Transcript: "A Chat with Hank" with Mark Schoeff, Jr. of Investment News

Transcript: A Chat with Hank with guest Mark Schoeff Jr. of Investment News

SPEAKERS

Hank Multala, Mark Schoeff Jr.

Hank Multala 

Well,  welcome to the podcast. This is a chat with Hank. And I'm Hank Multala. I have to apologize here from the start, I'm feeling a little bit under the weather. But thankfully, the podcast discussion I'm about to have has been recorded prior to this introduction. So that'll be a great benefit to all the listeners. So unless you've been living under a rock while working in the financial services industry, you should be very familiar with my next guest. In this chat, I have the privilege to spend some time with Mark Schoeff Jr. As most of you know, Mark is a Senior Reporter with Investment News. He writes about legislation and regulations affecting retail investment advisors and brokers. He reports and has reported extensively on DOL's fiduciary rule, on SEC's Reg BI, and other investment advice reforms, some of which are the most profound regulatory changes we've seen in a generation. In addition to this, he also covers FINRA, the House Financial Services Committee, the Senate Banking Committee, and other Capitol Hill committees and regulators. A little bit about his background. Mark has his Master's in International Commerce and Policy from George Mason University. He worked for Senator Richard Lugar of Indiana, as his press secretary during Senator Lugar's chairmanship of the Senate Agricultural Committee, as well as Senator Lugar's presidential campaign back in 1995-1996. Mark joined the Center for Strategic and International Studies as the Director of External Relations and then became a staff writer for Cranes Workforce Magazine, where he created the position as the Washington correspondent for the magazine. Besides his current role at Investment News, Mark's a contributor for Howie Politics Indiana and presently serves as Co-Chair of the publication's committee for the National Press Club in DC and also serves on the Board of Governors. I'm guessing just by this overview; Mark keeps a fairly full schedule. Since Mark writes about legislation regulation, we have the opportunity to discuss some very timely topics, which include SEC emphasis on ESG regulation, we talk about Reg BI enforcement, we discuss cryptocurrency and touch on other legislation that impacts the industry. We also discuss SEC enforcement under Wall Street's top cop Chairman Gensler and on an unrelated side note, there was an article that came out on NPR a day after my sit down with Mark regarding the new oversight under Chairman Gensler and his securities, law enforcement policy, as well as protecting amateur investors. Mark and I chat about how he got a start in journalism. The one thing I really enjoy about Mark's reporting, which is something I have read for years, he really has a keen ability to break down the complex and make it very easy to understand and comprehend, without missing the primary intent of the article. I don't think there's anyone who can match his journalistic muscles to keep our industry so well informed. And again, I'm very grateful he's given me a small sliver of his time out of what seems to be a very busy schedule. And now I bring you a chat with Mark Schoeff Jr.

Hank Multala 

Well, I'm here with Mark Schoeff Jr. Mark, thanks for your time today, and taking some time off the chat. I'm really looking forward to our short time together.

Mark Schoeff Jr.

Well, thank you Hank, for having me as a guest on your podcast, I am looking forward to our chat.

Hank Multala 

Well, thank you. With all that, that I mentioned in the intro, we have a lot to cover, and I'll be very respectful of your time. As I begin a lot of discussions, I'm always interested in areas that are kind of unfamiliar to me, you know, journalism and what you do, and I'm also interested in how people began their path to where they are no. It seems, everybody's familiar with you, I've read you for years and you're just you have an insider's perspective to what transpires on the Hill, you're very transparent. You're reporting, I know you want to be kind of down the middle of the road. So I'm kind of curious what led you into journalism and even more specifically, into the legislative and regulatory side of our business?

Mark Schoeff Jr.

Sure. Well, first, I want to make my standard disclaimer about being an insider. I am not a Washington insider. I just hope that Washington insiders returned my calls. So my job is to find them and get them to talk to me. The  reason I got into journalism is because I was too short and too slow to play basketball. I'll make this a quick story. When I was a sophomore in high school and struggling on the sophomore basketball team, it occurred to me that I will never be a be a basketball player, this was devastating for a young man in Indiana.

