Why Consumer Data Privacy Matters, and How Credit Unions Can Prepare for Regulations

By now you’ve probably heard of the California Consumer Privacy Act (CCPA), but if you’re not based in California, you may not be paying much attention… yet. Ben Herman, the CEO of MadFish Digital, joins us to talk about how the CCPA is setting a precedent for a wave of similar regulations that will keep growing in strength and complexity, much like ADA. He discusses the specific steps credit unions can take to be out in front of this trend, whether or not you’re based in California, and the ways in which COVID-19 has only heightened data privacy concerns.

 

Key takeaways

1. CCPA is a California law that impacts credit unions right now, assuming they have at least 50,000 visits a year (technically devices) from California. It is the first in a wave of similar regulations that will keep growing in strength and complexity, like ADA. Even if you don’t have a presence in California, it’s important to start preparing now to avoid getting caught flat-footed.
2. Like making websites accessible, protecting data privacy is the right thing to do, and credit unions can build member trust by being out in front of this.
3. People are going to keep reading articles about data being stolen and get frustrated, which will drive continued change, especially when people’s stimulus checks or unemployment benefits are stolen because of leaked data.
4. Protecting data privacy isn’t something any one department can work on in isolation: it touches legal, marketing, IT, and compliance.
5. Regulations like CCPA may make your marketing work harder on multiple levels. You might end up with worse data about what is working and what is not working, and it might be harder to personalize messaging to a visitor.

Read the full transcript:

Cameron:
Hello, and welcome to another episode of The Remarkable Credit Union podcast. We created our podcast to help credit union leaders think outside of the box about marketing, technology and community impact.

Cameron:
Each episode we bring on expert guests from inside and outside of the industry for conversations about innovation. Our goal is to challenge your preconceptions about business as usual. And provide you with actionable takeaways, that you can use to grow your membership, improve the financial health of your cooperative and magnify your positive impact in the community.

Cameron:
Today’s big question. How can credit unions stay ahead of the rapid changes in consumer privacy, so that this doesn’t become another situation like the ADA act?

Cameron:
Today I’m really excited to welcome Ben Herman. Ben is the CEO and co founder of Mad Fish Digital, a digital marketing company that is also a proudly certified B Corporation. I have known Ben for over 10 years, we met in a group that I was helping to run at the time for- We were all similar sized businesses trying to make our way in the world and Ben and I hit it off very early on. One of the smartest guys that I have met.

Cameron:
Ben also is in business with his wife. And he said that he learned how to work out hard issues in business, by starting a company with his wife when they were sharing a 500 square foot apartment. So, tips for us. And Ben is also an amateur barbecue enthusiast. Which I’m sad to say in the era of COVID, I probably won’t get to sample anytime soon. But we can get that on the calendar for sometime in the future.

Cameron:
Ben, thanks for joining us today.

Ben Herman:
Thanks for having me Cam.

Cameron:
Let’s start with, what is consumer data privacy and why should we care?

Ben Herman:
Yeah. So if you think of consumer data, that’s your information that is stored with Facebook, or Google or different accounts, or social media activity that you have. And they’re collecting data on us all. So, everything from your email address, date of birth, different attributes, things you like. And the privacy side of it is, making sure that you have the right to avoid that data from being sold or exposed and used by those companies in a profitable manner. Your data is part of the foundation for Facebook’s profits. And you’ve really had limited options to do anything about it.

Cameron:
So this is a newer area. It’s not brand new, but it’s a newer area of thinking about consumer data and our rights to our own data. And I think about the ADA act a lot, where with ADA, that was the law, that was the regulation. But the meta issue, the broad issue, was website accessibility. And the broad issue here is consumer data privacy, but why this is on our radar especially, is we also now have a specific regulation. Which in this case is CCPA, the California Consumer Privacy Act. So it’s just in one state. So I wonder if you could tell us, what is CCPA and why does it matter?

Ben Herman:
Yeah, definitely. So CCPA stands specifically for the California Consumer Privacy Act. And it has to do with having that ability to not let a company sell your personal data. And having the right to know what they’re using that data for, what they’re collecting about you and having the right to have them forget that data and not collect it. One thing to note though is, the CCPA, right now in its current form, affects businesses that have a specific criteria. Of being, 25 million in revenue or more. They pass the personal data of more than 50,000 consumers or devices. And it earns more than half of its revenue selling consumer personal data.

