What Bill C-2 Means for Compliance in Canada | 019

Greg Dent: 00:00:00

Hello and welcome to another episode of The Know Your Compliance podcast. I am happy to have my brother, my co founder, and the tech brains behind really trusted on with me today. Daniel, welcome to another episode.

Daniel Dent: 00:00:18

Good to be back. We said we'd do it again sometime well,

Greg Dent: 00:00:22

and we never knew exactly when, but here we are, and it is June 2025, and what has caused you to come back on the show?

Daniel Dent: 00:00:34

Ooh, Bill c2 the strong borders act. It is exciting to compliance students like us. Wait, wait,

Greg Dent: 00:00:41

are we gonna get political in this thing, or is this just a we're gonna, I mean, maybe a little, I suppose I hadn't really thought about that.

Daniel Dent: 00:00:48

I did. Yeah, it's going to be hard not to get political. I

Greg Dent: 00:00:55

suspect that's true. So let's dig in at the top the strong borders act. Why is this? And to be clear, for the purposes of our conversation today, Bill c2 has a whole bunch of stuff into it. In it, we're only focusing on the parts that relate to the pcml, TFA, the proceeds of crime and money laundering and terrorist financing Act. There is a whole bunch of other things involved, well outside of the scope of what I want to talk about. But for me and for our audience and for Daniel, the impacts it has on the pcml TFA are both interesting and worthy of conversation. So why are we talking about this today, and why is this on a docket?

Daniel Dent: 00:01:37

Yeah, so let's be clear, it's not law yet in this land, and it is probably the case that there will be significant changes before this, whatever started with this ends up becoming law, but there are pretty significant impacts to a whole bunch of different businesses and individuals in this country, there's impacts for our customers, there's impacts for our future customers. And some of this stuff is actually quite reasonable and makes sense. And people who are practitioners are going, Oh, well, finally, the law is being updated to reflect the reality or to reflect a clear need that doesn't have a huge downside. And, you know, there's other parts where it's like, oh, have you really thought about this? And that's kind of the nature of the legislative process

Greg Dent: 00:02:32

too. I think, yeah. I mean, there's, there's naturally a committee process that this will all get kind of pulled apart and put back together again, and the what that looks like at the end often is a reflection of but not quite the same. So, so let's get to some specifics. There's, I think, broadly as I see it, and I mean, if you have a different view on this, let me know. But as I see it, there's kind of a handful of categories of changes. There's some stuff around the legislative framework that our reporting entities have to adhere to. So to kind of the sub bullets there are going to be mandatory registration, or universal registration, increased administrative monetary penalties, an effective compliance program that's worthy of some conversation. And then mandatory compliance agreements coming out of the coming out of all of those four things out of that. So that kind of the the legislative framework as reporting entities. And then there's some stuff around operationalization. Is how I would call it, the big one being the cash transaction restriction, which is its own sub topic worthy of some conversation. And I think the other operationalization piece that's important and interesting, I think, is the information sharing, the personal information sharing. So does that those kind of categories align with your viewers? There are other things that you think we really we should be bringing into this conversation.

Daniel Dent: 00:04:01

Well, I mean, the whole enrollment conversation is pretty big deal too, right?

Greg Dent: 00:04:04

Yeah, that's the, that's, I think, where we start here So, and that's where I what I think, in terms of the legislative changes around regulation. So let's start with that universal enrollment for all reporting entities. And, I mean, this is the one where I heard you say it. And as a practitioner, I'm like, Well, duh. I don't know how else to bet. I mean, it's not a very eloquent way of saying it, but what are your like? So

Daniel Dent: 00:04:32

my first reaction is, well, duh. And then I started thinking. And then I started thinking more. Do that on occasion, but there are a bunch of websites of what I will describe as sketchy, financially related companies that when I go to them, I'm like, I don't know if this company is legit. And one of the things I sometimes see on those websites. There's a little badge that says, registered with FINTRAC. And I go, Hmm, okay, that's an interesting way to try and build consumer trust. If you're not a practitioner like we are, you might think that means something. Currently it's the case in most sectors that you want to register with FINTRAC. You go register with FINTRAC. Now, if you're an MSB, they can ask to do a criminal record check. And there's starting to be a conversation about fitness requirements. And you know, there's a lot of industries where fitness requirements already exist and are pretty standard. You know, your financial services, real estate licensing, like lots of licensed professionals,

Greg Dent: 00:05:53

indeed, like this, the sectors and the people most likely to be listening to us, the that that real estate and that mortgage sector stuff, you don't become one of those without a certain amount of licensing. And so there already is a bit of a fitness test on the industry side of things. Yeah.