Hank Multala 

I can imagine

Mark Schoeff Jr.

actually, it still is today, but especially in the early 1980s. Most  boys and most girls thought that they would grow up to be basketball stars. It dawned on me I wouldn't be, and I was sort of, in a glum state, an English teacher at Fort Wayne Northrop High School, where I went to school, who was also the advisor for the school newspapers said Mark, if you can't play sports, why don't you write about them. So I started writing for my high school newspaper. And then I became a stringer for the sports desk of the Afternoon Daily in Fort Wayne. That led to my involvement with my daily campus newspaper at Purdue University and started me off on the path where I am today as a Senior Reporter for the Investment News, based here in Washington. So that's the overview of why I'm in journalism, and specifically why I'm covering legislation and regulations that affect retail investment advisors and brokers, well, that's because I was laid off in 2010. I was working for a magazine, published at that time by Crane Communications, covering employment and labor law, they eliminated their Washington position. Thankfully, Investment News, which was also published by Crane Communications at the time, picked me up so I had to switch gears and learn about fiduciary duty, FINRA, the SEC, the Senate Banking Committee, and  financial services, I had to jump in and get my arms around that so that that's why I’m, specifically on this beat.

Hank Multala 

That's pretty cool. Did you ever go back to English teacher and say, look what you did to me?

Mark Schoeff Jr.

You know, I sent her a couple of copies of Workforce Management, the magazine I worked for before Investment News and, and told her, you know, dear Evelyn, you know, now that I'm an adult, I can call

Hank Multala 

her Evelyn, not Ms. or Mrs.

Mark Schoeff Jr.

Exactly, I worked up the courage to write, Evelyn, rather than Mrs. Sersoe, and I said, you know, here's a copy of Workforce Management did the cover story, and this all started with you. When you told me if I can't play sports, you guys should write about them.

Hank Multala 

Well, I'll send her a thank you note to.

Mark Schoeff Jr.

Thank you to Hank for your loyal readership of Investment News.

Hank Multala 

Oh, yeah. It's a great, great publication. I won't even call it you know; everybody says industry rag. Now, this is not an industry rag, it's a publication. So a lot of work goes into it. So I appreciate that. I mentioned in the introduction, it's always nice to discuss very timely topics. So it's probably best to start with areas I would say most familiar to most of our audience. And I have to say it was great doing some research on the subjects we're going to discuss today, all of which, I know your hard work focuses on. Since you've been so engrossed in the reporting around, regulations and legislation that effect the retail investment advisor and brokers, I'm asking this question as a novice. In this political climate, I think the public feels, I don't want to speak on behalf of everybody in public, but it feels a lot of areas seem to be politicized along party lines. What's your professional view regarding this perception obviously, relative to your work, is a real or is it fiction? Or does it have  fictional impacts to regulators and other committees that you cover?

Mark Schoeff Jr.

It's absolutely real. Hank, you're correct. Almost every issue has become politicized and if I hear one more time, somebody say, well, Investor Protection is a bipartisan issue, it's not Democratic or Republican. Well, of course, it is. That doesn't mean that one party wants to protect investors and the other doesn't, but they have very different ways of approaching it. And everything from regulation best interest to cryptocurrency regulation, to regulation of so-called Digital DEPS, digital engagement practices, which the SEC is looking into, all of it is being addressed within a partisan framework, because Republicans are on one side of those issues, and Democrats are on another. That's just the way it goes. In fact, there's politicization at the Securities and Exchange Commission as well. The SEC majority is always based on the party of the president who's in the White House. So we have a Democratic majority right now, three, two, and they're going to pursue a very different regulatory agenda than the Republican majority did in the Trump administration. So yes, everything is political. That doesn't mean it's bad necessarily. It just means it's the reality and it's something that regulators and lawmakers have to deal with and industry practitioners like you and your clients. And your clients also need  to acknowledge it and keep it in mind as you follow what's happening here in Washington.

Hank Multala 

Right. You talked about digital engagement practice, that also goes into communications between advisors and everything. I know there was an article, you actually put it out today. It hit my desk. That's a reporting statement, which came across the wire, but JP Morgan securities, which is a BD subsidiary of JP Morgan Chase, they were fined = $125 million for communication, you know, for their advisors, staff, and associates =over WhatsApp and other, you know, other uses of technology. Is this, are we really seeing a shot across the bow by Chairman Gensler and Director Gurwall? It is, and = does this show that they're serious? How would you rate the present SEC body historically to the most recent peers that we may all be familiar with?

Mark Schoeff Jr.

