify that this is not the same person? Because the name had a very similar name, let's say, sort of like a, you know, a John Smith, sure, and this name was very common, and how, how do you proceed in that respect? You know, how do you prove that this is not the same person, and how do you allow the broker to go ahead with the transaction? Yeah,

Greg Dent: 00:06:13

it's actually, it's an interesting question, because it's something we get on our system with our users frequently as well. Well, frequently, No, fortunately, we don't have that many hits on our on our various lists, but it comes up with some regularity. And I guess the conceptually, and I don't know in your particular case, or in that broker's particular case, what lists with how they were accessing the lists. But for the list to be useful, you'll need to be able to have access to personal information of the sanctioned individuals. So frequently, birth date is available. Frequently occupation is available. Sometimes you'll have some of the lists will show will have aliases, or actually, all of the lists will have aliases built into them. And so what you're trying to do is disambiguate. Disambiguate using those some of those other characteristics, birth date is the most obvious and the easiest one, if you're if the person you're sitting face to face with has a different birth date. Well, look that we've got a really good answer, but it's it's going to the next level of, of not fuzzy, of a fuzzy matching and conceptually, that's the challenge. We're all up again, all up against the the story I like to tell is, there is a there is another Greg dent. He's a, well, there's actually two other Greg dents that I know of. One's a bodyguard for Taylor Swift, oh and, and and one's a football player in Florida who was accused of sexual misconduct. Oh, no. Now, yeah, now I'm, of course, I'm neither of those. Greg dents, there's the easiest way, I know that is because our birth dates are vastly different. And so that's fundamentally, that's the first thing. Now, if you were to push me and say, Well, what if the birth dates are the same? I think if the birth dates would are the same, I would probably not want to move forward with the transaction perfectly honest with you

Mary Gronkowski: 00:08:12

exactly, exactly. So we do need to find out what, what other characteristics showed up, not just name, but Date of Birth would a sanctions list also pull in social insurance number or no? That wouldn't be something that it would cap. I

Greg Dent: 00:08:28

haven't seen it. It's not to say it wouldn't necessarily, but it depends on the granularity of the data. Some of the challenge, of course, is that how your provider, or whoever the provider of the list is for you may choose to expose certain amounts of data or not, so we and frequently, there are rules around the amount of data they're able to provide, specifically because you don't want to make it easy to circumnavigate this either, right? They can well imagine the John Smith, who is on the terrorist watch list, would probably like to be able to buy and sell and absolutely and move their money. And if they can, if they understand the data points that are being used, quote, unquote, against them, then they're going to be able to try and circumnavigate them with with fake documentation or whatever,

Mary Gronkowski: 00:09:16

right? Yeah,

Greg Dent: 00:09:18

now that's that's interesting.

Mary Gronkowski: 00:09:20

We had a recent situation where the borrower provided fake ID, and then, oh, we got actual real ID, but the fact that he provided fake ID sounded all the alarms and red flags went up, and now they're they're looking at doing more due diligence on the file, finding out why, you know why? Why was this fake ID available? So a lot of different scenarios are popping up and raising red flags.

Greg Dent: 00:09:54

Yeah, that's a fun one. That's a really fun one. So the individual act. Accidentally showed the frontline staff member or the broker, in this case,

Mary Gronkowski: 00:10:04

an ID. And this broker was smart, because with driver's license, in particular, each province has a website you can go to and enter the driver's license number, you know the identification number, expiry date, the name, and it'll tell you whether or not it is valid. So I think that's you know, how they came across US, and then they confronted the the borrower with that, and all of a sudden they got an actual valid ID.

Greg Dent: 00:10:38

What do you do in that city? I Well, Oh, that's interesting, because I think the fact that they attempted to use fake ID by from a from a purely money laundering definition, point of view, is attempting to obfuscate their identity.

Mary Gronkowski: 00:10:56

Er, right away, that's an STR filing, right?

