Why Blockchain Is Redefining Payments for Midsize, Community Banks

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In the weeks following Silicon Valley Bank’s downfall, the 25 largest U.S. banks experienced a $120 billion increase in deposits, according to the Federal Reserve. Meanwhile, the nation’s midsize and community banks saw deposits fall by over $108 billion during the same time period. This represented the largest weekly decline of non-megabank deposits in history and set a perilous precedent for the health of the nation’s economic engine.

Unlike megabanks, midsize and community banks are people-centric and largely focus on empowering their local communities. The collapse of Silicon Valley Bank and Signature Bank has left pressing questions for businesses everywhere: Are community and regional banks in danger of becoming obsolete? Will the future be dominated by a handful of global institutions that are unresponsive to the needs of America’s entrepreneurs and small business community?

Smaller banking’s decline is not just limited to March: Community banks’ share in total lending and assets fell by 40% between 1994 and 2015, according to a 2015 paper; the country has lost over 9,000 smaller banks since 1993. For local communities, losing a community bank often means losing access to credit for that first-time small business or aspiring entrepreneur.

In times of crisis, it is often the community and regional banks, not the megabanks, that serve the vast majority of American businesses. During the coronavirus pandemic, community banks supplied a disproportionate share of Paycheck Protection Program loans, despite having budgets that pale in comparison to those held by the largest financial institutions. Additionally, they provide pivotal working capital to American businesses: community banks are responsible for 60% of all small-business loans and more than 80% of farm loans.

While America’s largest banks continue to dominate the market, the country’s smaller banking institutions are left with few options to compete with gargantuan research and development  budgets at megabanks.

While community banks are spending more to build out technological capabilities — as evidenced by cybersecurity and contactless digital payments growing by a median increase of 11% in 2021 — there is still a key technology that can transform their commercial banking capabilities and provide them with a competitive advantage versus the megabanks: private permissioned blockchain.

Private permissioned blockchain solutions operate in sharp contrast to traditional payments platforms, which are limited by high transfer fees, transaction size limits, 9-to-5 hours of operation and lengthy time delays. Payments made using private blockchain, on the other hand, enable community banks to offer their corporate clients secure, instantaneous transactions around the clock and at a fraction of the cost. This technology also enables banks to provide customized payments and financial services for every industry and for businesses of all sizes.

Fraud and regulatory efficiency are also key factors for banks to consider. Fraud losses cost banks billions of dollars every year, with a multiple of that figure spent preventing, investigating and remediating fraud. These costs are growing rapidly, and community banks lack the resources of the megabanks to address this growing issue.

In contrast, private permissioned blockchains are only accessible to authorized users, resulting in a dramatic reduction in fraud incidence, which correspondingly reduces the costs to prevent and respond to fraud cases. Critically important for smaller banks, private blockchain are also not expensive to implement and can be installed swiftly and efficiently on existing legacy core banking platforms.

Offering corporate clients a secure, efficient and customized payments and financial solutions 24 hours a day using private permissioned blockchain gives community banks the ability to capitalize on their key competitive advantage: close proximity to small businesses.

Business-to-business, or B2B, payments continue to hold a wealth of promise for community banks. Experts estimate that over 40% of all B2B payments are still conducted through paper checks, creating glaring inefficiencies and security issues plaguing community banks already struggling to compete.

One solution to close the gap between large banks and community banks is implementing emerging technologies that level the playing field without investing enormous amounts of capital to overhaul their entire tech stacks.

We are at a crossroads in U.S. financial history; the future of the country’s midsize and community banks hangs in the balance. Technology has proven to be the great equalizer, especially during periods of economic distress and financial uncertainty. Private permissioned blockchain adoption offers a lifeline that community banks desperately need in order to survive and prosper.

Finding Fintechs: A Choose Your Own Adventure Guide

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In my role as editor-in-chief, I attend countless off-the-record conversations with bankers who confess their experiences with financial technology companies. Sometimes, those experiences are anything but good, including a host of empty promises, botched integrations and disillusioned bank staff. It’s like the fintechs took off on the rocket ship but never made it to the moon, after all.

For one, banks and fintechs have a hard time speaking each other’s language. Banks, by nature and necessity, are focused on regulatory compliance. By contrast, technology companies tend to focus on growth, driven by nature and necessity to promise the world to their clients.