Ben Herman:
So there are some qualifications that the current CCPA legislation- There’s qualifications for the CCPA as it stands currently. But we do expect that to change and evolve. It’s the first legislation of its kind that’s ever been passed in the United States. It’s definitely a regulation. And I would expect it to continue to expand over time.

Cameron:
And my understanding is, I think there’s at least four other states that are also considering things like this, is that correct?

Ben Herman:
I’ve heard that too. Yes.

Cameron:
Okay. And GDPR, can you tell us what that is?

Ben Herman:
Yeah. So GDPR, is the General Data Protection Regulation. It’s a legal framework that requires businesses to protect the personal data and privacy of the European Union citizens. So visitors in Europe. And it affects all companies that deal with any type of data of EU citizens. So specifically banks, insurance companies and other financial groups. So it’s not just limited to a set of companies that meet the criteria of the 25 million in revenue, passing personal data, et cetera, as the CCPA is. It covers a wide range of- A wider net, so to speak, of businesses that are potentially collecting information on visitors.

Cameron:
So it sounds like what you’re saying is basically that, CCPA is the opening gambit of this kind of consumer privacy regulation in the US. And that that will probably grow and expand over time. Is that correct?

Ben Herman:
Exactly.

Cameron:
Okay. And also you’re correct, you are not a lawyer. I’m sorry, I didn’t think.

Ben Herman:
That’s okay.

Cameron:
You’re not authorized to give legal advice and all the usual caveats there. So what steps do you think credit unions should be taking given this? Especially if they’re either based in California or have a large membership footprint in California.

Ben Herman:
Yeah. Kind of like you touched on, obviously consult a legal expert first. But next I would think about how you handle and manage data. So considering what data you’re tracking. And getting a handle on… What you’re tracking, why you’re tracking it, where you’re tracking it. Because until now there’s- In the marketing world, for all businesses, credit unions included, there’s a ton of tools at our disposal. And they’re all super helpful for a brand. And so that will just simplify it, by saying that. You’re getting everything from attribution data, to website analytic information, to call tracking and different tools that are out there. Email collection for newsletters. There’s so many different platforms and tools people are using. Now is the time to start to get a handle on mapping out what you’re tracking and where. Because I think every business should be on top of this, because we do expect it to slowly expand.

Cameron:
So I guess what I’m hearing is, I totally agree with this. Number one, talk to your legal counsel. That’s obviously the first thing to do. But number two, basically map out the data you’re- Just even sort of the assessment, what are we doing right now? And then once you’ve wrapped your hands around that, the next step would be to come up with some kind of internal policy- You’re not overly familiar with this, but the NCUA Ben, is a group that regulates credit unions. And this is the kind of thing that will probably show up in the future is, what kind of policy do you have around this? And then the last- Or hopefully the next step would be, if you are liable or you want to start giving members or potential members more control over their data, that you could start building front end things on the website. As you said, either to communicate what data you’re collecting. And then give people the option of not collecting that data, or for getting data which has already been collected.

Cameron:
Is that an accurate way to summarize it?

Ben Herman:
Very much, yes. Exactly.

Cameron:
All right. So for CCPA, I’ve got to ask, because ADA was just this kind of beast that just kept rapidly evolving. Do you think this will be like ADA with all the lawsuits and all the confusion and anxiety and lack of clarity? Or do you think this will be different?

Ben Herman:
Yeah, unfortunately I do. I think it’s different a little bit right now because it’s so new. But I would expect us to start seeing more class action lawsuits and things of that nature. They typically, I think- It usually starts with larger businesses. Larger companies. And then they’ll work their way towards the smaller businesses. But I would very much expect it to hit in the same manner.

Ben Herman:
There’s not a lot of tools out there to double check- It’s a little bit more manual right now, to double check if somebody is technically in compliance with some of these regulations. Whereas the ADA, you’ve got a lot of different website tools out there. You could bulk check thousands if you really needed to- Of websites and then make a list of who’s not following and then go after them in a terrible litigious manner. If you so felt it. As we’ve seen, CCPA isn’t there yet. But I don’t see why it’s not going to be.