It certainly sends a message to the industry that the SEC is serious, very specifically today about record keeping and they want financial firms to keep track of written communications so that the SEC can refer to them in investigations and other regulatory work. That's really set at the SEC off here is when the SEC was looking into matters of JP Morgan, JP Morgan could not produce all those written communications that were flying back and forth on WhatsApp and other texting programs and

Hank Multala 

 like 1100 communications or something like that

Mark Schoeff Jr.

as well and was one example. Yes. on that issue, the SEC is quite serious, as they said with this $125 million penalty, but beyond that, it's also a stake in the ground for this new leadership at the SEC and it’s still new. Chairman Gensler was sworn in in April, so he's still in his first year, enforcement Director Gurwall started I believe in November. This I believe the biggest case that the SEC has announced during the Gensler administration, so to speak, and one of the biggest that they've announced in  recent memory. So yes, Chairman Gensler and Director Gurwall are basically saying, the SEC is going to be a tough enforcer. We're not afraid to impose large penalties, and they're putting the industry on notice.

Hank Multala 

So how would you rate them? How would you rate them in terms of an enforcement body so far?

Mark Schoeff Jr.

Yes. Well, they're off to an energetic start. For instance, the first regulatory actions taken under Reg BI, occurred over the summer with violations regarding form CRS, firms missed deadlines or didn't post form CRS at all? So they started, Reg BI enforcement, though those were novel cases, you've got this huge penalty against JP Morgan. They've also pursued several cases against crypto exchanges. Now, I don't cover those. Each of those enforcement cases, but I know that they've been very active on crypto enforcement. So this is a this is an energetic CSIS enforcement effort. I think it'll be one of the most active Enforcement Divisions that we've seen over the nearly 12 years that I've covered the SEC.

Hank Multala 

Okay. All right. I covered some of the topics we're going to discuss in this in the intro. So let's begin with ESG regulation. I read that the push for rulemaking came from Gensler and a few other democratic commissioners. And the SEC, I know is gathering public input and is establishing a task force. I understand that from an investment standpoint, if you look at ESG, some may draw the conclusion that  companies that prescribe to ESG parameters, that everything has been vetted, and perhaps an assumption that all ESG is ESG, that  people have looked at it very carefully. So what's the purpose of the regulations is it to put guardrails on parameters of what ESG entails, can you give us your view on that?

Mark Schoeff Jr.

The proposals that the SEC is going to promulgate early next year, everyone believes, pertained to public company disclosures on climate risk, human capital factors like diversity and workforce management and so on. So the thrust, according to Chairman Gensler and the Democrats on the commission, is to give investors what they're seeking, which is more information about ESG factors, as they make investment decisions, they point to this market for ESG related investing, which is some $17 trillion. The Democrats on the commission say this is what investors are demanding, and this is = why we're following through on this. Also, the focus on ESG allows enables the SEC to play its part in a government wide effort by the Biden administration to tackle climate change. And then there's also a piece of it involving the SEC probing financial advisors to ensure that they are following that they're delivering what they're promising when it comes to ESG investing. And if they are marketing, certain investments and strategies as ESG oriented the SEC is looking into them and making sure that advisors are  delivering on that. And then there's another prong where the SEC is probing whether fund names line up with the ESG strategies that the fund is pursuing. So the SEC is pursuing several different avenues. The purpose of regulations basically is to  put more information out to investors and to ensure that investors are getting what they pay for when it ESG

Hank Multala 

Are investors looking for these disclosures?

Mark Schoeff Jr.

Well, this is, of course, something that's debated. Republicans will say, ESG is not necessarily material to  a company's financial performance and the Democratic commissioners and Democrats in Congress will say investors are demanding this information, you can tell by the way the investments they make in ESG funds, and they're used to be ESG factors in their investment decisions. One side says they're responding to the market, and the other side says, it's not material. So this goes back to your first question. Everything has a, everything is being conducted in a political context.

Hank Multala 

Yeah. I know Gensler said that, you know, climate change, and he mentioned climate changes or  climate risk, does that show the politicization?

Mark Schoeff Jr.

You know, not necessarily. I'm saying is, one side will describe the issue one way and the other side will describe it another way. Who's right and who's wrong? Well  that's kind of above my paygrade. Addressing climate risk is not necessarily a Democratic issue, the Democratic administration puts a lot more emphasis on it than the previous Republican administration did.

