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[Music] thank you guys for being here so as Deborah mentioned my name is tiara and I'm gonna let each of our panelists here introduce themselves all right my name is Tyler Berlin on the EVP of business development for Hyper we're a technology provider for banks and credit unions I was one of the original employees with the company and as a result been fortunate to touch every aspect of our company so I sit with our banks and credit bank and credit clients across the country with their operators I I know a lot of you from the industry and also spend a lot of time with the regulatory bodies I am at commerce I'm the founder of green wave advisors I founded Green Wave about four and a half years ago I'm based here in New York City what we do is we provide financial research and analysis for the cannabis industry I'm a former sell side and by side equity analyst as well as a auditor I used to work with one of the big four also served at a bank worked at Chase wrote their policies on accounting for derivatives which is probably one of the most boring topics you could imagine but that said it just gave me a lot of insights as to how auditors think which is one of the impetus for why I decide to write a report on baking my name is andre herrera i'm EVP of banking and compliance with hyper I have over 26 years experience in financial services 18 years as chief information officer of a bank and over the last four and a half years I've worked with hyper and I deal with banking appliance issues with our clients and so we partner with banks and credit unions our technologies enable these financial institutions to bank cash intensive businesses and hire higher risk types of businesses such as marijuana related businesses so to start off there was recently a report that said that it's a release that there are 441 and credit unions that are serving marijuana-related businesses and that's up from 340 in citations reported last year Andre to start off I guess the kind of levels that can you help define marijuana related businesses and what that really what the different categories are well certainly it's also when you look in the fence and documentation from February of 2014 it defines a marijuana related business as it uses the phrase it arrived income and so if you're looking at it from Vincennes standpoint if you derive any revenue from cannabis you know they consider you marijuana related business now more from a practical standpoint at the financial institution level there's more of a three-tiered system you know in categorizing marijuana related businesses you have a Tier one type of business and a tier one marijuana related business would be someone that's product touching and so like your cultivators your dispensary is your infused product manufacturers testing companies those would be tier one companies a Tier two mrb would be a company that is deriving the bulk of their revenue they directly support those tier one merchants and then on the tier 3 level those are the businesses that have on the SE inconsequential you know contact with the business so if you're a CPA and you do the taxes for an mrb and it's a very minority you know share of your business then you'd be considered a tier 3 mrb you know obviously from a banking standpoint the tier ones have the most difficulty in obtaining banking accounts tier two a little bit easier but still difficult and typically your tier 3 types of em are B's they already have accounts and they're already within the system it's really hard to get a read on that just to your point when these when these disclosures are made by the banks they're not oftentimes actively banking cannabis businesses so what I try to do when I wrote this report was really trying to get a handle on what's going on in the banking environment really for investors to put them at ease not so much as a play as an investment opportunity but to really kind of lay things out and when I analyze the fence and data it looks like because the banks are hovering over about 400 that's what they're reporting and they disclose what the terminations are so you can apply with the then the number of banks that have been added so as quickly as a bank account is shut down another one is opened so it just it could just be the same businesses just repeating so there are often misconceptions in the industry sure so I think it's important for everybody to understand that the debit and credit networks are opposed and I hear a lot of people say well you know we understand we can't use credit cards but debit is essentially an ACH and what they're missing is the debit network is still a network and they're they're opposed I think out of necessity at this point because it still is a federally illegal product but to take it a step further it's also important for operators to realize that if you're using these forms of payments you're most likely going to put your relationship with your bank or credit union jeopardy the reason being is because most banks and credit unions don't want to know that you've misrepresented your application to an acquiring bank somewhere and their regulators are also looking at it so we have many clients who will sit down with their operator and say look we're willing to bank you but if we find out you're doing certain things that are not permissible running debit or credit products we're just gonna shut down your bank account no questions asked so we've built a product called hyper commerce that's rolled out in multiple markets and allows for permissible permissible digital commerce in all of these different markets very user friendly our banks originate those transactions on behalf of their emergence and how many types of businesses you