Daniel Dent: 00:06:08

Now the fin track regime has been expanding to a whole bunch of other regimes when I think car dealership, yeah, okay, depends on the province. There's different stuff going on. And of course, then you quickly get into, and this is true for all of our industries. What is a car dealer? Is a guy that sells three cars this year, a car dealer and that there's that whole other conversation when you start getting into invoice factoring and other newly regulated very easily, very newly regulated.

Greg Dent: 00:06:44

Well, yeah, and I think I love where you're going with this, because this is the problem that the DPMS sector, sorry, the Diamonds and Precious Metals sector has been having for years, which is, at what point are you the guy at selling or the girl selling, you know, trinkets at the craft fair. At what point do you become a regulated entity? At what point do you are you required to report to FINTRAC and have a compliance program and all those lovely things? And that's, I think, where you're going with this, not to jump the shark,

Daniel Dent: 00:07:17

but that was the first place I was going with this, because that's like the most obvious one for most people, and I believe that when whatever version of this comes to pass, I expect that for all of our customers, we're going to need to help them to get registered. That's sort of my expectation as some something that's going to be part of our world, because I think people are going to need some support with that, but there's also a bigger regulatory question here, and this is actually where I think there's going to be significant lobbying to prevent it from coming to pass As is okay. And that's the fact that FINTRAC, all of a sudden, becomes a de facto regulator that can shut down any of these businesses because they have the ability to revoke registration. I was chatting with somebody that sits on the board of one of our large Canadian financial institutions the other day, and he was telling me, yeah, you know, we had to tell this regulator, sorry, we just can't meet your deadline, because this other regulator is currently demanding these things under this audit by this deadline. And there's already, I actually can't tell you exactly how many regulators there are for a bank right now, but I can tell you there are many Yes, all of which pose existential risks to the ability of banks to operate. Yes, and I don't think they will easily accept yet another one,

Greg Dent: 00:08:59

right? So the interesting thing, and I so, I think that's an interesting that's an interesting problem you've you've considered, and I mean, I guess I, I my view on this is different. It's the same, which is, you know, I'm always concerned about regulatory burden and the burden that businesses have as a result of doing whatever it is they're doing in the marketplace. For our clients, the small businesses, the burden of of having to or of having to enroll and to maintain registration that, in and of itself, is actually a burden that many of them just aren't ready for, honestly,

Daniel Dent: 00:09:44

huge, but so one of the keys to our success, I think, has been the fact that we serve the single person brokerage, the five person brokerage, the two person brokerage, the multi 1000 person. Brokerage like we span the gamut within the industry, in the sectors that we operate in, one of our core values, in fact, has been to find a way to find solutions for all of those people, despite their size, big or small, because there's different challenges at different scales, let's go to RBC scale. How many legal entities are there involved in RBC business? Many? I couldn't tell you exactly, no idea. Yeah, right. I can tell you that they have people whose jobs it is to keep track of that. Yeah,

Greg Dent: 00:10:37

right. Yeah. And,

Daniel Dent: 00:10:40

and I I'm going down that logical path because I know it's going to be a huge burden for our customers. No question about it, they will need our support with this. But let's not underestimate there's different challenges as you get larger. And I think there's everybody that is going to have some level of challenge with it. Some people have the resources to

Greg Dent: 00:11:03

do it. Yeah. Now what we haven't said yet, funnily enough, is that this is one of the things in the proposed legislation that I think almost for sure happens. Like I just, I can't see a path where this doesn't become part of the stuff that does get passed. And I you know, for all of the challenges we can come up with as as a result of this. This one, unfortunately or fortunately, depending on your view of the matter, this one probably comes to pass

Daniel Dent: 00:11:30

some variation of it. Yeah, because like so we work primarily real estate and mortgage, and I know that there is a working agreement. It's public that this is the case. There is working agreements between FINTRAC and the real estate

Greg Dent: 00:11:52

regulator here, yes, in DC. Anyway, yes, right.