Hank Multala 

Right. So I want to look at Reg BI a little bit for a moment if I'm correct. I think  the brokerage advice standard went into effect. When was it at the end of at the end of June 2020? So from your point of view, is it is Reg BI is stronger than the previous suitability standard or is it or is it too weak to reduce conflicts of interest for brokers or brokers?

Mark Schoeff Jr.

That is the question. I asked my sources all the time. I don't know that I'm qualified to answer that as a reporter. I'm reluctant to  make a judgement. But I would say that Reg BI incorporates many of the same fiduciary principles that govern the principles of fiduciary duty, that govern investment advisors. However, with REG BI, there's not the same fiduciary liability as investment advisors have with their fiduciary duty. So Reg BI has a lot of characteristics of suitability, but also some thematic  underpinnings of fiduciary duty. Investor advocates will say that it is weaker than suitability. Jay Clayton, the previous SEC chairman, argues adamantly that it's stronger than suitability. So we're just going to have to see in practice how this works out. A lot will depend on the enforcement cases when they come down. That will tell us to what extent Reg BI really does differ from fiduciary duty, we'll see it in the violations that the SEC cites for firms that the SEC thinks are not adhering to Reg BI

Hank Multala 

Gensler brought in Gurwall because he was the New Jersey AG? So, you know, a lot of the documentation and disclosures, and please correct me because I'm just going through my own research here I did for our discussion, but a lot of documentation disclosures are already part of a structure of independent RIAs. I know a few years ago was at UK and the Netherlands implemented bans on commissions  due to product biases. It seems like this has been a question that's been around for a couple of years do you see you know a ban on commissions in the US at some time and  what are the dangers at passive investing or focus to a fiduciary standard if there are any.

Mark Schoeff Jr.

No commission's will be banned in the US, the financial industry's lobbying is far too strong for that to ever happen. Reg BI is the framework that's going to stay in place. Chairman Gensler made clear that he's not going to try to rip it up and start over again. But where the SEC is going to try to maybe strengthen it is through examinations and enforcement. So Reg BI does not ban commissions, I don't think we'll ever see a commission ban here in the in the US.

Hank Multala 

Mark Schoeff Jr.

There will always be a role for active investment management and charging a higher fee for them. But what the SEC is going to zero in on is making sure that those higher fees are fully disclosed, and explained, and that the investors are getting what they're paying for in terms of the services from the advisor, but the commissions aren't gonna go away.

Hank Multala 

 Earlier this year,  the Clayton Enforcement Division, there was a, a settlement against Kestra, which is fun fee disclosure. And it remains a priority. I know that the SEC issued an alert on wrap fee accounts. As the as enforcement's kind of been zeroing in on other conflicts of interest issue, give us a an overview of the risk alert on wrap fee accounts,  what are they looking at, specifically, who do you think will be impacted most to these reviews and potential settlements and, and fines or maybe the potential sediments of fine, I'm probably jumping ahead too quickly, but maybe just give us a risk alert of wrap fee accounts, what they're looking at specifically,

Mark Schoeff Jr.

Well, the SEC is put wrap fees on its examination priority lists for several years now. And they want to make sure that if an advisor is charging, a wrap fee, that  the investors  are getting some value for that fee. What really sets the SEC off is what's called reverse churning where you where you put a client in a rap fee, and then just set it and forget it. The  wrap fee is supposed to be for clients where a lot of trading is being done, and they're going to be better off with that wrap fee rather than paying per trade and the SEC is zeroing in and making sure that this is what's happening in reality. So advisors wrap fees have become highly popular and the SEC wants to make sure that there's no reverse churning, and that all the fees really are incorporated into that wrap fee. In other words, if an advisor is charging aw rap fee, and then some other fees on the side, that's going to get them in trouble as well.

Hank Multala 

I know a couple of areas that you reported on, $100 fee or reentry fee that gives reps, five years to return without having to retaking qualifying exams. To me, this seems kind of a no brainer, because it aligns with other industries,  other industries do the same thing. But the other area that I saw you penned an article was on increased requirements for private placements, which I read was a was a priority by Chairman Clayton, to open private markets to ordinary investors, if I read that correctly. Why go down this path of opening the markets up to a much broader spectrum of investors  when the complexities alone of  private placement and should say the barriers of entry  around it have been strict, you know. Why go down that road,  isn't things like this best understood by qualified investors?