guys have we touch every aspect of the industries that our banks bank so our banks Bank in credit unions Bank cultivators retailers marijuana infused product companies so paper commerce is the consumer to business platform and then we have hyper payments which allows business-to-business Commerce permissibly in that ecosystem January what impact have you seen on the financial institutions I guess kind of thinking from that time frame to know all right well that's a good question so when you look at the federal guidance regarding the banking of marijuana you just have you had two documents yeah you had the Cole memorandum and then you had the fencin guidance and so when the Coleman randomness ascended I think there was a lot of the debacle like a knee-jerk reaction and so some of the institutions that were considering getting the space that that might have been you know just on the edge one way or the other they put pause they hit the brakes a little bit there is actually there's only one institution that we're aware of that when the Coleman around was rescinded that they actually stopped taking any accounts and they close those existing accounts but after a little bit of time has passed I've actually seen a reversal so I think in a certain way having the Coleman remember rescinded has created a positive effect for banks and so as every day goes by and institutions are looking back and they saying oh hold on you know the Coleman Runner was rescinded and you know the world didn't explode and the attorneys and and the the DOJ didn't go after all of these bankers and so the bankers are seeing it actually safer now that that comer was ascended so it's overall been a positive effect outside of that initial will cut like a knee-jerk reaction but institutions are actually more comfortable now that that things are going just as they would before and banking marijuana and have you seen action taken against financial institutions who do bank related businesses so so we watched that fairly closely and to this date there has not been a banker that has gone to jail you know strictly for banking cannabis we have not seen any enforcement actions any civil money penalties against these bankers and so yeah I think that as long as these bankers are following the proper guidelines if they're following around banking practices and they're doing it in a safe manner with all these businesses why do you think more financial institutions are not getting into the business now that the market has really expanded and kind of given that the Cole memorandum hasn't broken down the market and everybody is not running away from it you know I think it's a case-by-case basis I think they all have different reasons for maybe not getting into the space but Mihaly regulated cash intensive industry and those industries even outside of cannabis event banking issues for years because they're extremely burdensome for the institutions trying to Bank them candidly that's why we're here but not only is the financial institutions charter on the line but also the officers of a financial institution of personal liability when banking these industries so if I'm a chief compliance officer something goes wrong in my institution I can have a civil money penalty imposed on me personally that can't be covered by the insurance policy of that institution so you know again I think that people fail to realize that not only is that Charter on the line because technically they're banking a federally illegal industry but also there's personal liability within that institution so those are the typical reasons why we see institutions shy away from it and then candidly many of them are misinformed so they don't know that they can do it they don't know how to do it so when we meet with new banks and credit unions which is nearly on a weekly basis at this point they want to know and the questions you know are look we want to bank this can we bake it and if so how and so a lot of what we do is on the educational aside from the technology side what is pricing like for that is that on the bank side is that on the the business side whose our clients are solely banks and credits there are feature sets that touch their merchants and consumer but only through that banker Freddie Matt when we think about federal legalization and the impact that that's gonna have in particular how do you think that that's an impact what prohibition ends I think you know will be like any other business and there won't be the issue of whether or not you're able to bank or any fear of banking a cannabis business do you think that the level of transparency and all of the information that is track now like the business like hyper is doing I mean how do you think that that type of information translate will there still be a need for that type of information probably on a lower scale I think right now it's very important to have the internal controls in place and to really be able to track and understand and know your customer I think that was the biggest fear if I'm not mistaken for some of these banks in that you know they had to be 100 percent sure that their customer was in compliance with the Cole memo and they just don't have the resources to kind of figure all that out so that's why I think the hyper of the world you know provides a good alternative and how I guess for all three of you how do you guys view this product it seems like it's something that could apply to many industries not just cannabis you know there are a lot of industries where you would want to know your customers customer but really hasn't been enforced because we haven't been in this situation where we're working with a federally illegal illegal product so what do you think about that well I could tell you that