What Crypto’s Falling Dominoes Could Mean for Banks

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On Nov. 11, the cryptocurrency exchange FTX declared bankruptcy. It’s a saga that’s played out through November, but here’s the bare bones of it: After a Nov. 2 CoinDesk article raised questions about FTX and a sister research firm, a rival exchange, Binance, announced on Nov. 6 its sale of $529 million of FTX’s cryptocurrency. In a panic, customers then sought to withdraw $6 billion and by Nov. 10, FTX CEO Sam Bankman-Fried was trying to raise $8 billion to keep the exchange alive.

This isn’t just a modern version of the old-fashioned bank run. FTX’s new CEO, John J. Ray III — who led the restructuring of Enron Corp. in 2001 — stated in a filing that he’s never seen such a “complete failure of corporate controls” in his 40 years of experience. “From compromised systems integrity and faulty regulatory oversight abroad, to the concentration of control in the hands of a very small group of inexperienced, unsophisticated and potentially compromised individuals, this situation is unprecedented,” he said.

The fallout promises serious ramifications for the digital assets space — and may impact some banks. BlockFi, another cryptocurrency exchange that was bailed out by FTX last summer, filed for bankruptcy protection on Nov. 28. Those two bankruptcies have impacted Memphis, Tennessee-based, $1.3 billion Evolve Bank & Trust, which operates a banking as a service platform for fintechs including FTX.

The bank stated its exposure to FTX was in deposit accounts for a limited number of FTX customers, whose funds would be released once Evolve gets approval from the bankruptcy court handling the FTX case. Evolve also issued credit cards for BlockFi customers through a relationship with Deserve; those accounts were suspended. “Evolve has no financial exposure to BlockFi or to the credit card program they marketed,’’ Evolve said in a statement Thursday.

“To be clear, Evolve did not lend to FTX or their affiliates; we do not have corporate or deposit accounts with FTX or their affiliates; we do not lend against crypto; we do not offer crypto custodial services; and, we do not trade crypto,” Evolve said in an earlier statement to customers. Evolve also said the bank has never invested or transacted in crypto.

A larger bank also appears to be impacted. La Jolla, California-based Silvergate Capital Corp., with $15.5 billion in assets, said in a statement that its FTX exposure was less than 10% of its $11.9 billion in digital assets deposits; it later said that BlockFi deposits comprised less than $20 million. However, funds from digital assets clients make up 86% of Silvergate’s deposit base, according to its most recent earnings presentation. The rest are brokered, explains Michael Perito, a managing director at Keefe, Bruyette & Woods. And now, he says, “their targeted core customer base is under a lot of stress.” As a result, Kroll Bond Ratings Agency placed Silvergate’s ratings on watch downgrade on Nov. 21.

“As the digital asset industry continues to transform, I want to reiterate that Silvergate’s platform was purpose-built to manage stress and volatility,” said Alan Lane, CEO of Silvergate, in a press release. The bank declined comment for this article.

FTX may be the worst but it’s not the only crypto-related incident this year; it’s not even the first bankruptcy. The volatility has resulted in what has been dubbed a crypto winter, marked by a steep decline in prices for digital assets. The price for bitcoin peaked on Nov. 8, 2021, at $67,567. As of Nov. 29, 2022, that value hovered just above $16,000, with a market cap of $316 billion.

Even if banks don’t hold cryptocurrency on their balance sheets, there are many ways that a chartered institution could be directly or indirectly connected. Erin Fonté, who co-chairs the financial institutions corporate and regulatory practice at Hunton Andrews Kurth, advises all banks to understand their potential exposure.

She also believes that crypto could be at an inflection point. “Some of the non-sexy elements of financial services are the ones that keep you safe and stable and able to operate,” says Fonté. “It’s the compliance function, it’s the legal function, it’s proper accounting and auditing, internal and external. It’s all those things that banks do day in and day out.”

That could result in more regulation around crypto, and more opportunities for banks. “A lot of people are getting hurt, and have gotten hurt this year,” says Lee Wetherington, senior director of corporate strategy at Jack Henry & Associates. “That gets legislative attention and that certainly gets regulatory attention.”