Cameron:
As someone Ben, who was really passionate about website accessibility, starting 14 plus years ago, I think it was. It sure didn’t seem like the lawsuits had a whole lot of heart or integrity to them. They just seemed like someone, as you said, running a bulk scanner and sending out demand letters. Which is too bad, because I think accessibility, just like consumer data privacy, they are really important, societal level questions for us to be asking. But it seemed like it tarnished ADA and took it away from the spirit. And turned it into a fear-based thing.

Cameron:
Speaking of fear, fear always sells, as you know. So we talked through these four levels of, step one, talk to your legal counsel. Step two, map out, wrap your hands around what you’re doing from a data collection standpoint. Step three, create a policy, an internal policy. Maybe that’s 3A, maybe 3B is put it on your website. But then step four, it would actually be giving visitors more control over their data. So as you also said, as a marketer as well, that’s really useful data. So what do you view as the pros and cons of giving visitors more control over what data is collected? Or how it’s used, et cetera? Given that it’s really useful to a lot of us and we may not be legally required to.

Ben Herman:
Yeah. The pro side is that it’s their data. So it’s their information. It’s their website browser that got cookied. We want to know more about them. So on the pros, it’s the right thing to do. It’s transparent. It’s how it should be. Somebody should know. I should know. You should know. We should all know, what and why somebody is tracking information. I’m less concerned if somebody knows which ad I came into their website from. I’d still like to know, if they have an easy way to tell me, or if there’s a way I can go find out. I don’t mind that as much. And actually, I don’t mind the retargeting and being cookied and having an ad that’s relevant to a website I visited show for me because that to me is relevant marketing. I think that that’s important.

Ben Herman:
So I think on the transparency side, that’s good. I do mind the thought that somebody’s out there making money, based on things that- My personal information of what bands I like, or selling me certain things based on attributes of my job title, or family, things like that. So, that part I’m not super excited about. It’s the reality we live in- But yeah, so the pros are that it’s more transparent and the right thing to do. In my opinion.

Ben Herman:
The cons though, are that it really skews website analytics data. So when you’re letting people opt out of cookies, what happens is… In Google analytics, you have different channels that it reports on. So you can see if somebody clicked your ad in Google search, or if they came in from an organic search engine. Or they clicked your ad in their feed in Facebook, or something like that. When you’re not cookie-ing them and you let them opt out, it all gets stored in a bucket called direct. So your traffic for the direct channel goes way up. And direct is essentially- It used to be reserved for if somebody typed in the URL of your website directly to their browser. But now we’re seeing that number skyrocket and it’s really just misattributed traffic from other channels. But that’s the best that the tools can can do right now. So the con on the- It falls more on the marketing and the tracking side, we get a little less visibility into people and where they come from for websites.

Cameron:
Do you have any information- Putting you on the spot here, Ben. Do you have any initial data on approximately how many visitors opt out? Is it like 1%? Or 100%, or 50%?

Ben Herman:
Yeah. I don’t unfortunately. Sorry, I should be better prepared with some of those numbers. But any time you-

Cameron:
It’s hard to get them, I know.

Ben Herman:
One of the things with GDPR, that I always found interesting was, you have to have people opt in to be cookied. And most people don’t opt in to it. So traffic in those geographies gets way misattributed. But I don’t know the exact percentage. My assumption is, that we’re going to see California traffic get more and more and more misattributed, as businesses are putting these mechanisms in place. Just even on a proactive level, that do business in California.

Cameron:
Yeah. Makes sense. So I guess what I’m hearing just in summary, is that the pros are, you think it’s the right thing to do and you also think it’s the future? So maybe you can build some good will and trust and be prepared as data privacy stuff evolves. But obviously the cons are, we lose a lot of really valuable information as a marketer and that could have material effects on conversion rates and business outcomes. Is that’s correct?

Ben Herman:
Yeah, absolutely.

Cameron:
All right. And I believe, if I can share this on the podcast, that you are a Homer Simpson fan. Is that correct?

Ben Herman:
I’m a general Simpsons fan, but yeah Homer-

Cameron:
General Simpsons fan, okay. Just for clarity, because not everyone may know, when you say, “We cookie someone. Or someone gets cookied.” Can we just be really clear about what that means? Because I think of Homer Simpson.

Ben Herman:
Just throwing a cookie at somebody? Or eating a cookie?

Cameron:
Or eating them all, I don’t know.