I mean this goes back a long time ago so I'm sure systems are a lot more sophisticated now but even back in the 90s there were procedures and controls in place to really ensure that you knew your customer when they were on boarded there was a lot of you know checks and balances but I think you know now you have to actually have to take it to a different level because where's this money coming from you know more so than just you know any other type of business well and you know in my banking days I banked a lot of cash intensive businesses I banked a lot of high-risk industries and I did not have the technology that exists today and a lot of the products and feature set that we have within hyper came from my own experience my own difficulties in my own institution and so it doesn't necessarily have to be cannabis it can be any type of cash intensive business or any business that the regulator's of the banking regulars consider a high-risk business even if cannabis was made legal today all the banks and credit unions still have to deal with the anti-money laundering aspects and know your customers so there's still all of these banking regulations that have to be followed whether the product is is is legal or illegal but you know with hyper we said all right if we can make it easier for these banks and credit unions to manage the process to deal with applications documentation transaction monitoring I mean we're currently we're monitoring almost 600 million dollars a month in debits and credits across our platform and so we put it to where a banker credit union can simply deal with the exceptions rather than having to go through and spend all of these hours and waste of time looking at each transaction and so we try to make life easier for the bankers if it's easier for the bankers it's easier for their regulators as well I spend a lot of time with the with the NCUA with the FRB the effort the UCC and the FDIC and you know when you talk to them about banking marijuana they're pretty much consistent across the board you know it's a permissible activity but we want to make sure it's done right and so they want to make sure that any bank or credit union entering the space is doing it in a proper manner and they like transparency that like ease about it and so those are things that our platform brings to the to the community it's Andres point it's it's it's important to realize that their industry is far larger than the size of the cannabis industry currently that have had banking issues far before cannabis and those include check cashers payday lenders cross-border remittance pot upon industries all those industries have had significant challenges and that's really what we were originally built for also to tell a quick story in regards to I think it's it's important to set a standard in this industry of how this industry Canas should be banked and at the end of the day that's what's going to enable the industry to thrive I got a phone call from a CEO of an institution a few weeks ago and he made a comment to me he said look I don't know if I've ever seen the technology do you provider have an effect on an industry quite like this and I said well what happened and he said well been baking the industry for almost three years I had a visit from my regulators and when they left they gave me a laundry list of data points I needed to provide going forward and my question to them was was twofold one I've been banking this for three years what's changed and two how on earth am I going to provide this information and the regulator said to him look we have institutions using a product called hyper that's the new standard and for us that that spoke volumes it you know it's legitimized everything we've done for the last four and a half years and it's also more importantly we feel like we're helping shape a standard in this industry and that's really really important for everybody extremely so we're in the process of you know doing some things with them and and they'll be able to check those boxes just very frequently be able to send out that information not even send it it's it's it's real time so we always put our institutions in a proactive not reactive approach Andre there's been a lot of conversation and in various states that are looking at state owned and run marijuana banks there's been a variety of feasibility studies what do you think is the the feasibility of those types of institutions well a lot of people that are talking about state banks have never worked in a bank before and so they're probably not real familiar with all of the types of regulations and things that you need to go through and opening up a bank and so when I hear about you know states that are looking at opening up a state-run state-owned institution a number of states ar already gone through the feasibility studies and and those have not been successful I know California is looking at that you know at this moment but to open up a new bank you have to have a federal reserve master account and it's that master account that connects all of the financial institutions together and so without that account you basically you can't cash a check you can't send a wire you can't get an ACH and so all of the things that were used to in day-to-day banking those are not available to you and the Federal Reserve has yet to issue a master account for a financial institution that is focused on the marijuana industry and so I look at the fourth corner credit union in California and Colorado of course you can go through their history and they went through literally years of the process applications suing the government and you know at the end of the day you know they didn't get exactly what they wanted and so I'm gonna say it wasn't it wasn't exactly