Greg Dent: 00:11:01

Yeah, I would then absolutely 100% to me there's, well, okay, I never say 100% but there's a reasonable percentage that person should probably or that that di should be filing an str. Based on that, I would suggest that I'm not sure that that's enough of a weird situation as a business owner. And this isn't an A this is me taking off my AML, CTF hat. This is me just looking at is from a risks point of view. I'm not sure I'd want to continue working with that individual, because there's now evidence that they're I mean, look, let me put it this way, Mary, do you have a piece of fake ID? I don't mean to put you on the spot, but the answer for me is no,

Mary Gronkowski: 00:11:51

no, no, maybe when I was 17 or

Greg Dent: 00:11:57

Yeah, no, I'm kidding. I'm not going to tell whether I did or not then, but certainly at this point in my life, that's just not something I use, nor would have any reason to own. And the very fact that they own that, to me, raises enough of a red flag as a business. And it's not even again, it's that I'd be worried about what else they're trying to do. And keep in mind, if we go to like the core of what we're doing here, anti money laundering is important because we help prevent criminals using the legitimate money system to to bring their proceeds of their crime in. But it is actually also just illegal to assist in money laundering. And, yeah, period. Like, like, ignoring your fin track obligations, like, if you are asked to help somebody launder money, and you say yes, you are breaking the law and, and to me, what's interesting about this particular scenario is that might be enough of a red flag that I would just not want to be involved, because the risks of assisting with money laundering are too high all of a sudden, right, right?

Mary Gronkowski: 00:13:12

So you can understand these are the type of questions I'm getting, and so it's really trying to make sure that they understand the overall picture, right, and what their responsibilities are in this case, right? Yeah,

Greg Dent: 00:13:24

no, totally. Pretty fun. Pretty fun. Like

Mary Gronkowski: 00:13:28

I said, Never tell moment, yeah, yeah,

Greg Dent: 00:13:32

one of the things that I've seen come up on my side and has been kind of entities, and whether those entities, and we were talking a little bit that most of the time, that's going to be a corporate shell, frequently, it's a hold code that they've that they've established, and that's that's pretty usual. But I was, I'm our support desk right now is in a conversation with a mortgage broker around a trust, and it's a, I don't know if it's a family trust or a business trust or whatever, but similar kind of concept, the core of the question is getting to that beneficial ownership piece. And have, have you been finding that that's been difficult for people to wrap their head around? Because I know we certainly have been seeing a lot of questions

Mary Gronkowski: 00:14:17

on it well, with our professional, commercial mortgage brokers, experienced mortgage brokers that deal heavily with corporations, partnerships, trusts, they already know that they have to identify beneficial ownership so they get it and they understand it. And you know anyone owning 25% more or more and shares are considered a beneficial owner, right? So and they understand what sort of documents they can get. So it's not just identifying who the beneficial owners from what I understand, it's also confirming the accuracy of what they gave you, right? So. Yes, articles of incorporation or shareholders agreement, partnership agreement, whatever that is. And in your situation, the trust, there's got to be documentation that we can get as well. But the individual, the residential brokers that come across a commercial deal every now and then may not be experienced at asking those type of questions and drill down deeper into who are the actual owners of this company? Because, from what I understand and correct me if I'm wrong, but 70% of the, if not more, I heard, a really high number of money laundering is done through corporations,

Greg Dent: 00:15:40

through I mean, I don't know if I don't know about the stat this, but that sounds directionally. That sounds right, which is to say, like the it is much easier for someone to launder money using various shells. And that's actually like it. It almost sounds silly to say it. It's so obvious, because the concept behind laundering money is that you want to not be able to be identified, because, by definition, you remain involved in criminality and are trying to get the funds in so as many corporate shells and trusts and partnerships that you can kind of layer that into to hide who you ultimately are is exactly so, and probably right on the number,

Mary Gronkowski: 00:16:28

yeah. And you know what? We have a huge gap in the mortgage industry. We have a learning gap on that side of the business. You know, we don't have really good training on these type of transactions, commercial transactions, we were very limited in terms of education and knowledge in that we've got some really good, experienced commercial brokers that that I would love for them to put together a course, because this is, it's a gap in our industry, for sure.