What Could Change
Legislation could target crypto exchanges directly, but legislators are also looking at the banking sector. In a Nov. 21 letter, the Senate Banking Committee urged bank regulators to continue monitoring banks engaged in digital assets. They specifically called out SoFi Technologies, which acquired a chartered bank in February 2022 and subsequently launched a no-fee cryptocurrency purchase option tied to direct deposits. “SoFi’s digital asset activities pose significant risks to both individual investors and safety and soundness,” wrote the legislators. “As we saw with the crypto meltdown this summer … contagion in the banking system was limited because of regulatory guardrails.”

In a statement on SoFi’s Twitter account, the company maintained that it has been “fully compliant” with banking laws. “Cryptocurrency remains a non-material component of our business,” SoFi continued. “We have no direct exposure to FTX, FTT token, Alameda Research, or [the digital asset brokerage] Genesis.”

Currently, the Federal Reserve and Federal Deposit Insurance Corp. require notification from banks engaged in crypto-related activities; the Office of the Comptroller of the Currency takes that a step further, requiring banks to receive a notice of non-objection from the agency. More regulation is likely, says Fonté, and could include investor and consumer protections along with clarity from the Securities and Exchange Commission and Commodity Futures Trading Commission. “There’s a lot that’s going to come out there that is going to reshape the market in general, and that may further define or even open up additional avenues for banks to be involved if they want to be,” she adds.

Opportunities in crypto and a related technology called blockchain could include retail investment products, international payments capabilities or trade settlement, or payments solutions for corporate clients that leverage blockchain technology — such as those offered by Signature Bank, Customers Bancorp and Silvergate.

The risks — and opportunities — will vary by use case. “We’re being presented with entirely new risks that haven’t existed in the past,” says John Epperson, a principal at Crowe LLP.

Banks could be seen as a source of safety and trust for investors who remain interested in cryptocurrency. Larry Pruss, managing director of digital assets advisory services at Strategic Resource Management, believes banks could win back business from the crypto exchanges. “You don’t have to compete on functionality. You don’t have to compete on bells and whistles. [You] can compete on trust.”

James Wester, director, cryptocurrency at Javelin Strategy & Research, believes that with the right technology partners, banks can approach cryptocurrency from a position of strength. “We understand this stuff better,” he explains. “We understand how to present a financial product to our consumers in a safer, better, more transparent way.”

Wetherington recommends that banks consider cryptocurrency as part of a broader wealth offering. He’s visited bank boardrooms that have looked at how PayPal Holdings and other payments providers offer users a way to buy, sell or hold digital assets, and whether they should mimic that. And they’ve ultimately chosen not to mirror these services due to the reputational risk. “You can’t offer buy, hold and sell of a single asset class that is materially riskier than any number of more traditional asset classes,” he says. “If you’re going to offer the ability to buy, hold and sell a cryptographic monetary asset, you should also be making available the opportunity to buy, hold and sell any other type of asset.”

But all banks could consider how to educate their customers, many of whom are likely trading cryptocurrencies even if it’s not happening in the bank. “Help those customers with things like tax implications … or understanding how crypto may or may not fit into things that their retail customers are interested in. That’s one of the things that financial institutions could do right now that would be good for their customers,” says Wester. “There’s a real need for education on the part of consumers about [this] financial services product.”

Banking is Changing: Here’s What Directors Should Ask

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One set of attributes for effective bank directors, especially as community banks navigate a changing and uncertain operating environment, are curiosity and inquisitiveness.

Providing meaningful board oversight sometimes comes down to directors asking executives the right questions, according to experts speaking on Sept. 12 during Bank Director’s 2022 Bank Board Training Forum at the JW Marriott Nashville. Inquisitive directors can help challenge the bank’s strategy and prepare it for the future.

“Curiosity is a great attribute of a director,” said Jim McAlpin Jr., a partner at Bryan Cave Leighton Paisner and newly appointed board member of DirectorCorps, Bank Director’s parent company. He encouraged directors to “ask basic questions” about the bank’s strategy and make sure they understand the answer or ask it again. He also provided a number of anecdotes from his long career in working with bank boards where directors should’ve asked more questions, including a $6 billion deal between community banks that wasn’t a success.

But beyond board oversight, incisive — and regular — questioning from directors helps institutions implement their strategy and orient for the future, according to Justin Norwood, vice president of product management at nCino, which creates a cloud-based bank operating platform. Norwood, who describes himself as a futurist, gave directors a set of questions they should ask executives as they formulate and execute their bank’s strategy.