you know what what the credit union's goal was and so with a state-run institution it's not going to be any different it's still going to have to comply with federal regulations it's still gonna have to plot comply with all of your bsa/aml you know regulations and so just simply the ownership of that institution is not going to be a magical fix for that you know is it theoretically possible you know the answer is yes it's theoretically possible but we place a very low probability on that occurring and the same thing for new institutions you know for about two and a half years every week I'd get a call from someone and say hey Andre I've got I've got three million dollars I want to open up a bank or credit union for marijuana and so I'll go through I had had about a you know 20 minutes you'll reply to that I said alright you've got you got a big building you've got nice teller stations you put a vault in there now what are you gonna do he's gonna put the money in the vault in the stare at it and so that master account is is very important you know in that you are cast solutions that exist in the marketplace and so there are vaulting companies such as like blue line that does certain cash services but from a de novo Bank or a new institution that's extremely difficult for someone to get open you know by the by the Federal Reserve you know by the time these banks if you if a new bank were to be opened by the time the cost is incurred and and everything's I've been running prohibition will I be over so what's the point it doesn't seem practical for I guess for all of you guys as you're looking at different financial institutions and the lens from hiper is a little bit different but Matt you've studied so many financial institution how difficult is it for them to get involved in banking a marijuana related business what process did they have to go through for a business to get to know for a bank to start banking those businesses well I think I think it's a matter of just the management policy they're their appetite to you know accept the risk of associated with a marijuana related business but to put things in perspective there are about 11,000 of credit unions and financial institutions in the United States there are about 7,000 in those states where marijuana is legal so that represents with so about 400 say about 400 banks and about each Bank banks about 50 businesses you're talking about 7% of the total population of the banks are banking so there's a huge huge gap and a great opportunity for Hyper to onboard all those institutions we actually believe the number is is less than 30 institutions in total in the u.s. openly banking the space when I say that I mean 10 to 15 accounts or more they have a full board buy-in they have a dedicated marijuana related business program and they're actively pursuing growth and that's that's based on a front line view for over four years in every state if marijuana related business doesn't have a banking relationship and doesn't necessarily you know know who other businesses used to make how do they engage in those relationships what are the resources and the steps that they wouldn't even need to take to find one you know I get calls daily and after years and we always try and pair a operator in the space with the appropriate institution in that state and we're happy to do that as a service to the industry I think it's important that that if if you're operating in this space prior to a transparent banking relationship keep crystal clear books get a third party forensic audit for the monies coming into your operation because if you don't you're never going to get that cash into an institution they're going to consider a legacy cash if can't prove their provenance of those funds prior to their relationship it's not going in that institution and if they do accept it it's probably an institution that isn't gonna be banking the industry long so just be aware of those things and try and be as aboveboard as possible Matt when we think about the investment landscape and of course investment in canvas is increasing how does the banking element in the u.s. affect well I think there's a lot of fear there's certainly added risk so when you do your valuation there's a risk factor that presumably would be higher because most of these businesses are operating in a cash business but I you know I personally think you know soon over the next maybe two to three years this issue will be resolved either prohibition will end or the states Act will be passed which will presumably allow banks to operate as any other type of you know to bank any other marijuana business like any other business and what impact has all of us had on tax revenue you know the fact that it is a highly cash business it's difficult for some for some businesses to even pay their taxes so what do you think the loss factor is for how that's what's being collected well because it's in a cash business I mean if you're a law abiding you know business I mean you should be collecting the taxes and depositing the taxes there's definitely the risk of you're talking about some of that money not ending up in a in a bank account I think you know to your point about making sure there's an audit making sure that there's a trail for everything would be you know probably one of the most important things but I you know it's clearly a public safety issue because not only do you have the tax revenues I mean the sales revenues from these dispensaries in these cash businesses but you also have the tax added on to that so it increases the amount one thing I think with the state of California was looking at is to have the tech beat there was a Fed window I think there's a Fed window in California where you can take your tax