Ben Herman:
You got cookied. Yeah. So a cookie is- It’s what you call a little bit of code that gets added to- It gets saved to your computer when you’re browsing through different websites. So if you look at a certain product on an eCommerce website, if they have a certain type of tracking in place, it’ll actually save a little bit of information to a file, behind the scenes that you see, you can go clear it out and delete it. And there’s tools within the browser that let you do that. But the cookie is that file that gets saved. And then Google and other different platforms reference that file as you navigate through other websites. And it remembers like, “Hey, you like this certain pair of shoes.” And it’ll either- They’ve got code on their end that recognizes that. And will either show you that pair of shoes again or something similar that other people bought.

Cameron:
So you’re a robust shoe shopper is what I’m hearing. I’m learning all sorts of things about you. You have more shoes than Imelda Marcos, I’m sure.

Ben Herman:
Wow. I’ve got three pairs- The same three pairs. You only need three pairs- No it’s good.

Cameron:
The dangers of recording these live. All right. So, I’d love to know, what kind of budget do you think a credit union should be setting aside for compliance with this?

Ben Herman:
So it’s difficult to say. I don’t know, because the costs come in a lot of different ways. I don’t know the exact budget that someone should set aside. It’s hard to recommend it. But I do know that the issue impacts a lot of different departments. So it’s not just a marketing issue, or an IT issue, or a legal issue. It’s a compliance issue that impacts everybody. Because it affects all the departments that touch a website. IT is the group that tends to own the website and edit the code and add the different tracking mechanisms. Marketing is the one who’s using them. And legal is the one who’s helping everybody understand and navigate the waters.

Ben Herman:
So yeah, it impacts multiple departments. And I don’t know of setting aside a certain budget. But typically there’s tools that you can get away with- At least for GDPR, that were a few hundred dollars a year. That would allow you to put some out of the box tracking mechanisms on the website, that let people opt in or out of being cookied. But then you could make that more complicated or more customized for a brand if they needed.

Cameron:
Yeah. And it sounds like, as you said, putting these things on the website, on the front end, has a material impact on the data you are able to collect. All right. So the answer is, it’s impossible to say, because every organization is different. But that this should be on people’s radar. And that, especially because like ADA, because it’s like a super cross departmental issue. Versus something that really could just be handled by, say, the marketing team.

Cameron:
So what would- I’ve read up on this a fair bit. I still don’t understand all of it, that’s why I thought it’d be awesome to bring you in. I know with ADA, one of the big concerns were, there were just these big class action lawsuits. Do you have any sense as to what the potential lawsuit costs are if a credit union was found to be in violation of CCPA? Or maybe really any organization? Because it sounds like right now you think credit unions aren’t liable at this point.

Ben Herman:
Yeah. It’s difficult to- We’re just starting to see the first wave of class action lawsuits for CCPA. And so, it’s difficult to say. I don’t know that I have a good answer on what the lawsuit cost could be. And I’m sure it would range depending on a brand’s size. But-

Cameron:
Can you tell us- Maybe just even tell us about one of those lawsuits? Or what you’re seeing? I just think that’d be fascinating for our audience.

Ben Herman:
Yeah, I have to learn a little bit more about it, but there’s currently one happening right now against Ring. And so right now the lawsuit really presents the question, on whether the CCPA invalidates different arbitration provisions? So, it states that, “Any provision of the contract or agreement-” And I’m reading this off the article. “Any provision of a contract or agreement of any kind, that purports to waive or limit in any way a consumers right.” Under the title, “Including, but not limited to any-” I’m not going to read this, sorry.

Cameron:
This is brutal, man. [crosstalk 00:22:02] Online. You could, you could put us to sleep though with that.

Ben Herman:
I know.

Cameron:
So it’s a class action lawsuit against Ring and this is one of the first ones that you’ve seen. And it sounds like, what you’re saying is, basically no one really knows where this is headed, but there probably will be more. And that’s how the legal precedents will get established a lot like ADA.

Ben Herman:
Yeah, exactly. And really, if there is ever a data breach, consumers can potentially recover between $100 and $750, per consumer, per incident. And they have the ability to sue as an individual or on a class basis.

Cameron:
Got it.

Ben Herman:
So it’s a wide range there.

Cameron:
And that can be a lot of money, Ben. You hear about these breaches where hundreds of thousands or millions of user records are lost. And at $750 a record, that would be… I would imagine that can sink a company?