1. What points of friction are we removing from the customer experience this quarter, this year and next year?
“It’s OK to be obsessive about this question,” he said, adding that this is maybe the most important question directors can ask. That’s because many technology companies, whether they’re focused on consumer financials or otherwise, ask this question “obsessively.” They are competing for wallet share and they often establish customer expectations for digital experiences.

Norwood commended banks for transforming the middle and back office for employees, along with improving the retail banking experience. But the work isn’t over: Norwood cited small business banking as the next frontier where community banks can anticipate customer needs and provide guidance over digital channels.

2. How do we define community for our bank if we’re not confined to geography?
Community banking has traditionally been defined by geography and physical branch locations, but digital delivery channels and technology have allowed banks to be creative about the customer segments and cohorts they target. Norwood cited two companies that serve customers with distinct needs well: Silicon Valley Bank, the bank unit of Santa Clara, California-based SVB Financial, which focuses on early stage venture-backed companies and Greenlight, a personal finance fintech for kids. Boards should ask executives about their definition of community, and how the institution meets those segments’ financial needs.

3. How are we leveraging artificial intelligence to capture new customers and optimize risk? Can we explain our efforts to regulators?
Norwood said that artificial intelligence has a potential annual value of $1 trillion for the global banking industry, citing a study from the McKinsey & Co. consulting group. Community banks should capture some of those benefits, without recreating the wheel. Instead of trying to hire Stanford University-educated technologists to innovate in-house, Norwood recommends that banks hire business leaders open to AI opportunities that can enhance customer relationships.

4. How are we participating in the regulatory process around decentralized finance?
Decentralized finance, or defi, is a financial technology that uses secure distributed ledgers, or blockchains, to record transactions outside of the regulated and incumbent financial services space. Some of the defi industry focused on cryptocurrency transactions has encountered financial instability and liquidity runs this summer, leading to a crisis that’s been called “crypto winter” by the media. Some banks have even been ensnared by crypto partners that have gone into bankruptcy, leading to confusion around customer deposit coverage.

Increasingly, banks have partnerships with companies that work in the digital assets space, or their customers have opened accounts at those companies. Norwood said bank directors should understand how, if at all, their institution interacts with this space, and the potential risks the crypto and blockchain world pose.

Blockchain and Banking: Opportunities and Risks With Digital Assets

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In the 12 years that have passed since the world’s first Bitcoin transaction, digital payment systems have come a long way. Crypto and digital assets such as Bitcoin, Ethereum and Ripple make the headlines almost daily and account for more than a million transactions every day.

With more customers holding crypto and digital assets, banks can no longer afford to dismiss the crypto trend and must find ways to address those customers’ needs. The potential benefits extend beyond customer retention. Engaging with crypto and digital assets can provide banks with opportunities to reach out to new customers, differentiate themselves from competitors and find new sources of noninterest income.

As the scope of the crypto landscape has expanded, the debate over the banking industry’s place in it has intensified. Because of its historical role as a cornerstone of the broader financial system, many industry leaders contend that the banking sector has a logical role to play in bringing order and stability to the world of crypto transactions.

This contention is bolstered by the advent of stablecoins, which have values pegged to some other asset such as a fiat currency or a commodity. This feature seeks to reduce price volatility and enable more confident valuations so that stablecoins can be treated more like other intangible assets.

Proponents also note that banks clearly are capable of accommodating the crypto trend — just as they adapted to credit card processing, automated clearinghouse transactions and peer-to-peer payment systems.

While the broader industry sorts out its eventual role in the crypto world, individual banks face more immediate decisions about whether and how they should start accommodating crypto and digital assets. Opportunities abound — beginning with the provision of commercial banking services to companies that hold crypto assets or use them as a medium of exchange.

Beyond standard account services, some banks might choose to apply their expertise in payment processing and settlements to enable digital transactions. Banks with strong custody and wealth management operations might expand those services to accommodate crypto investments. Other banks could decide to accept digital assets as loan collateral.

More specialized, technologically demanding applications could prove feasible for some banks. Possible scenarios include providing merchant processing services using crypto assets, operating crypto ATMs and managing crypto reward or cash-back programs and other decentralized finance applications.