receipts and deposit it right into a Fed account I don't know where yeah well it is a safety issue and not just for the operators but it's a it's a safety issue for the the state and so the the states they have their places where you take your your make your tax payments and people are literally walking in with backpacks full of cash pay their taxes and so that's extremely dangerous because these these tax locations they weren't designed for handling a lot of cash they don't have all the security aspects it's not like you walk in and you have the bulletproof glass and all of these security guards everywhere and so so it's not safe and and having secure and safe electronic payments to pay taxes it's good for all of the state workers it's good for the tax collection and and also you've mentioned California you know in California you know they've had marijuana banking there for for many years but it's been disguise has been masked and and so not all of the operators you know are being are following all of new laws and regulations you know in there and so there's probably there's a lot of lost tax revenue you know in these states you know until all the licensing you know gets in place be interesting to see how things shake out because my guess is there's gonna be a lot of audits that are gonna reveal at some point that a lot of the money's not getting to where it should be and is there any way that companies know are are regularly auditing their businesses I mean are there tools that they can use or there's I mean just policies kind of SOPs in place I mean as a former auditor I would say there's but it's very nice and I don't think anybody really knows what's going on to be honest with you I think it's kind of to take some time that's reassuring it's actually required and so we've seen that a medical market where state will require that they have a yearly audit by a verified third party so there are businesses that are doing these audits pretty industry and on a regular basis so before I open up for questions but before we do that I wanted to kind of open it up to you guys on what based on your experience in the market what you're seeing what do you it's gonna happen when it comes to baking I think in this short term as we're still there in this federal illegal environment or I guess on the other side of that what do you hope will happen as the market continues programs until we get that federal legalization point I see I see attitudes changing and so about about three years ago I was at a Bank Association conference and I would just mention the word marijuana and at this it'd be Alice and crickets and it's no you couldn't get anyone to even talk about it you know about a year later they asked me to speak at their at their annual event and so bankers that had that thought I'll never ever do this are now saying all right maybe I'm in it you know now maybe I'm going for it you know they're their banks go into the sport for different reasons some are in it for community service they say okay I'm doing the community service a public service by bringing in these monies taking this money off the street and opening accounts others are saying I'm doing it for the money and others have some personal contact with marijuana they have a family member that is using miracle medical marijuana and so there are different reasons that these institutions are getting into space but more and more are open to it now than even one year ago now from a regulatory standpoint I think something that would be very helpful is to have more guidance so I'd say more regulation but in this case more regulation is a good thing you know when you go out and you look at every other banking product you know there's a government entity it's called a FFIEC and the FFIEC publishes you know handbooks examination handbooks recommendations best practices for pretty much every financial product out there if you go out to the FFIEC website and you look for the marijuana examination handbook it doesn't exist and so when a banker you know is looking at this as well I've got a rescinded cold memorandum and I've got this FinCEN guidance which is about seven pages long you know that's not a lot to go by and so having more regulations having more guidance even when legal I think it's going to help the space and so by having more specific policies and procedures from a federal standpoint will enable and it'll make more banks bill and credit it's feel more comfortable and getting into space I would say I hope that there's the banks or that have more comfort now in opening these accounts as time has gone on because it's very clear at least in my mind that the Trump administration is not shutting down this business if they were gonna shut it down that would have done so already we're two years in I think the risk to a bank is is very minimal unless you know you're with El Chapo or something you're courting in all this cash keep some kind of trade but I think and also not only just the plant touching businesses but a lot of people have been like shut down shunned out or ancillary businesses have nothing to do at all you know I'm lucky I was able to open up an account pretty easily and I have marijuana the name marijuana all of them I reap I hope that helped bankers but you know it's you know really should be something that should be a lot easier for most other businesses as well but you have seen that there it's an impact on plenty of stories of people have their own personal you know checking and bank and savings account shut down because they're affiliated with the industry I mean are you still seeing that in this space actually that goes back to that fence hidden you know guidance and so that the fence and guides from 2014 actually talks about a