That seems to be changing. In the current economy and amid falling valuations for fintechs, many of them are focusing on profitability rather than growth for its own sake. And banks are changing, too. Small community banks, which we’ll define loosely as those below $10 billion in assets, historically have been reluctant to engage directly in partnerships with fintech companies unless those companies are offered by their core processors.

Traditionally, banks’ own policies forbid contracting with young firms that lack several years of audited financial statements, a fact that has excluded the vast majority of early-stage fintechs. But as fintechs mature in terms of compliance with banking regulations and as banks try to incorporate better technology into their systems, there is more room to meet in the middle.

This report is intended as a guide to help more banks take advantage of the offerings of financial technology companies to improve efficiency, customer relationships and to facilitate growth, and to do it in a way that mitigates risk.

First, though, I start with some terminology. Partnership gets batted around an awful lot. But what is it?

The Federal Reserve’s 2021 report, “Community Bank Access to Innovation Through Partnerships,” defines partnerships broadly to include traditional vendor relationships as well as more expansive arrangements that include shared objectives and outcomes, such as revenue sharing. We’ll adopt the Fed’s definition here, for ease of discussion.

In your journey to see what the universe may offer, Godspeed.

5 Key Areas Where Banks Can Implement Automation Solutions

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As automation has become more widely available to the financial services industry, banks need to take advantage of automated solutions to streamline manual systems and processes and maintain a competitive edge.

But they would be mistaken to seek out automation only for a solution to a specific problem; rather they should take a holistic approach to automation and craft a strategy that incorporates automation in a variety of ways that could potentially improve many functions of their business. While commercial, off-the-shelf software exists for specific automation use cases, banks need to understand how automation fits into their broader business strategy and how to weave it throughout the organization’s processes. This allows leadership teams to understand where a customized approach is necessary and where turnkey solutions may be suitable.

There are five specific areas that banks should assess for automation readiness and efficiency gains.

1. Customer experience. A frictionless customer experience is a standard expectation in many industries; banking is no exception. In the past, if a customer wanted to open a deposit account at a bank one month and take out a loan the following month, the bank might require two interactions with two different employees to gather data from that customer. But there are process enhancements that can automate and streamline these processes to remove the redundancy and enhance the customer experience.

Automation can streamline the intake and digital cataloging of customer information, pulling that data together into a single place and data set that employees from various functions of the bank can query and use. The consistency of information makes the experience more palatable for the customer, and more efficient for employees.

2. Credit approval and loan operations. A typical commercial loan application and approval process can require the loan applicant to submit a significant number of documentation items and pieces of information to the bank. Using an automated tool to gather, process and organize that information can significantly cut the cycle time for the loan application, approval and origination process. Additionally, an automated process on the front end enables the loan operations process on the back end of a transaction to be more efficient and seamless, as employees can access all of the electronically obtained information in an organized format.

Automated solutions for credit and loan operations — one example of which is highlighted in this case study — can result in better information for banks and quicker decisions for applicants. Banks can use automated solutions to integrate with credit bureaus or other data providers via application programming interface (API), and apply credit policies throughout underwriting.

3. Data management. Most banks have numerous data sets that can be queried separately but not all together. What this can mean from a lending perspective is that a bank may have a commercial loan system, a retail loan system and a credit card system; all of those systems could have different outputs, which could make it difficult to analyze data and have a holistic and meaningful view of the customer’s relationship, profitability and risk profile.

Organizations should explore how automation solutions may improve their existing infrastructure and make their data more relevant and useful by enabling real-time reporting to build a more complete profile of the customer.

4. Automation tools can vastly improve the intake and data maintenance process required to comply with Know Your Customer (KYC) regulations. Automation can replace manual process during customer onboarding and ongoing monitoring and verification efforts. Compliance automation creates a uniform process and data set that the bank can use throughout the customer lifecycle, rather than on an as-needed basis, when onboarding is completed or when monitoring items arise.

5. Streamlining the audit function. As we highlight in this case study, automation can help a bank’s internal audit department “spend less time gathering data and scoping audits and more time on fieldwork such as testing hypotheses, assessing risk management, and reaching conclusions using a datacentric approach.” In that specific case, a bank used an intelligent automation solution to identify gaps and pain points in how it quantified risk during the audit planning process, accelerated its planning process and incorporated various data sources, such as consumer complaints and regulatory standards, into the audit plan.