Daniel Dent: 00:11:55

And I'm making that connection because FINTRAC needs to have a way to systematically manage the money laundering risk in their country. And they're really scaling that up. We're seeing a whole bunch of people getting e car notices

Greg Dent: 00:12:13

a lot. I just did a compliance officer corner on that earlier today. In fact, yeah, yeah,

Daniel Dent: 00:12:19

yeah. And so how do they decide who send that out to? If they don't even know who a real estate broker is?

Greg Dent: 00:12:27

Well, and that's just it, right? And I think you know, in real estate to to our earlier conversation, because there's a licensing body already in place nationally. Well, sorry, provincially, but across the country, there's actually a pretty there's an easy place to go get that database already. You start looking at car dealerships. Fact, invoice factoring Diamonds and Precious Metals, that's just not the case that there's Yeah. So I think, anyhow, I think that happens. Let's, let's move to staying within the kind of legislative obligation side of the the of the things that are being proposed here, what about, I think the effective compliance program is one that caught my attention as being important and interesting and almost for sure to happen as well. Here's here's, my view, is that it sounds really like a nothing change, the the the person or anything shall ensure that the program is reasonably designed, risk based and effective. That's kind of so bland. It's almost like a no brainer. Yeah, obviously that just is something people should agree to. And I think for sure, I would be surprised if this didn't happen. Why is this one significant, and why is this one important? And why should this one happen? In my view? Sorry, I should. And if you disagree, make the case the other way. I suppose

Daniel Dent: 00:13:57

so. This one I would describe as a codification of existing practice. Yeah,

Greg Dent: 00:14:04

that's probably a good way of looking at it, actually. Yeah, right.

Daniel Dent: 00:14:09

I think that currently they're not necessarily directly calling it out in those terms. But if they say, hey, you need to have a properly trained person, which they do, that's part of the legislation. And if you have a program that is not effective, then it's a pretty easy argument to make that a properly trained program person would be able to recognize that the program isn't effective and would have a problem with it. I can make the argument a whole bunch of different ways. You know? You can say, hey, look, you keep not catching these really obvious, glaring money laundering circumstances. We're going to fine you for that. And like. Yeah, it's hard to argue that the expectation here is not this already. It's just that it gets enforced in a different way right now. And I think this makes it simpler for them to directly enforce the thing that actually matters a great deal and that we see that they already care

Greg Dent: 00:15:20

about, yeah, and, I mean, I think, just to kind of belabor that point for just a brief second, the some of the recent amps that have been published are very clear that program and having an effective compliance program is actually the goal here, and they are finding people for not simply for not having an effective compliance program, regardless of what's actually happening operationally or not. And so a well documented program becoming codified just kind of makes sense. Okay. Well, so yeah, just

Daniel Dent: 00:15:56

gonna put one more thing there, reasonably designed, risk based and effective. So you grab a template, you print it out, you put your name on it, you stick it in a drawer. Is this reasonably defined? No. Is this risk based? No. Is this effective? You haven't even read it. It can't possibly be effective,

Greg Dent: 00:16:23

right? Well, look already on the in the current guidance published on the site, is my favorite line, which calls that out already. So I mean that what? And to your point, the sectors we work in have had this as a ongoing problem, a new problem for the mortgage sector, an ongoing problem in the real estate sector, where templates are relied on to a point that templates shouldn't be relied on, or and or somebody else's program is copy pasted and is suddenly yours, and that's not. It's none of those things as well. So this just not spin track the language,

Daniel Dent: 00:17:08

yeah, it's not fit for purpose, right? Yeah,

Greg Dent: 00:17:12

yeah. So along the same vein, we see increased administrative penalties under the amps increasing that dramatically. This, to me, this brings us more in line with the American model of anti money laundering, where fines are significant and sometimes punitive on some level. Dare I say it, what is your what are your thoughts on this one.