Ben Herman:
Oh, absolutely. So I think you have to be super, super smart and really evaluate the importance of what you’re doing with that personal data. I think, like you mentioned before, it’s disheartening that we have to have this level of regulation. It’s probably good in the long run. ADA compliance is super important. That’s a great thing. When it’s abused on the other end, by attorneys that are maybe unethical or just going after people because they can, not because they’re trying to actually help the end user. It’s unfortunate.

Cameron:
Yeah. One of the things that was sad/entertaining with some of our clients was… Some of these lawsuits would be filed because credit unions are usually geographically restricted. And so it’d be this demand letter saying that, “This person couldn’t access the website.” And it’d be like, “Well, this is a credit union, based in Southern California. And this is a user in Georgia. It doesn’t even make sense. They’re not even eligible to be a member.” And clearly it was they had one, quote unquote, super user, who they were making the basis for all of these lawsuits.

Cameron:
But at the same time, as you’ve said, it’s a really- These are both really important issues. I’m curious on that light, because we’re at an interesting moment in history. I’ve never had to do this on the podcast before, by the way, today is May 4th, 2020. Because everything changes or it seems to be changing so fast.

Cameron:
So in light of COVID and more members going online for their banking needs. A lot of credit unions basically being forced to be digital first and shutting down their branches or having very limited hours. Do you think that CCPA and maybe consumer data privacy in general will get more scrutiny or less scrutiny?

Ben Herman:
Well before I answer that question, I just- Since you brought it up, I wanted to say, may the fourth be with you.

Cameron:
Well played.

Ben Herman:
And I think it will get more scrutiny. Absolutely. As time goes on I think. You’re already seeing that with Zoom, for example. Completely different industry, but you’ve seen security flaw related lawsuits, just since the pandemic in the US started to really take hold. As more people were using Zoom, there’s more people using it noticing like, “Oh, Hey. They’re not as secure as they claim.” Or, “There’s a security flaw or issue.” And sure enough, it turns into litigation. So I do think as we adopt more- CCPA gets more… I believe July 1st is the first juncture we have. As it gets more important and more noticed by websites, it will be taking on a lot more scrutiny. Both positive and negative.

Cameron:
And then I believe- Is this correct? That January 1st, CCPA went into action, but as you just referenced July 1st is when people can start legally enforcing it?

Ben Herman:
Correct.

Cameron:
Okay. Well, I think- Ben, we chatted a little bit before the podcast and I think you said you hadn’t heard too much about this. But for anyone out there who hasn’t heard of why consumer data matters, there have been some pretty horrifying evidence of people not getting their stimulus checks and, or being denied unemployment, because a hacker got ahold of their information. Because some company had their data and maybe sold it, but probably more likely it was just sloppy and it leaked to- It was a breach.

Cameron:
And so people would go- The government tried to make it really easy to get your stimulus checks and so do some of the unemployment in different states. Some of the websites for the unemployment insurance, are meant to be really user friendly. And people would log in and these are people at the limits of their financial means. And they’d find out that it had already been, quote unquote, claimed, because a hacker went in and had found their social, their first and last name, their birthday. And then they just put in a different bank account number and poof that $1,200 stimulus check has gone from someone who really needs it.

Cameron:
So I think all of those things around data privacy are going to get amplified even more in this environment. As need and risk and usage, all get amplified.

Cameron:
All right. I want to go to some rapid fire questions, Ben. I know you’re like- One of things I love about you is you’re really smart and you’re always prepared. But you cannot prepare for this, because I didn’t send you these in advance.

Cameron:
First question. I did not know this, that you were an amateur barbecue enthusiast. What’s your favorite thing to barbecue?

Ben Herman:
Right now? I’ve been doing it for a few years, probably about five or six years. So lately, the last year and a half, I’ve really been trying to focus on my brisket game. Getting better at the point and the flat. So brisket’s probably my favorite one for right now.

Cameron:
Okay. All right. I like that answer.

Cameron:
So you mentioned that you and Corey, your wonderful wife. I did not know this, that you were getting the business going while sharing a 500 square foot apartment. And as you know, I am two and a half weeks away from B day. That’s when our first baby is due.

Ben Herman:
Super exciting.

Cameron:
I’m very excited. I have no idea what I’m doing. So what conflict management advice do you have for me and Anna, as we’re about to welcome our first child into the world?