Automation can improve virtually any function of a bank’s business, but organizations may find it daunting to determine where or how to begin implementing such solutions. Discussing options with a third-party advisor can help bankers craft a valid and thorough automation strategy that incorporates all the advantages of automated capabilities that might be relevant and available. This strategic approach maximizes efficiencies for the bank, while providing a best-in-class customer experience.

The Business Deposits Challenge

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In this excerpt from Reinventing Banking, Bank Director’s special podcast series sponsored by Microsoft Corp., Derik Sutton points to the value that community banks provide to their local small businesses. But that’s evolving in the digital age, as businesses have new ways to access capital and get paid. In the conversation, he discusses:
  • What’s Changed in Banking Small Businesses
  • How Mobile Apps Could Become Payments Terminals
  • Reconnecting With Customers
To listen to this episode in its entirety, click here.

Digital Banking: Being Best in Class and Driving Profit

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Forward-thinking financial institutions have been focused on digital transformation to compete with megabanks and fintechs. They’re funding development to actively shaping user expectations for what a digital banking experience can offer. By 2028, the global digital banking market size is estimated to surpass $10.3 trillion.

Yet, many banks without deep pockets or partners and limited technology resources are relying on their core technology provider for a turnkey platform — a “bank-in-a-box” that includes bundled services like payments, loan origination and digital banking. The biggest threat remains for those institutions that decide to maintain the status quo with a less-than-impressive digital banking platform or ineffective home-brewed solution.

Consumers expect a seamless digital experience to help them manage their finances and achieve their financial goals. A recent study found that consumers’ trust in digital banking is shifting away from their preferred financial institution. If account holders aren’t convinced that their preferred bank provides the best digital security and privacy, reliability, feature breadth, and ease of use, they’re willing to leave. It’s clear that digital banking can make or break a bank’s future.

What is the ideal digital banking experience that account holders want? Banks should keep these best-in-class components in mind as they search for the right partners and technology for their digital banking transformation.

  1. Data-driven insights. Bank executives must find ways to execute on internal transaction data to deepen user relationships and build profitability and institutional loyalty.
  2. Seamless user experience. Now more than ever, it’s important that banks understand what attractive features will improve digital banking experiences for their users.
  3. Continuous software delivery. Best practices for continuous software delivery is to find a partner offering a single code source, rather than multiple.
  4. Investments in API and SDKs. Vendors that can seamlessly integrate application programming interfaces, or APIs, into digital banking help banks leverage the latest industry leading technology and maintain a competitive advantage.
  5. Cloud-forward thinking. Banks can leverage the cloud to enhance features, security and user experiences while improving uptime, performance and quality.
  6. Modern security strategies. When financial institutions and digital banking providers band together and treat cybersecurity as a shared responsibility, security issues can pose less of a threat.

Financial institutions may need to consider replacing legacy technologies and embracing artificial intelligence tools. This means taking advantage of transaction data flowing through the core to uncover important insights about account holders’ needs based on their behaviors and spending patterns, and using it to optimize the digital experience. This kind of thinking results in transforming digital banking — moving from a cost center into a revenue center, all rooted in data.

In the past, marketing campaigns focused on products that just needed to be sold. They were delivered from the top down, funneling to all users regardless of their personal needs. That strategy changed when big data, artificial intelligence and machine learning gave marketers the ability to target tailored messages to the ideal recipient. Aligning data insights and marketing automation means banks can deliver experiences that are compelling, timely and relevant to account holders.

Pairing insights and marketing automation with a digital banking platform allows banks to target their account holders with personalized engagements and cross-sell marketing offers that appear within the banking platform and other digital channels. Banks can generate a 70% return on initiatives targeting existing customers, versus 10% when targeting new customers, according to PwC. “In a time where every bank is focused on revenue growth in a constrained and competitive environment, making smart choices with limited resources can provide a fast track to higher-margin growth,” PwC states.

Banks can use data to drive revenue through the digital banking channel through a number of real-world, practical applications, including:

  • Onboarding programs.
  • Self-service account opening.
  • Product cross-sell and upsell.
  • Competitive takeaway.
  • Communications and servicing opportunities.
  • Product utilization.
  • Transitioning retail accounts into business accounts.