Mark Schoeff Jr.

Well, this is this is an example of how a democratic SEC is going to differ from a Republican SEC. Already the Gensler SEC has put on its agenda a review of some of the private market regulatory changes that the Clayton SEC approved at the end of Clayton's tenure last year. So the democratic commissioners would raise the same concerns that you did that ordinary investor don't have the same wherewithal, that the private markets don't afford ordinary investors the same protections that the public markets do. There's not the disclosure and other requirements on issuers that there are in the public markets, the ordinary investors in the private markets could be taken advantage of and this democratic SEC is going to look more closely than the Republican SEC did at investor protections in the in the private markets. Now the Republican SEC and Republican commissioners right now in the SEC, would argue that we need to open the private markets to give ordinary investors a chance to get returns on their retirement funds, for instance, that institutional investors get in the private markets. So that's the other the other side of this of this argument. I don't know if there's a place in the middle where they can find agreement or if we went from relaxing private market rules in  the Clayton SEC to tightening them up in the in the Gensler SEC. I don't know if it's going to be just sort of turning the switch on and off or if maybe there'll be a middle ground.

Hank Multala 

If the keep turning a switch on and off., they’ll ever get anywhere. So let’s switch topics here. And I know, as it relates all the work you do to further educate and create greater awareness in our industry., One of the hot topics obviously is it's ino surprise to anyone that's cryptocurrency. AT his just a personal statement, but I view crypto much less tangible and more cloudy than private placements. Soice the crypto markets contain, many unirestered securities, give us a view on overview of where they are in the expansion of investor protection. Right now, in terms of taany mandates that are that you see coming down?

Mark Schoeff Jr.

Well, crypto currency, the debate is raging at the moment. There are no pending regulations, and I don't believe even on the most recent regulatory agenda that the SEC put out, I don't believe there's a crypto regulation proposal pending. The  SEC has essentially said Chairman Gensler said that cryptocurrencies can be regulated under current securities law because they're often offered as part of an investment contract and investment contracts are considered securities. So he's saying that a lot of crypto currencies should register with the SEC and follow disclosure rules and be subject to SEC oversight and enforcement. On Capitol Hill, you have Democrats who are looking at crypto firstly through the investor protection lens, and then Republicans who are looking at basically Democrats who are prioritizing protecting investors, Republicans who are prioritizing protecting innovation. Again, I don't know if a middle ground can be reached on legislation. It seems unlikely right now based on a recent House Financial Services Committee hearing. It was collegial. It was an educational effort. And it featured six cryptocurrency CEOs, and Republicans and Democrats were on their best behavior so to speak, but you could tell in the questioning that they have different approaches to crypto regulation. I doubt that they could produce legislation that would pass the Senate where the Republicans can stage a filibuster. That puts the ball in the SEC court, and that's why the SEC is being pretty aggressive and saying  we can regulate these tokens because the SEC is concerned about potential investor harm. Gary Gensler called the crypto market: he likened it to the Wild West. Yeah, so I would say look for the SEC seem to forge ahead on its own in crypto regulation.

Hank Multala  

So it's really a struggle between federal agencies and the SEC. Is that where, where it's kind of kick the can down the road further and probably not, not come up with anything, any sort of protection anytime soon.

Mark Schoeff Jr.

I don't know that there's a struggle necessarily, I believe the there is some overlap between the SEC and the  Commodity Futures Trading Commission, the CFTC. So, the CFTC regulates commodities and there are those who say that cryptocurrencies are commodities. The SEC regulates securities and there are those including Gensler, who say cryptocurrencies are securities. So there is some regulatory overlay. You'll probably see the regulator's collaborate, because the heads of the regulatory agencies are both Democratic appointees, and you'll probably see some collaboration and Gensler himself as a former CFTC Commissioner. I don't know that there's necessarily that there certainly are turf concerns among agents don't be agencies. I think we'll see some cooperation. But I don't expect the I don't expect Congress to be able to step in and sort it out.