Developing Crypto Capabilities

The first step is deciding which of the various opportunities to pursue. Establishing a separate department or division is usually a poor strategy. A better course is to integrate crypto and digital asset capabilities into existing business lines.

Bank leadership teams clearly have an important role to play in guiding such decisions and should make sure that any venture into crypto and digital assets begins with a thorough strategic assessment. The goal is to identify the bank’s existing strengths and build in crypto components rather than forcing crypto capabilities into business lines where the bank might already be struggling.

Once executives identify promising opportunities, another critical early step is determining the best methodology for developing crypto capabilities. Large banks with extensive in-house technology resources might build their own applications, but most community and regional banks might find it more feasible to work with strong technology partners, including targeted fintech companies supporting the banks’ strategic goals

Risk and Compliance Issues

Risk and compliance uncertainty are common concerns underpinning hesitation among banks when it comes to developing crypto capabilities, given that the relevant regulatory, financial reporting, auditing and tax standards are still evolving. Yet banks can successfully mitigate the uncertainty through effective strategic planning and due diligence.

In addition, regulatory and advisory bodies are actively working to clarify the picture. Agencies such as the Office of the Comptroller of the Currency, the Federal Reserve Board and the Securities and Exchange Commission are crafting guidance or comment letters; financial reporting and accounting organizations are developing standards that will aid board members responsible for overseeing compliance.

With fintech businesses and other competitors eager to engage with crypto-oriented customers, banks cannot ignore the potential customer retention, brand enhancement and revenue generating capabilities of crypto and digital assets. By monitoring the evolving guidance and carefully evaluating the risks and opportunities, banks can pursue a balanced approach that capitalizes on the potential benefits while remaining consistent with their established levels of risk tolerance.

Why Regulation Should be Part of Cryptocurrencies’ Future

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Despite a recent embrace by the capital markets and financial corporations, digital assets and cryptocurrencies are still not at the point of widespread, global adoption. To get there, lawmakers and financial agencies should implement rules and regulations to protect consumers and enable the space to develop further as an alternative financial system.

The evolution of digital assets like cryptocurrencies has a phenomenal potential to change the financial industry. However, it also creates challenges. Digital assets are decentralized and do not rely on either governmental authorities or financial institutions to create, transmit or determine the value of a cryptocurrency. Supply is determined by a computer code; prices can be extremely volatile. Over the past decade we have witnessed digital asset exchanges being closed down due to fraud, failure or security breaches.

Within the United States, there is no uniformity in the regulatory framework with respect to how businesses that deal in digital assets should conduct themselves. New York is one of the few states that has a functional regulatory regime through the New York State Department of Financial Services. Meeting compliance in New York has become a badge of legitimacy. However, there are also a significant number of companies that have chosen not to operate in New York due to these regulations. On the other hand, Wyoming has adopted a lighter regulatory framework and is widely considered the most crypto-friendly jurisdiction in the United States.

Congressional Developments
In April, the U.S. House of Representatives passed “The Eliminate Barriers to Innovation Act,” a bill that directs the Commodity Futures Trading Commission and the U.S. Securities and Exchange Commission to establish a digital asset working group and open new regulatory frameworks for both digital assets and cryptocurrencies.

The bipartisan bill would initiate the commission of a specialized working group that would evaluate regulation of digital assets in the U.S. The joint working group would include the SEC and CFTC, in collaboration with financial technology firms, financial firms, academic institutions, small and medium businesses that leverage financial technology and investor protection groups, as well as business or non-profit entities that are working to support historically underserved businesses. The working group would draft recommendations to improve the current regulatory landscape in the U.S., which will then be extended internationally where possible. The working group will be given a year to evaluate and provide technical documentation on how these recommendations should be implemented through compliance frameworks.

Regulation Ensures Market Stability
While some people believe that cryptocurrencies should operate completely independently from any form of regulation, publicly accountable businesses are vigorously regulated in order to protect consumers and economic stability. Independent audits are similarly required to protect the interests of all stakeholders, ensure that the applicable laws and regulations are adhered to and that the financial statements are free from material misstatement, as well as fraud (to a certain extent).

Regulators around the world regularly warn crypto asset investors to be extremely cautious and vigilant, partially due to a lack of regulation, which creates an opportunity for fraudsters to prey on uninformed investors. Fraud and error can usually be mitigated by prevention, detection, and recourse. Introducing regulations to govern the cryptocurrency industry will mean preventative measures are in place to ensure fraud doesn’t occur and that there is appropriate legal recourse for victims. There is also a significant role for auditors in detecting possible instances of fraud or error, as well as assisting with the recourse process.