Digital banking is mission critical to banks. Catalyzing this platform with data insights and marketing automation creates an engaging channel for deeper customer relations, ultimately transforming the digital banking investment into a profit center.

Leveraging Technology for Growth

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Technology is playing an increasingly central role in banks’ strategic plans. Now more than ever, banks rely on technology to deliver products and services, improve processes and the customer experience, acquire new customers and grow.

When it comes to new technology, banks essentially have four options: build it, license it, partner with a third party or buy it. Traditionally, only the largest banks had the resources and inclination to build technology in house; however, some smaller banks are now dedicating resources to developing technology themselves.

Much more commonly, banks obtain technology solutions from their core processors or other vendors. Over the last several years, there has been a proliferation of banks partnering with fintech companies to deploy their technology, or for banks to provide banking services to a customer-facing fintech company. As banks become more tech-centric, more are likely to explore acquiring fintech companies or fintech business lines. Each approach carries with it unique advantages, disadvantages, risks and legal and regulatory considerations.

The federal bank regulatory agencies have been especially active in recent years in the bank/fintech partnership space. In July 2021, the agencies published proposed updated interagency guidance on managing risks associated with third-party relationships, which includes guidance on relationships with fintech companies. Later in 2021, they released a guide intended to help community banks conduct appropriate due diligence and assess risks when considering relationships with fintech companies, and the Federal Reserve Board published a white paper on how community banks can access innovation by partnering with third-party fintech companies. Prior to that, the Federal Deposit Insurance Corp. published a guide intended for fintech companies interested in partnering with banks. These pronouncements indicate that while the agencies are generally supportive of banks innovating via fintech partnerships, their expectations for how banks conduct those relationships are increasing.

As technology and the business of banking become more intertwined, banks need to remain mindful not only of regulatory guidance on these partnerships specifically, but on the full spectrum of laws and regulations that are implicated — sometimes unintentionally — by these relationships. For example, partnership models that involve banks receiving deposits through a relationship with a fintech company could implicate the brokered deposit rules, which the FDIC updated in 2020 to account for how banks use technology to gather deposits.

As another example, partnership models that involve a fintech company offering new lending products funded by the bank, or the bank lending outside of its traditional market area, can raise fair lending and Community Reinvestment Act considerations, and potentially expose the bank to a heightened risk of regulatory enforcement action. Banks must keep in mind that when offering a banking product through a fintech partnership, regulators view that product as a product of the bank, which the bank must offer and oversee in accordance with applicable law and bank regulatory guidance.

What’s Next
Although bank/fintech partnerships have been around for some time, the amount of recent regulatory activity in this area suggests the agencies believe that many more of these partnerships, involving many more banks, will develop.

As the partnership model matures, more banks may become interested in developing closer ties with their fintech partner, including by investing cash in their fintech partner. Banks may be motivated to explore an investment to make its relationship with a fintech partner stickier, allow the bank to financially share in the fintech partner’s growth or enhance the bank’s attractiveness as a prospective partner to other fintech companies.

Banks considering investing in a fintech company or a venture capital fintech fund must understand not only the regulatory expectations associated with fintech partnerships generally, but also the legal authority under which the bank or its holding company would make and hold the investment.

As some banks start to look and operate more like technology companies, more may explore acquisitions of entire fintech companies or fintech business lines or assets. In addition to the many business and legal issues associated with any M&A transaction, banks considering such an acquisition have to be especially focused on due diligence of the target fintech company, integration of the target into the bank’s regulatory environment and ensuring that the target’s activities are permissible for the bank to engage in following the transaction.

Banks need innovative technology to succeed in today’s fiercely competitive financial services marketplace. Some will build it themselves, others will hire technology vendors or partner with fintech companies to deploy it and some will obtain it through acquisition. As banking and fintech evolve together, banks must understand and pay careful attention to the advantages and disadvantages, and legal and regulatory aspects, of each of these approaches.

Expect Funding Wars, Tech Troubles in 2023

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Back in January 2022, rising interest rates looked increasingly likely but weren’t yet a reality. In Bank Director’s 2022 Risk Survey, bank executives and board members indicated their hopes for a moderate rise in rates, defined as one percentage point, or 100 basis points. Of course, those expectations seem quaint today: In 2022, the Federal Reserve increased the federal funds rate’s target range from 0 to 0.25% in the first quarter to 4.25% to 4.5% in December — a more than 400 basis point increase.