suspicious activity report that financial institutions have to file if they have a depository count that is deriving revenue from a marijuana related business so if you take that guidance literally if you take it to the letter then theoretically employees of Mr B's the owners personal accounts all of those would be subject to those reporting requirements and rather than have an institution saying well should I be you know do I have to file these SARS on these people it's just easier if they say no and they say now we're just not going to bank it and and they think it's easier that way by not by not having to deal with the problem but again that comes back to additional guidance further guidance better definition you know on what exactly is a marijuana related business I think going forward to again going back to money services businesses those industries are perfectly legal but they're very small number of institutions willing to bank them because of the regulatory compliance burden and I think the cannabis industry is gonna be very similar so the notion that you know if this goes federally illegal tomorrow all of a sudden every bank or credit is gonna jump into the space we don't believe that to be accurate just based on what we see on the front lines but again things are changing so with every new state that comes online there's a new set of banks or credit unions that are going to bank that state's market so that's opening up new banking as regulatory bodies like I said get more accustomed to auditing financial institutions that are making this space that helps everybody because they're starting to look for things that you know maybe they weren't aware of in the past and they're getting more comfortable with these banks and credit unions being in the space and then look the payment side of the fence is opening up we're very fortunate we've done a lot of work in this space obviously but we are about to be able to offer both our business to business and consumer to business products nationwide and that will help many people in this industry transact in a permissible aboveboard transparent manner and again all of these things contribute to legitimacy and enable enabling this entire ecosystem with thrive thank you guys I'd love to open it up to any questions from the audience right now oh we got one [Music] the actual answer is yes there are institutions are banks and credit unions that are lending directly into the space you have a couple of problems and now it's not a lot so it's not like there are 20 of those you know it's more like there are three or four of those that are lending to the space you have a couple issues the first one that always comes into my head is perfection of collateral alright so if you're a financial institution you're making a loan if you cannot perfect that collateral then what do you really have and so if I'm a banker and I've got a cultivator that I've loaned on and they go out of business am I gonna go and grab all their marijuana now what am I gonna do is I mean I'm not licensed I can't do anything with it I'm just gonna stare at it and then another consideration pass it out to the tellers you know and another issue I'm more behind the scenes is going to be on loan loss reserves and so if I cannot perfect my collateral am I going to have to have like a one-to-one loan loss reserve you know for those loans and so it's a lot of a lot of unknowns but that answer your question yes there are institutions that are lending the space typically they're doing real estate type loans at very low loan-to-value ratios so so basically you're talking about about all of the all of the individuals and so actually I wrote an article about a month month and a half ago sent out to financial institutions saying you're lready banking marijuana you just don't know it all right and so I live in Monterey County in California and and you know it's surprising how many people are touching the space I mean this Neil friends and acquaintances that I never would have thought would be in the marijuana business oh yeah I'm invested over here oh I got money over here and then you've got these mutual funds you have all the tax money so think about it every government that's collecting taxes every county every local municipality that's all marijuana money and it's all going to these banks so it's even going into your large I'll call them big institutions and so whether they know it or not pretty much every institution is it has marijuana money touching it in some manner and the regulator's understand this and so the regulator's understand that that this is something that is probably here to stay and so every regular that I've spoken to like in the last year it have been very positive discussions as I hey we know we've got to have the right and proper way to manage and audit these at the financial institution level and last one of the compliance all right so four so yeah someone you just gotta take those one by one I have to have a couple pants for a couple of those right so all of your existing banking regulations all of your customer information program all of your customer due diligence your enhanced due diligence all of your oh fak your 314 a I mean I can do this I can list regulations all day but all of those still pertain and so they're not any different all right regulators are viewing this as another financial services product they're not saying all right here your money service businesses here your car loans but your marijuana is something completely different now actually they're considering that another financial product a higher risk financial product but yet another financial product all right and so all of your existing banking regulations apply and how hyper helps is we take all the heavy