Digital Asset Outlook
Mazars will be keeping a close watch on the progress of the innovation bill. We believe positive regulatory changes are ahead. Gary Gensler, the recently confirmed head of the SEC, has a keen knowledge of, and appreciation for, the applicability of digital assets in the global financial services ecosystem. Gensler is the former head of the CFTC, as well as a professor at the MIT Sloan School of Management where he researched and taught blockchain technology, digital currencies and financial technology.

In a recent interview with CNBC, Chair Gensler said there needed to be authority for a regulator to oversee the crypto exchanges, similar to the equity and futures markets. He said many crypto coins were trading like assets and should fall under the purview of the SEC.

We welcome this level of engagement and improved regulation, which will be good for the industry, investors, consumers and society at large. Without regulation, cryptocurrencies are unlikely to become a standard part of investment portfolios due to the current high level of risk.

The information provided here is for general guidance only, and does not constitute the provision of legal advice, tax advice, accounting services, investment advice or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal or other competent advisers. Before making any decision or taking any action, you should consult a professional adviser who has been provided with all pertinent facts relevant to your particular situation.

Four Things to Do if Your Bank Is Eyeing Digital Assets

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Digital banking is evolving in the wake of guidance from the Office of the Comptroller of the Currency as it concerns digital assets and their underpinning technology.

The regulator issued an interpretative letter last July authorizing OCC-regulated national banks to hold digital assets and another one in early 2021 allowing such banks to use blockchain and stablecoin infrastructures. Consumers and commercial entities continue to demand offerings and services for digital assets, and the pandemic has accelerated this push.

This rise of digital assets will have far-reaching implications for the entire banking sector for years to come. It’s crucial for executive teams at traditional banks to understand how best to capitalize on these changes, where the risks lie and how to prepare for the future of banking. For banks weighing how and when to start offering digital asset services, here are four key things leadership teams should do:

  1. Prepare to stake a claim. The evolution of money toward digital assets is affecting bank and fintech organizations globally. Companies should proactively think through adjustments now that will enable them to keep up with this rapid pace of change. At the start of this century, when mobile banking apps first began appearing and banks started offering remote deposit captures for checks, organizations that were slow to adopt these technologies wound up being left behind. The OCC guidance explicitly authorizing the use of digital assets should alleviate any doubts around whether such currencies will be a major disruption.
  2. Assess technology investments. A crucial determinant in how successful a bank will be in deploying digital asset-related services is how well-equipped and properly aligned its technology platforms, vendors, policies and procedures are. One of the primary concerns for traditional banks will be assessing their existing core banking platform; many leading vendors do not have blockchain and digital asset capabilities available at this time. This type of readiness is key if bank management hopes to avoid significant technology debt into the next decade. Additionally, banks will need to assess whether it makes sense to partner, buy or build the necessary technology components to transact, custody, settle and potentially issue digital assets.
  3. Prepare for growing demand. As digital assets become more mainstream, there will be significant growth in institutional adoption and growth in consumer demand, especially from millennials and Generation Z customers. The OCC’s recent interpretative letters and the rapid growth of digital assets even just in the last year only emphasize that the adoption of such assets will be the next phase of evolution for banks. That also involves added responsibilities and regulatory compliance that executives need to start understanding now.
  4. Mind the regulator. The era of digital assets is new, and as such, there is heightened scrutiny around related services and offerings. Executives will need to assess existing “know your customer” compliance obligations and update accordingly. Banks also need to understand necessary capital expenditures related to deploying digital asset services. Regulators will be especially interested in not just what’s under the hood, but how banks are managing these new parts and pieces.

What’s next?
Banks that are contemplating or already in the process of deploying digital asset services will need to understand the regulatory requirements in this space and make upgrades to their core banking platforms to make sure those systems can interface with blockchain and other distributed web (sometimes called Web 3.0) technologies. To learn more about how your executive team can prepare, register now for BankDirector’s May 11 webcast — sponsored by RSM — on the future of bitcoin and digital assets.

How Innovative Banks Capitalize on Cryptocurrency

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This summer, three new developments in the relationship between banks and cryptocurrency players signaled a shift in attitudes toward digital assets.