A year ago, anyone looking at recent history would have been challenged to foresee this dramatic increase. And looking ahead to 2023, bankers see a precarious future. “We’ve never seen more uncertainty, on so many fronts, across the entire balance sheet,” says Matt Pieniazek, CEO of Darling Consulting Group. “Let clarity drive your thought process and decision-making, not fear.” 

While we can’t predict the future, we can leverage the recent past to prepare for what’s ahead. Here are three questions that could help boards and leadership teams plan for tomorrow. 

How Will Rising Interest Rates Impact the Bank?
Despite the rapid rise in the federal funds rate, just a handful of banks pay savings rates north of 3%: These include PNC Financial Services Group, which pays 4%; Citizens Financial Group, at 3.75%; and Capital One Financial Corp., at 3.3%. Most still pay the bare minimum to depositors, averaging 0.19% as of Dec. 14, 2022, according to Bankrate.

Pieniazek believes this will change in 2023. “[Banks have] got to accept that they were given a gift [in 2022].” Because of an environment that combined a rapid rise in rates with excess liquidity, banks were able to delay increasing the interest rates paid on deposits.

Funding costs are already beginning to reflect this changing picture, rising from an average 0.16% at the beginning of 2022 to 0.64% in the third quarter, according to the Federal Deposit Insurance Corp. 

“The liquidity narrative is changing,” says Pieniazek. “Our models are projecting that there’s going to be substantial catch-up.” Typically, deposits start to get more competitive after a 300 basis point increase in the federal funds rate, he says. We’re well past that.

That means banks need to understand their depositors. Pieniazek recommends breaking these into three groups: the largest accounts, which tend to be the smallest in number and most sensitive to rate changes; stable, mass market accounts with less than $100,000 in deposits; and account holders between these groups, with roughly $100,000 to $750,000 in deposits. Understand the behaviors of each group, and tailor pricing strategies accordingly. 

Will Banks Feel the Pain on Credit?
“Most banks are cutting their loan growth outlook in half for 2023, versus 2022,” says Pieniazek. Bank executives and boards should have frank discussions around growth and risk appetites, including loan concentrations. “Are we appropriately pricing for risk? And are we letting blind adherence to competition drive our loan pricing as opposed to stepping back and saying, ‘What is a fair, risk-adjusted return for our bank?,’ and level-set[ting] our loan growth outlook relative to that.” 

Steve Williams, president and co-founder of Cornerstone Advisors, sees less weakness in bank balance sheets — credit quality remained pristine in 2022 — and more concern for shadow banks and fintechs that have grown through leveraged, subprime and buy now, pay later loans. If these entities struggle, it could be an opportunity for banks. 

“The relationship manager model, in certain segments, has great runway,” says Williams. But that doesn’t mean that banks can simply ignore the disruption that’s already occurred. “We’ve been telling our clients, ‘Don’t dance in the end zone and be cocky,’ because … these blueprints for the future are still there,” he explains. “If we’re going to fight the funding war, we’ve got to do it in modern terms.” That means continuing to invest in technology to deliver better digital services. 

How Will the Tech Fallout Impact Banks?
It’s been a rough year for the tech sector. Valuations declined in 2022, according to the research firm CB Insights. Talented employees lost their jobs as tech firms shifted from a growth mindset to a focus on profitability. 

“Tech has never been cheaper than it is right now,” says Alex Johnson, creator of the Fintech Takes newsletter. “There [are] ample opportunities to snap up tech companies in a way that there just has never been.” 

Many banks aren’t interested in investing in, much less acquiring, a tech company, according to the bank executives and board members responding to Bank Director’s 2023 Bank M&A Survey. Just 15% participated in a fintech-focused venture capital fund in 2021-22; 9% directly invested in a fintech. Even fewer (1%) acquired a technology company during that time, though 16% said it’s a possibility for 2023. 

Snatching up laid-off talent could prove more viable for banks: 39% planned to add technology staff in 2022, according to Bank Director’s 2022 Compensation Survey. Many tech workers, scarred by last year’s layoffs, will seek stability. Over the last 10 to 15 years, “tech companies were the most valued place for employees to go; they were paying the highest salaries,” says Johnson. “It’s a huge, almost generational opportunity for banks, when they’re thinking about what their tech strategy is going to be.”