Daniel Dent: 00:17:41

See, for me, it gave me European privacy legislation. Vibes, oh, we're

Greg Dent: 00:17:45

gonna get to privacy in a second. Don't you worry. There's another one that more directly comes there. But

Daniel Dent: 00:17:53

yeah, well, yeah, we'll get there. Specifically, what I was noticing was the entity's gross global revenues. And because, look, the small businesses face problems because of their small size, the big businesses all of a sudden have a huge incentive to actually get this right and invest at a level that achieves the result, rather than a level that they think they can probably mostly defend. But if they can't, then it doesn't really matter anyway, cost of doing business conversation,

Greg Dent: 00:18:33

yeah, now where that penalty can be so significant that there is an actual risk, and so they're going to actually do things ahead of time to to make themselves compliant, is what you're suggesting. Yeah, yeah.

Daniel Dent: 00:18:47

And so significant that you know any finance related thing, there's going to be a question of, are you properly, properly capitalized in the context of this risk, right? And that's true for the insurance companies as well. And who knows exactly where that spills into but yeah, okay,

Greg Dent: 00:19:14

and then was there other pieces of let's see, yeah, the mandatory compliance agreements that part naturally follows and is probably just a good tool that that fin track can can get. Yeah, it

Daniel Dent: 00:19:29

changes things, though, right, right now. That's one of the tools in fin tracks box for nudging people along. It's not necessarily a thing that happens every time. And you know, there are people that play a game of waiting until they're forced to do something that they know that they kind of have to do anyway. And this really. Speeds up the process of them doing what they have to do anyway, so it reduces the benefit that they have from doing that. And so all of a sudden, it does shift the calculus towards, oh, maybe you just need to do what you were supposed to do in the first place.

Greg Dent: 00:20:18

Yeah. I mean, I've had conversations with managing brokers who I respect a great deal, in fact, but who have said to me, Well, I'm going to leave this unsolved until my next examination, so that that's what I have to solve at my next examination, which changes that that math a little bit. The other interest actually, to be fair, the other interesting thing about these is that they will be made public. I thought that was a compliance orders being made public is new in our current world. Amps are published eventually, by the way, they're not they're not quickly published, but they are published. But where compliance officers are now published. There's an increase orders, orders, sorry. What did I say? Officers, sorry. Where compliance orders are published, there's an increased reputational risk now that comes simply from, not from going back to my example, knowing you had a gap, but choosing not to fill it now has an immediate reputational risk. Rather than possibly getting a letter and having to do a compliance order and then facing reputational risk only at the amp level, this brings that reputational risk piece down a little bit, which is interesting and probably good if you believe in what fintrack is doing. Also, doing ultimately.

Daniel Dent: 00:21:44

So, yeah, so like the current status quo is that going through a fin track exam and having findings isn't necessarily unusual the moment this becomes the state of play? Yeah, I'm not sure that continues being the case.

Greg Dent: 00:22:07

Yeah, quite Absolutely. I mean, I think the moment this becomes that you're absolutely right now, and that's exactly what I was trying to say, is suddenly just hitting the minimum is no longer going to work, because the having just the bare minimum, and knowing you might have a couple of holes that's going to be what's published and and if you're serious about your compliance and you're serious about having a business that looks and is above board, you don't want that compliance order made public so I can They. Don't want that compliance order all of a

Daniel Dent: 00:22:42

sudden, no, like I can think of several of our customers that have good reputations in the community that we have worked with them, we've gotten to the point that they can get through a fin track exam and get a clean bill of health. And when we look at the past in their program before they started working with us, the community would probably be shocked to learn about all of the things that they have been getting ordered to do for years and years and years

Greg Dent: 00:23:15

and and we're not doing and we're not doing, yeah, yeah. And now there, there is an increased reason for them, another good reason to do it, if, if the other stuff, and I think what I would read into this a little bit is that,

Greg Dent: 00:23:35

on some level, Fin track is saying, Okay, we were serious, but now we're really serious. We we weren't kidding, guys, please do this.