In May, JPMorgan Chase & Co. began providing banking services to leading crypto exchanges Coinbase and Gemini Trust Co., — a notable change given that Chairman and CEO Jamie Dimon called the seminal cryptocurrency Bitcoin “a fraud” just three years ago. In July, the acting comptroller for the Office of the Comptroller of the Currency, Brian Brooks — who served as the chief legal officer for Coinbase prior to his appointment — released an interpretation letter confirming that financial institutions can bank cryptocurrency clients and could even serve as digital asset custodians. And this month, the popular crypto exchange Kraken secured a special purpose banking charter in Wyoming, marking the first time a crypto company gained banking powers, including direct access to payment rails.

Cryptocurrency is gaining wider acceptance as a legitimate commercial enterprise. But, like other money services businesses, these companies still find it difficult to obtain basic banking services. This is despite the fact that crypto is becoming more mainstream among consumers and in the financial markets. The industry is booming with a market capitalization equivalent to over $330 billion, according to CoinMarketCap, but it’s currently served by just a handful of banks.

The best-known institutions playing in the cryptocurrency space are New York-based Signature Bank and Silvergate Capital Corp., the parent company of La Jolla, California-based Silvergate Bank.

Signature’s CEO Joseph DePaolo confirmed in the company’s second-quarter earnings call that $1 billion of the bank’s deposits in quarter came from digital asset customers. And at just $1.9 billion in total assets, Silvergate Bank earned over $2.3 million in fees in the second quarter from its crypto-related clients. These gains weren’t from the activity taking place on the banks’ respective payment platforms. They came from typical commercial banking services — providing solutions for deposits, cash management and foreign exchange.

One community bank hoping to realize similar benefits from banking crypto businesses is Provident Bancorp. The $1.4 billion asset institution based in Amesbury, Massachusetts, which recently rebranded as BankProv, aims to treat crypto companies as it would any other legal commercial customer. Crypto customers may have heightened technology expectations compared to other clients, and present heightened compliance burdens for their banks. But the way CEO David Mansfield sees it, these are all things BankProv needs to address anyway.

“It really pushes traditional, mainstream corporate banking to the next level,” he explains, “so it fits with some of our other strategic goals being a commercially focused bank.”

Before BankProv launched its digital asset offering, it did a lot of groundwork.

The bank revamped its entire Bank Secrecy Act program, bringing in experts to help rewrite procedures and new technology partners like CipherTrace to provide blockchain analytics and transaction monitoring. It retooled its ACH offerings, establishing a direct connection with the Federal Reserve and expanding its timeframe for processing transactions to better serve clients on the West coast. And BankProv’s team met with crypto-related businesses for insights about what they wanted in a bank partner, which led the bank to upgrade its API capabilities. BankProv is working with San-Francisco-based fintech Treasury Prime to make it possible for crypto clients to initiate transactions directly, instead of going through an online banking portal.

At the same time, BankProv made plans for handling the new deposits generated by the business line; crypto-related companies often experience more volatility in market fluctuations than typical commercial clients.

“It’s definitely top of the regulator’s mind that they don’t want to see you using these funds to do long-term lending,” Mansfield says.

For BankProv, part of managing these deposits is deploying them toward the bank’s mortgage warehouse lending business; those loans are short-term, maturing within seven to 15 days. “[Y]ou need to find a good match on the asset side,” Mansfield explains, “because just having [deposits] sit in Fed funds at 10 basis points doesn’t do you much [good] right now.”

While BankProv officially announced that it would begin servicing digital asset customers in July 2019, the onset of Covid-19 made it difficult to get the program into full swing until recently. With travel being severely limited, BankProv made it a priority to hire new business development talent earlier this month that came with a pre-existing Rolodex of crypto contacts. The digital asset business hasn’t appeared in the company’s 2020 earnings releases so far.

Banking crypto-related clients will only make sense for some of the most forward-thinking banks; but for those that are successful in the space, the upside is significant. Mansfield believes BankProv has the attributes needed to thrive as a part of the crypto community.

“You have to be open minded and a little innovative. [I]t’s certainly not going to be right for the vast majority of banks,” he says, “and I think that’s why there’s really only two that are dominating the space right now. But I feel there’s at least room for a third.”