But what about vendors? The number of startups working with banks proliferated over the past few years. Amid this volatility, Johnson advises that banks sort out the “tourists” — opportunistic companies working with banks to demonstrate another avenue for growth — from providers that prioritize working with financial institutions. In today’s tougher fundraising environment, “if you’re a fintech company, you’re basically pulling back from all the things that you don’t think are core to what you do.” 

2023 could make crystal clear which tech companies are serious about working with banks.

Evaluating Digital Banking In 2023

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Platforms that offer future flexibility, as opposed to products with a fixed shelf life, should be part of any bank’s digital transformation strategy for 2023, says Stephen Bohanon, co-founder and chief strategy and product officer at Alkami Technology. Chatbots and artificial intelligence can deflect many simple, time-consuming customer queries — saving time and costs — but digital channels can go further to drive revenue for the organization. To do that, bankers need to invest in data-based marketing and account opening capabilities.

Topics include:

  • Platforms Vs. Products
  • Sales Via Digital Channels
  • Advantages of Live Service

Renew, Recharge and Reassess Customer Service

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As interest rates rise and the retail housing market cools down, lenders are bracing for an uncertain environment.

While banks cannot control the market, they can control how they respond and future-proof their business. Successful navigation in these unchartered waters requires institutions to reassess traditional product, service and industry boundaries in order to capture and create new sources of value. Digital transformation and innovation will remain an important strategic priority in 2023 and beyond — however, it is now equally important for institutions to provide lasting value to customers through personalized, highly tailored services.

The slowing housing market creates a unique opportunity for financial institutions to revisit and refresh these fundamentals, including exploring how they can deliver a more personalized experience. As banks remain focused on their roles as financial intermediaries, this time of challenge can also be a time of opportunity to strengthen existing relationships and expand loyalty with customers. Lenders can also take advantage of a slower market by implementing new automation strategies to further streamline their mortgage loan process. Successful institutions will recognize that this slower pace enables them to recharge, rethink and renew their focus on providing customers a superior experience.

Accelerating personalization and building loyalty is critical in today’s increasingly competitive financial services market. The answer isn’t just faster, more automated technology; financial institutions must adapt a hyper-personalized approach. According to a recent NCR study, 60% of U.S. banking consumers want their primary financial institution to provide personalized financial advice. Many Americans are facing an uncertain financial future and don’t believe their financial institution is providing the necessary support.

To successfully deliver that personalized experience, institutions must leverage data to provide more relevant, timely support. That means more effectively gathering and analyzing data to yield insights that ultimately help the bank connect with the customer. Banks should have the most accurate and complete picture of their customer’s economic health, which allows them to make meaningful suggestions and provide impactful advice. Consumers can then look to their data enabled and informed banker as a guiding force helping them build a more stable financial future.

Anticipating customer needs and catering to them with personalized offerings allows banks to generate increased revenue, all the while meeting customer expectations around personalized experiences. According to the 2019 Accenture Global Financial Services Consumer Study, one in two consumers wants personalized banking advice based on their circumstances. They want an analysis of their spending habits and advice on handling money. Additionally, 48% of respondents indicated that personalized banking data, such as spending, would help them change how they used their money.

A 2021 Capco research report found that 72% of customers say personalization is highly important in today’s financial services landscape. This number increases for younger generations: 79% of Gen Z customers say it is critical their financial institutions provide more personalized offers and/or information to help them reach their financial goals.

Customers provide banks with a lot of information about themselves across their interactions. Banks can use this data carefully, employing technology like artificial intelligence to anticipate customer needs. Anticipating and then proactively acting on those needs is crucial to creating an effective, personalized experience. Banks can also position products with sensitivity, effectively demonstrate their understanding of their customer’s unique needs or suggest curated products that demonstrate a knowledge of that customer’s specific financial needs and ultimately, build lasting loyalty.

Banks should also consider the way they approach economic distress in a manner that doesn’t weaken customers’ future foundation. Institutions should examine their interactions with both the rental market and the single-family ownership market. Banks need to think in terms of households, not consumers. Consider the household and heads of households instead of thinking of them as consumers.

There is an opportunity in this moment for institutions to create more personalized offers that are relevant to their customers. To succeed, banks must take operational steps to authentically personalize offerings to their customers, using technology in a way that’s fair and compliant.