Unknown: 00:23:46

Yeah, yeah.

Greg Dent: 00:23:48

Okay, so I think those are the those are the ones that are the most likely to happen in the current I think none of them stir up any huge public protest, or enough that they would change or anything like that, and I suspect that all of those end up taking pretty close to what's proposed, if not exactly what's proposed. Let's get on to some of the more contentious ones. Shall we? Let's start with probably the most contentious one. I Well, arguably, this is debatable,

Daniel Dent: 00:24:16

but I actually think you're going to have a different belief, yeah, just than me?

Greg Dent: 00:24:20

Yeah. Well, actually, that's why I'm kind of hesitating, because there are two that I think are going to be contentious, but the cash transaction limitations and the privacy information and the sharing, or the the information sharing, those two are the ones that I think are gonna be contentious. Let's start with cash transactions, because I think that's gonna have the most public backlash. At least I have a third one. Oh, what's your third one?

Daniel Dent: 00:24:43

The prohibition on anonymous accounts? Oh, you think

Greg Dent: 00:24:47

that's going to be problematic and or contentious? Yep, no, okay, it's

Daniel Dent: 00:24:52

it starts out sounding entirely reasonable, and then you start thinking about it some more. Are we banning gift cards in our economy? Yeah? Like, Oh, because most gift cards these days are issued by some sort of financial institution y type thing, or a good chunk of them, and it has been sort of standard practice so far to have a bunch of different really complicated ways to manage the very real risks that exist with Anonymous accounts. I can also say there is an existing exemption in the bank act that specifically requires banks to open accounts without proper identification, and that's to deal with some risks that exist around domestic violence. I can also say, like, when we start looking at a lot of these businesses that aren't financial institutions, that aren't having a history of having kind of proper compliance programs and know your customer and all that stuff, I think there's way more cases of people that aren't properly identified, then first meets the eye in a whole bunch of crazy broad parts of our economy.

Greg Dent: 00:26:09

Interesting, yeah, I know you're That's it. That's okay. Well, that's a whole. You've opened up my can of worms. I wasn't, I wasn't, yeah, I didn't think you were, yeah, point, yeah, yeah. Okay. Well, do you want to talk about? I mean, we're already down, yeah. So what's left on prohibition of honest accounts that you want to kind of delve into, that that is worth kind of chatting

Daniel Dent: 00:26:29

about. I think we can actually more easily just kind of talk about the cash restrictions, because the two dovetail really nicely right now. I would say there is one thing in here that most of our customers are going to be really grateful for, and this is the thing that I think will have the least pushback, that will be easiest to pass. And this is the notion that there it's no longer going to be possible to take cash and deposit it into somebody else's account.

Greg Dent: 00:27:06

Yes, I agree. As a practice, most real estate companies, anyway, already have it as a policy, and then affecting that at the branch level is not depends on the bank and the relationship, yeah, the rest. So I agree with you that part is actually just a good practice, truly. So

Daniel Dent: 00:27:28

good practice. But one, even that one, is actually really hard to fully operationalize. You know, you've got the little bakery that needs the temp that they only hired yesterday to go do their cash deposit for them today, because the way that they're doing their cash deposits involves a physical person doing that. That's a real problem. All of a sudden there, there's a whole bunch of assumptions that are everybody makes right now that this actually breaks. So there are some problems, and for the financial institutions, there's a whole bunch of tooling that's going to be needed. But you know, I can think of law firms where they're like, oh shit, somebody put cash into our account. This is a problem for us. They didn't want it to happen, but one of their clients just went and did it, or somebody that their client was dealing with our real estate brokerage customers, same thing like one of the things we do as part of our onboarding process is we try and encourage our customers to go have a conversation with their bankers to Make sure that this can't happen. Because our customers generally, after they have a chat with us, they're like, No, we don't want to touch cash. That is way too much work to handle that properly. But then it's like, okay, how do you make sure that you actually aren't handling cash? I know you don't want to handle cash, but people can have a way of making cash your problem when they want

Greg Dent: 00:29:02

to? Yep. Oh, absolutely, absolutely.