Hank Multala 

Right, so since you cover SEC, FINRA,  House, Financial Services Committee, Senate Banking Committee, Capitol Hill committees and other regulators, and you're very in tuned into,  conversations and subjects that are being discussed. You also get to see issues that are developing more or less in their infancy stage. Enlighten us on some areas you think may evolve from  these beginning stages to something more substantial. Is there things that you're seeing now that it kind of just, it looks like a little trickle, and you start to see it, then it's a creek, and all of a sudden it's a river. Is  there's there some things that your kind of seeing over the horizon right now that you see,  these things are going to start probably popping up in the next six months or a year...

Mark Schoeff Jr.

Well, I, I'm not sure I see anything trickling that's going to turn into a raging river. But I mean, the SEC is being pretty transparent about where it's going. So these digital engagement practices are something that's going to take up more and more of the SECs bandwidth in  determining whether a psychological nudge on a trading app amounts to an investment recommendation is something that I think could really change the atmosphere when it comes to digital engagement practices, because then you would have Robin Hood and other online brokers being subject to regulation, best interest, which is something they absolutely don't want to answer to. So these DEPS as they're called, so far, there's only been a request for comment about them. But that's something that will eventually evolve into probably a pretty major SEC rulemaking. Om ESG, that that's going to become a bigger and bigger part of the SECs agenda. I think once they do the climate risk and human factor disclosures, there may be some kind of rule proposal for an overall ESG framework so that they're not just doing sort of piecemeal disclosures, but  an entire overlay for  ESG investing. ESG is hardly a trickle right now, it's a major issue, but you're going to see more development in that area. And with REG BI, once the enforcement cases start coming out, right now the everyone's waiting to see  how the evolution of Reg BI will occur under the Gensler SEC, and we'll start to see that when the enforcement cases come out. So that's something that right now is really not on the radar. Everyone's in a wait and see mode. But boy once the  Gensler SEC starts to put its signature on Reg BI, that's going to be another huge issue much bigger than it is right now.

Hank Multala 

 Well, thanks for that. Appreciate it. So this is going to be my shortest question. My last one. So, is there something that you would like to share with the with the audience that perhaps we didn't discuss or that you wanted to provide a bit more detail on?

Mark Schoeff Jr.

One thing that advisor trade associations, which is lobbying groups emphasize is their outreach to lawmakers, and the Investment Advisor Association, the Financial Services Institute, and others, have what they call Capitol Hill days, where their members come to town at least pre COVID,  came to Washington and would  lobby lawmakers. They did that online during COVID and may still be doing it online. I would encourage your listeners and advisors generally, to be active politically. I know that politics is  sort of a landmine for advisors, they don't like to discuss politics with their clients, because they don't want to offend Democrats or Republicans, and they don't know really what their clients are. I would encourage  advisors to get involved in politics, at least to the extent that they are reaching out to lawmakers, to their house representative, to their senators, and making their voices heard on advisory issues on regulations affecting investment advice and in participating in the investment advisor associations outreach to Capitol Hill or the Financial Services Institute. Become  an engaged citizen from the perspective of being a financial adviser. It's really important that you weigh in and then you become active and so that you can maybe shape what's happening here rather than just having it happen to you.

Hank Multala 

Right, your voice can be heard. It's a small industry, your voice can really be heard. Thanks for that, Mark. I want to thank you again for your really timely insights regarding the right regulations and legislation affecting retail advisors and brokers. For those listening, you can always find out more by visiting or subscribing to Investment News at investmentnews.com to get latest news and opinions and just some fantastic insights on FINTECH, retirement diversity, women advisors and numerous other areas  that really impacts the lives of retail advisors and brokers and also get  involved with FSI and let your voice be heard. I know Investment News is one of the RSS feeds that is a resource to our news section on our website. So to find out more about us, you can visit advisorfirstpartners.com and don't forget to subscribe to our podcast A Chat with Hank on Stitcher, Google podcasts or wherever you may listen to programs. Mark, thanks once again for giving us your time. I know everybody appreciates the hard work by you and the staff and the other contributors at Investment News and what they put into in keeping us all informed and really making us better students of the industry. Well, thank you, Hank, for having me on your podcast. This is really a delight to talk with you and make myself available to your listeners. I appreciate all of your kind words about Investment News. My colleagues and I do work hard to keep the financial advisor community informed about what's happening in the sector and in my case, what's happening here in Washington. We appreciate your readership and your confidence in us, and we hope to keep earning it each day. Well, great. Mark. I appreciate your time. Take care.

Mark Schoeff Jr.

Thank you.