Greg Dent: 00:16:58

Yeah, that's interesting. We we've been, I mean, look, I think we've been seeing a lot of the same questions, but we've also been seeing a lot of the same questions prior to October from the real estate sector, which has kind of the same education gap, where, you know, a realtor just doesn't necessarily understand what a corporate structure is, because it's just not part of their training. That's that's lawyers get that kind of training, yep. And what becomes really complicated, and why it's really difficult not to crack is that each province actually, sorry, I'm going to take this bigger each jurisdiction, because there are nationally registered corporations as provincially registered corporations. Then you get into the states, and it's a whole different framework, but each of them are going to have differing levels of documentation with with really problematically different names, even though sometimes it's the exact same information on these two different forms. So

Mary Gronkowski: 00:17:57

that's right, and they may not know what they're looking at. So some of our experienced commercial brokers approached some of our regulators and said, Listen, we need a different separate licensing, classification and education and requirements for commercial mortgage brokers. And I have to agree with that. You know that it's a different level of knowledge, and it would be good to have a separation between the two.

Greg Dent: 00:18:22

Well, you're absolutely right, but, and, but the challenge that we face is that, as you quite rightly said, there are some residential mortgages that are set up in corporate shells as well. And you know, there are, and so unfortunately, even the Residential Brokerage brokers, sorry, need to have enough of an understanding, enough of a cheat sheet to navigate their way through how to identify the corporation, the trust, the the not for profit. That's another one that kind of falls into that category of weirdness. So, yeah, yeah, well, and for what it's worth, we do have some resources. They're not bad, they're okay, they're good, okay, I gotta say they're good, but that we do have some resources to help with. If people wanted to reach out, we're certainly happy to share that for sure. So okay, and then, I guess so. The other thing that we had talked about was IDV and dual process, and ultimately, ID and clients, quote, unquote, properly. What? What have you found on this? Because, certainly we've been having some interesting conversations. Well, with dual method,

Mary Gronkowski: 00:19:39

I think the confusion is, you know what's would sort what would qualify. So first of all, because we get a lot of documents, brokers think, oh, a t4 from an employer, I've got their name, address, sin number, but an employer is not a reliable source. So it's first understanding. Planning, the documents you receive must be from a reliable source. Number one, meaning government, provincial right, federal government, office. Right, Crown Corporation or a bank or financial institution, Canadian financial institution, so it's first identified. Do I have a document from a reliable source. Number two, what many don't understand is that those two pieces of documents that are completely independent and separate must identify either name and address, name and date of birth, and name and bank or financial institution account number. So you can't have two pieces identifying only one or confirming one of those items, right? So it must confirm two of the three, and then you then it's check you've got it right. So it's not just having two pieces of documents, like some brokers were thinking, and they can. And like I said, they we get a lot of documents, but some don't qualify for dual method, so it's really understanding what qualifies.

Greg Dent: 00:21:06

You've hit the nail on the head on this one, honestly, in my mind, because one of the reasons that we've been really reluctant to look when we write policy and procedure manuals, part of the conversation we're having with the compliance officer is, what forms of ID verification are your brokerage going to be comfortable taking? And we generally try to encourage people away from including dual process for exactly because of the complexity that you've just identified, and it's just the risk you run is, I believe the risk you've run is that when you don't ID somebody properly, you expose, well, you've reached your own policies. And so one of the rules that I try to live by when it comes to FINTRAC and fin track, compliance is whatever you say you're doing, you better be doing it and and you know, if you say you're doing dual process, but you end up not doing dual process properly, you're actually going to get, I think you're going to get in more trouble than if you said, Look, we're just not doing dual process because We don't, we can't understand the risks, and we don't, it's sorry we can't manage the risks properly. And because that's perfectly acceptable, you're, you're allowed to say, look, we don't accept you a process. That's not a thing in our

Mary Gronkowski: 00:22:33

Yeah. And I think if brokers have a really good process, for instance, there's a compliance file checklist that every broker has to check off and make sure they have in their file in order to get paid your commissions, it goes through an audit process. So on that checklist, if you are using dual method, you should check off which which forms you're using and which one of which of the three categories. Did you know, if you have a really good checklist and you're checking off the boxes, it's also a training tool, because it's reminding them, okay, these two dog, if I have a Notice of Assessment and a property tax bill, that's only confirming name and address, so I can only use one, you know? So I think it's just having the right process, the right checklist, and making sure there's also training, good training as well. Because you have to understand, on the broker side, we do get a lot of paperwork, unlike the real for sure, we deal with a lot, like for a refinance on let me say every refinance, we will have to get the bank statement right and a property tax bill, so both those together will qualify. Yeah,