Daniel Dent: 00:29:06

So that's the that's the part of this that I think is going to be less controversial.

Greg Dent: 00:29:12

Yeah, I mean that part of things to me. I I think you will be hard pressed to find people who don't agree with that part of things. That part makes sense, but the part of the cash transactions that becomes problematic is carry on

Daniel Dent: 00:29:28

the part. So I'm actually just going to directly read, for this first part, every person or entity that is engaged in a business, a profession, or the solicitation of charitable financial donations from the public. Skip out some parts. Basically, you can't take more than $10,000 the only context in which $10,000 or more of cash becomes acceptable is something that is purely personal, that isn't part of some sort of business that you.

Unknown: 00:30:00

Patient, yeah,

Daniel Dent: 00:30:02

so basically a ban on cash as we know it, continuing to be this fungible thing where all dollar bills are worth the same amount of money, depending on the context. And I am wording it this way, because this is a debate that has happened extensively in the crypto community. It's a debate that's happened extensively in countries that do have cash bans. It's a debate that directly impacts the notion of what a country's currency is and whether or not it's fully convertible. You know, I'm thinking of China at at the moment when I say that, but there, there is a very the moment you start down the path of you're not necessarily allowed to use cash. You are opening up a can of worms, and there are pretty significant in complications to your economy, yeah, very serious civil liberties concerns too. I don't want to minimize that, because it's real.

Greg Dent: 00:31:15

No, I think this one is like, I, I'm, I'm a pretty big AML guy. I think AML is good, but this one, I think, is probably a bit of an overstep on some level, which is to say, like the fact that my legal tender is really only legal tender to 9999 sorry, to $9,999 but the dollar beyond that, it is effectively no longer legal tender. And then I'm being dramatic for the purposes of illustrating the point, that creates some problems for me. So yeah, and, and to be clear, like, this is not a use case I actually have in my day to day life. In fact, I can't, I don't think I've ever had a use case for this, but I think I ought to be able to have that use case, and that's where I think it's a problem.

Daniel Dent: 00:32:02

There is a global experiment right now I would propose you have a bunch of jurisdictions that are entirely, or almost entirely, banning cash, and you have a bunch of jurisdictions that are specifically making sure that cash continues to be an option, even in cases where it might not actually make business sense and, like, not actually be an economical thing, yeah, yeah,

Greg Dent: 00:32:28

this is one of those moments where we we as a country, are going to have to and I think there's a conversation that I really hope we have as a country around is this really The path we want to go down? This is a bit of a a bit of a side note, but it is directly related. I was talking with someone I know who works at one of the local municipalities here, in their cash department, there, sorry, in their cashier department, and in the season of paying property taxes, they regularly have millions of dollars of cash come in to pay property taxes. Now is that something we want to stop? Actually, I don't know. Seems to me like that is a fairly reasonable use

Daniel Dent: 00:33:17

case of cash. So of all the use cases that is hardest to make an argument against. It's actually the payment of taxes. Like, like, at all right, like, if you think about the thing that really fundamentally gives a currency its value, it's the taxation powers

Unknown: 00:33:39

country paying the government. So, yeah, hopeful. That's why I think it's a funny thing to bring in. Yeah, I love that you brought that up. Yeah.

Greg Dent: 00:33:47

Okay, so that's going to be controversial. There ought to be some national conversation debate about that, and I certainly hope there is. It's not really my role, but I suspect that people will be taking that on and having that conversation. Let's get to the one that is also controversial, the personal information sharing, or the public private information sharing, is probably better phrased as and go.