lifting off of those off of those financial institutions we have things like document management digital applications we assist them with CTRs and czars I mean we have quite a long list of features that basically touch the entire lifecycle you know of banking a marijuana related business from when they're a prospect through the onboarding process the application process the ongoing due diligence which is very important also to site visit management and transaction monitoring the combination of a reg tech and a fin tech and one cohesive platform our client is the bank or credit union but one of the things we do that's that's very unique is financial institutions in the past have been reactive what I mean by that is if I'm accepting cash deposits I'm reconciling every 30 days or whatever that velocity is well if money's been laundered through my institution during that time period is too late so we integrate with most of the major point-of-sale providers in the space so if I'm a bank officer I can pull up any account in a real time I can click on a button and see every transaction happening in real time and at the end of the day I receive an expected cash deposit amount which lets me know exactly what should be coming in my door before it ever gets there so that's one of the things that help eliminate blind spots and put the institution or proactive not reactive so so our product touches consumers it touches the Mr B's and touches the Financial Institutions touches the applicants and each one of those entities they have their own dashboard and we have a very holistic approach to this and so even though you have these different dashboards they're all integrated and they talk to each other so for an example if I'm a financial institution and I need a quarterly financial all right well Hyper automatically notifies the MRB oh you've got this document that's due and then that mrb logs in to their dashboard within hiper they submit that documentation it automatically goes to the financial institution it notifies the account manager and so it facilitates and makes that whole process not only easier but from a regulatory standpoint it adds a lot of transparency so anytime someone does anything anytime someone approves a document or depended Cline's a document we know exactly who did it at the institution at what date and what time and I think part of your question is look every every institution is a little different from a policy and procedure procedure standpoint so they're gonna ask for different things so think of Hyper's technology wrapping around those policies and procedures and automating those processes so everybody's a little different yes so we have a client we have a couple clients actually that will openly bank they have based CBD market and their regulatory body feels like they they don't even need to do additional review in some cases they're very comfortable with it and we've actually published an e-commerce API and we've we've launched a WooCommerce and Magento plugin to enable e-commerce in a permissible manner for CBD operators across the country so we can help them get a transparent banking relationship and they will also have access to hyper commerce through that relationship they look for verification that it's it's have based and under I believe it's point three THC level focused on the United States at this point you know but every regulator that we've been into and we've been invited to every federal regulator you know every every regular likes that they like the transparency and you know they like the data set you know of course you know are we setting the bar high yes we are you know because in absence of specific guidance we're going to do things as right and correct as possible very few people have seen the technology in its entirety typically it's a either a federal regulator state regulator or a financial institution that's that's a good question all right so blockchain from a technology standpoint I love it I think it's great technology I think it's the future of transaction processing in the way that banks Yool process everyday transactions when you look at the cryptocurrency side of it you know so let's take away the technology and let's look at the digital currency you're bringing in something that that has a lot of anonymous sides even though you can track the ledger so I'm not talking about tracking a ledger but it's who's on the other side where did that Bitcoin come from and so I don't think that it's the right product for cannabis you know at this time because of the lack of full transparency on on who's doing the transactions where did all of those monies come from so I don't think it's the best thing for cannabis in our discussions with regulatory bodies the federal and state level a lot of the questions had been geared towards what are you seeing on the transaction side of the fence and anytime cryptocurrency is brought up at both levels they've said absolutely unequivocally we do not feel comfortable with that being involved in this space and so again if you're looking from a top-down perspective the the regulators are going to drive the conversation of the financial institutions which is going to drive that conversation down to the operator so most of our bank and credit clients if they find out their operators are running those forms of payment again they'll just shut down their bank again blockchain it's hard to yet I think you're looking a bit too far ahead but absolutely like I mentioned I like blockchain technology and I think at some point it will replace all core systems that are typically found in financial institutions but but this is something that is definitely down the road you know coming on board quicker than for the for the banking [Music]