Greg Dent: 00:23:49

no, absolutely you are, you are correct. I mean, I think the Yeah, no, you're absolutely right. And I think a good checklist does solve for a lot. I like me a good checklist. And any take to me this is fundamentally our the way we the way I think we can help with compliance, is by creating systems. And a checklist is one of those rudimentary systems that becomes really

Mary Gronkowski: 00:24:16

helpful and simple, yeah, yeah,

Greg Dent: 00:24:19

yeah, we've seen on our side, people leaning into the remote ID verification and I think for what it's worth, I think that that is probably, I guess, it depends on what your what the objective is, but for what it's worth, I Do believe that a good remote ID verification process allows for a lower risk of fraud. And I mean, look, we're talking about percentages here and all the rest, so small percentages, but I do think leaning into some of the tech out there on this stuff is really helpful, particularly if you view the if you consider the. Risks associated and lowering the risks being an important part of all of this process.

Mary Gronkowski: 00:25:04

Yeah, it's crazy. It's it's the IDV is great technology. However, I'm going to tell you a story. Yeah, sure. Actual situation that happened to one of our brokers. This client of theirs was in a coffee shop, and this gentleman, just friendly guy, started talking to him. They shared a coffee, together a donut. They became friends. They would meet regularly. They'd go, you know, do other stuff together. They became friends. The client ends up going on holidays, and this friend ends up getting access to his property with a key. I guess he was watching his home for him. You know, he's became his friend. He got his ID and he he went to our broker for a mortgage and signed up and got approved for a mortgage, as if he was this other guy was on holidays, who he befriended. Anyways, the mortgage closed, and they even asked for ID. It was all done virtually, but they did IDV technology, and it passed scary physical ID. So, yeah, it's, it's, it's happening. They're very sophisticated. These guys, very, very that's

Greg Dent: 00:26:24

interesting. I'd love to hear more about that story off air, because, I mean, for whatever you're able to talk about, because that's IDV done properly, does include a step that would have prevented that process, which is the matching between the person presenting the ID and the ID itself. So I'd love to hear more about that. Yeah, yeah, yeah, no. And I mean, look, you're, you're, you're, it's an interesting story, and I've heard variations of that same story, not with ID, with good IDV use, but good but, but it is worth noting that that there is always that element of risk for sure, one of the things that we had talked about, I mean, I guess here, let me ask the question directly, what is the next challenge you foresee? And I think I know the answer, but I I'm going to cure you it that way. What do you think the next challenge that we're we're facing within the mortgage sector coming up now? Well,

Mary Gronkowski: 00:27:20

we know that the next challenge would be this, you know, this two year assessment of their entire business, right? And

Greg Dent: 00:27:32

I was hoping you'd get there.

Mary Gronkowski: 00:27:34

It's mandatory. It's part of the compliance, but it's, it's important to have a separate set of eyes on your whole process to reassess, are there any gaps, and making sure that you know you have corrected the gaps. And I can't see anyone else doing it, other than a company that has the expertise, who's done this before and can provide the proper advice, because it's, it's quite a vigorous process, from from what I understand, but I'm sure you'll tell us,

Greg Dent: 00:28:06

Oh yeah, no, it's, it's a vigorous process, for sure. I mean, not only is it a vigorous process, but I actually think, and I really want to highlight what you said, it's a really important piece of a puzzle, because it is, the way I like to look at it is, it's your free shot, and it's not free, but it's your free shot at a fin track examination without the threat of the massive administrative monetary penalty, or at or a sanctions letter, or a finding sorry, a findings letter with, with, you know, a bunch of action plans, minimally, just like It is your opportunity to test your program without the guillotine of fin track involved. And I think that's, to me, it really is an important piece of the puzzle, and it's something that you're that, that the industry is going to have to start to kind of wrap its head around what that looks like for Yeah, yeah, yeah. Well, it depends on when they started. You know, the people who actually wrote the program the day they were supposed to. We're now four and a half months in. So they have another 20, well, 20 or 19 and a half months to start an effectiveness review. The people who haven't managed to put a program together yet, they have a bit more time they should probably ge t on writing the program, because they should have one by now.