Daniel Dent: 00:34:13

So there's this complaint that I know exists, and it's a really valid one, and it's one that this would change. The complaint is, we do all this work, we submit all these suspicious transaction reports. It goes into the black box, and nothing happens with it. This proposes to change that. Well,

Greg Dent: 00:34:35

yes, maybe I don't actually think that's what this proposes to change. I would disagree a little bit, which is to say, I would be very surprised if the result of passing this as it currently is, is that FINTRAC were to tell us, Oh, by the way, we arrested so and so thanks to your intelligence. That's not the direction I think this is going, nor is it the intention, I think, by the way,

Daniel Dent: 00:34:58

so. So I'm going to bring up two things that are going to be related, both politically controversial. One is Canadian. One is American, because anti money laundering. Like, yes, we are a Canadian company. We're focused on the Canadian market. Our operations are Canadian where we are Canadian in every shape and form. We keep the data in Canada, like

Greg Dent: 00:35:21

the whole, whole bit, yeah, but we are

Daniel Dent: 00:35:25

also really aware that Canada is part of international regimes, and the things that happen in other countries end up becoming Canadian legislation. So we we keep our eye on what's going on around the world. In Canada, we had the freedom convoy. And in America, there was Operation choke point. And there is an argument that the way that the protests in Ottawa were quashed was through effectively, Fin track,

Greg Dent: 00:36:02

Yep, that was certainly part of the, one of the tools that was cutting off the supply

Daniel Dent: 00:36:09

of, yeah, like it was, it was one of the tools that was used. And there is a lively debate on the appropriateness of which tools were used, and I'm not touching that one today.

Greg Dent: 00:36:24

Oh, we're not going to get that political.

Daniel Dent: 00:36:28

I'm just saying that I know that this happened, and I'm pretty sure it had a pretty big effect. Yes, Operation choke point was this thing in America that a lot of people kept. A lot of people don't want to acknowledge happened. But people's bank accounts were getting shut down based on what industry they were in, based on there was a level of political control over access to the financial system that a lot of people would have very serious concerns about, whether it is appropriate for that power to exist where it did, and that fundamentally, I think, like there's the information sharing part of it, and when We start talking about privacy in the abstract, people don't normally get too worried about that when you start talking through, okay, what are the consequences of you not having this privacy? That's a different conversation. And you know right now, there's already a very real problem with people getting de banked and de risked and certain individuals and certain industries not being able to have access to our financial system. Yeah, yeah. When you can piss off some local cop, he makes an attestation that maybe didn't have a lot of a sufficient oversight,

Greg Dent: 00:38:05

due diligence, due process, etc, yeah, yeah. And

Daniel Dent: 00:38:09

when the call this, when the consequence of that is not merely one bank account getting shut down, which is already pretty bad, but systematically being banished from our financial system.

Greg Dent: 00:38:23

You cease to become an individual in this country effectively or Well, I mean, you cease to become a person who can operate effectively in this country anyway. Yeah, yeah.

Daniel Dent: 00:38:32

There's gonna be some pushback on that. And I think right now that's a very real concern. And I think it is really hard to build a system that's going to have the kinds of checks and balances to make it so that as written, that this works. Yeah,

Greg Dent: 00:38:55

I this is so I this is one where I certainly hope that there is extensive conversation. There's two that I hope that there's extensive conversation. And this is the other one really, because I there are some elements of this that are little probably overreach, probably the best way I can frame this.

Daniel Dent: 00:39:22

Most people are good. I believe that I do right. Most of our law enforcement are fantastic. Most of our bureaucrats like there. When I look at our society as a whole, the estimate I've seen some people that like work in customer service will say is that 4% of people are assholes. It's

Greg Dent: 00:39:47

an interesting number, but the

Daniel Dent: 00:39:49

number is whatever it is, but it's not most people. And the thing when we start looking at policy on a national scale is we all. Always have to remember that those people exist, and we want to make sure that they can't have outsized impacts. Yeah, that's exactly right.

Greg Dent: 00:40:09

Lovely. Well, I this has been lovely. This has been a good kind of brief walk through the parts of c2 that I think are relevant to what we do as a business and what and the industries that we serve in particular. So I hope it's been helpful for our listeners. Daniel, I want to thank you once again for coming on. Always good to have you on the pod, as it were. And, yeah, look forward to having you on again, I'm sure in the not too distant future. Yeah,

Unknown: 00:40:37

it'll be fun. All right.