Ben Herman:
Conflict management advice? Wow. I don’t know if I have any advice. How about an experience share? A story?

Cameron:
Sure.

Ben Herman:
That at some point, you have a nine year old, standing in your kitchen, talking to you- That you need to take seriously, in a serious conversation. And he’s wearing nothing but his underwear. And it’s one o’clock in the afternoon on a Saturday. And that’s when it dawns on you, that, “All right, we’ve gotten this far. How do I navigate this situation?”

Ben Herman:
So, I don’t know if I have any advice whatsoever, other than…

Cameron:
To take your nine year old in his underwear seriously?

Ben Herman:
Exactly. Every moment is enjoyable. Every moment is a moment. I don’t know, there’s good and there’s probably not good. But they all lead to the next one, for us at least. I don’t know. So yeah, at some point you’ve got somebody talking at you and you’re- You could reverse the questions and try and help teach the situation, but you just call it as it is. And you’re like, “Dude, you’ve got to go get some clothes on if we’re going to have this conversation.”

Cameron:
All right. That’s good. I like that. All right, let’s have another one. What’s in the trunk of your car right now?

Ben Herman:
Oh man. Hopefully nothing. I think it’s pretty clean. I try and keep it- The manual to the car and I think I’ve got a bunch of tools for it, to help if I ever need to do any work on the interior.

Cameron:
I’d recommend adding a spare change of clothes for your son it sounds like. What’s your favorite cause?

Ben Herman:
Oh, it’s one that we’re really trying to consider how to be a part of. Favorite ca- There’s a lot of causes, especially now that I think are important. But the one that I’m really enthused about for business, is 1% for the Planet. And we’re not there yet, as a business. But it really resonates with me every time I get to talk to a business owner who’s part of that. I think 1% for the Planet, it’s the way capitalism needs to go more so.

Cameron:
So it’s basically, 1% of revenue goes to environmental and social causes?

Ben Herman:
Exactly. Yeah. 1% of revenue. So that’s a pretty big deal.

Cameron:
Big numbers. All right. Most importantly Ben, boxers or briefs?

Ben Herman:
Man, these are tough questions.

Cameron:
These are tough questions.

Ben Herman:
I have both.

Cameron:
Okay.

Ben Herman:
Serious, yeah.

Cameron:
I’ve always wanted to ask that question, since I think Bill Clinton or someone got asked that at some point. All right. I’m going to spare you more rapid fire questions. Ben, thanks so much for joining today. I’d love to do a final take. Is there anything that you want to reiterate from today? Or anything that you didn’t get to, that you’d like to leave our audience with?

Ben Herman:
I think we covered it all. CCPA, I think it’s here to stay. It’s only going to expand. I think it’ll help us, but there’ll probably be some pain in understanding and adapting to it. But I do think it comes from a good place and it’s the right thing to do.

Cameron:
All right. Ben, thanks so much for joining us.

Ben Herman:
Thank you, Cam.

Cameron:
All right, folks, another enjoyable podcast. I really enjoyed chatting with Ben, really smart, funny and interesting guy. A few of my key takeaways. The first one is just that people are going to keep reading articles about their data being stolen and not being able to do anything about it and get frustrated. And this is going to drive continued change, and actually probably a lot more even than articles, especially when we look at things like people, having their stimulus checks or unemployment benefits stolen because of leaked data. We’re kind of at the beginning of something that’s just going to keep increasing.

Cameron:
I like these four steps to be prepared and not get caught flat footed. One, consult your legal counsel. Two, do an audit of your current data collection practices. Three, create a policy for data collection and usage and consider sharing it on your website. And four, add website tools to let visitors have more control over what data is collected or to have data that’s been previously collected forgotten.

Cameron:
I think it’s also really important to be thoughtful about that last option of giving visitors more control, because it will make your marketing work harder on multiple levels. Both you will have kind of worth data about what’s working and what is not working around attributing things to campaigns, and also by making it harder to personalize messaging or functionality to a visitor.

Cameron:
And then lastly, that like website accessibility, this is the right thing to do. Credit unions have a chance to really build member trust by taking a principled and ethical stand and being out in front of this versus acting like some of the other unscrupulous businesses out there are, and only acting on this when we’re forced to.

Cameron:
All right. Thanks for joining us today for another great episode. Until the next time, I wish you all the best of luck in making your credit union remarkable.