Greg Dent: 00:29:27

you know, I for what it's worth, I think what we've found on our side and and the mortgage brokerages that we're working with, considering the whole thing as a system and making sure that it works together. All of the pieces of the puzzle work together. Really end up being valuable in that you can it becomes a much more flexible, a much more flexible program. And I guess actually something we didn't, we forgot to talk about when we were talking about it. But highlights why what I'm saying. Right now is important is that the regulations changed, the area changes. So we were joking prior to the call, literally, this morning, there was a fairly substantial change. Yeah, we should, we should mention that. Oh, fairly substantial. I you know what? That's overstating it. But there was a change to the regs. Do you want to? Do you want to talk about that for a second, just to kind of highlight for people what that is?

Mary Gronkowski: 00:30:21

Yeah, well, it just came out this morning. And yeah, and to be clear,

Greg Dent: 00:30:25

I haven't read the guidance completely yet, so I don't think you have either. I'm not. I don't want to put you on the spot too much. But no, I

Mary Gronkowski: 00:30:32

broke it down because I thought, Oh my gosh. Like, this is, this is big. I mean, it's, it's, it's, it's a new reporting structure called listed persons and entities report, which is replacing the terrorist property report, right? Yep, yep. And from what I understand, it's reporting property and possession that is owned or controlled by or on behalf of a terrorist group, listed person or listed entity. And this property can be anything. It doesn't have to just be real estate, right? It

Greg Dent: 00:31:06

could be cash, could be art, could be a car, weather,

Mary Gronkowski: 00:31:11

yeah, so I guess these new policies, these new guidance that are coming out, brokers have to amend their current policies to reflect these additions, right? There was a list of new terror terrorists. Did you see the list of the new terrorists added on? Some from Venezuela and Mexico? And yeah, these new they're not new. They're drug cartels that should have been on the list long time ago. Yeah.

Greg Dent: 00:31:43

Yeah, no. And I think what you've just touched on, and I want people to, I want to just double click on it for a second, because it's really important to hear both of those two changes. Means that some that somebody, whether it's a service provider, in our case, doing it for you, or you as a compliance officer, doing it yourself. Somebody had to go through your documentation and make all the changes to make sure that when your program is audited, either by fin track or by your effectiveness review, you don't have a reference to a terrorist property report, because that's not a thing anymore as of March 2. Now look, there's some there's some grace. If you were to get an examination notice on March 4, it would be perfectly reasonable to not have everything in place that that would be, this isn't, this isn't a, you know, boom, guillotine hit. But if, if FINTRAC comes in six months from now, when you haven't made any effort to change your documentation, they're not going to be as comfortable with that. Well, the other thing Greg

Mary Gronkowski: 00:32:44

is, is we've encouraged our broker owners to subscribe to fintrax communications, because otherwise they won't even see that communication that came out this morning. So for those that have not subscribe to fin tracks, newsletters and notices. You better definitely get on there, because you want to know what's going on and what changes you need to make. For sure, please,

Greg Dent: 00:33:11

please, please. It's for our for people within our database, we regularly publish videos, and whenever FINTRAC issues something that's relevant, we'll make a point of kind of doing a bit of an analysis on it. But if, if you're not on our list, by the way, our lists are free, like you can sign up, just let me know we're happy to put you on those lists. But for people who aren't on our lists, yeah, making sure you're on the fin track list yourself is a really important step, because all of the changes, they do publish them, they are making people aware, and you're expected to know what's going on. You can't. You can't claim ignorance. That's not, unfortunately, a

Mary Gronkowski: 00:33:49

thing. Yeah, I know. And they get bombarded with emails, so it's good to have one person that's really on this, your AML Compliance Officer, who's watching these emails, making the changes to their policies. It's, yeah, it's, I call it the beast,

Greg Dent: 00:34:09

right? I live in, live and breathe in this beast. It's a lot of fun. I say so Well, Mary, I really appreciate you taking the time. I think this is the kind of conversation that I think is really valuable for for anybody who's listening. I suspect most of the people who are listening, tuning into this episode will be mortgage brokerages, I hope anyhow, who can find some value out of this, because they'll there. There's a bunch of tidbits that that you've shared with us that I think, I think they can take to heart if they're not currently doing

Mary Gronkowski: 00:34:40

so, yeah, well, thanks for having me, Greg, this was fun.

Greg Dent: 00:34:44

Wonderful. Thanks. Have a wonderful day.

Mary Gronkowski: 00:34:46

All right, take care.