US A2A

Michael Salmony 0:12

Hello, my name is Michael Salmony and I'd like to welcome you to another episode of the payments trilogue together with Javier and with Ralf. And today we want to look at the US market, which is something we haven't done before. Now, I don't know if anybody's noticed, but there's a bit of turmoil in the US at the moment. ⁓ And that is actually also hitting the open banking sphere. ⁓

There was an attempt to introduce more regulation, but Trump killed the CFPB. So that doesn't look like it's happening. The banks are starting to charge for API calls. So a few things are happening slightly differently. So it's wonderful to have Sarah here. So Sarah, maybe you could tell us a little bit about yourself, your company, and a few of the things I've started to teaser.

Sarah 0:58

Yeah, absolutely. Thank you so much for having me guys. Really appreciate it. You'll find out in my little Sarah ⁓ background introduction here, but ⁓ I've spent a lot of time looking at and focusing on the European payment space. ⁓ I wrote a few articles on PSD2 and I was ⁓ very involved in making that switch. ⁓

from a technical perspective and guiding merchants through that transition when I was at Braintree. So still follow very much the global payment space. And it's just fascinating to see all the various implementations and how things have grown pay by bank and elsewise. But ⁓ my name is Sarah Stapp. ⁓ I am chief commercial officer at Aeropay. Aeropay is the fastest growing US pay by bank payment network in the country.

We're also the only ⁓ payment method, pay by bank provider that has a full end to end suite that we built in house. So we're pretty special. But myself, Sarah, ⁓ I've been in payments about 15 years now. I started when I was six. ⁓ Don't do the math, please. And ⁓ I actually ⁓ fell into payments as I think most people do.

I applied for a job posting for a small little startup called Braintree. I was employee number 20 there. I didn't know anything about payments except, know, this little plastic card is how I pay for things and that little box I didn't even know was a POS device at the time. I was like, that thing that I signed. So it was a cool startup in Chicago and I thought it was fun. And I joined.

And the first thing that when I joined in 2010, the Durbin Amendment was really big. So one of my first projects from the CEO was like, go listen to what that guy, Dick Durbin is talking about with this Durbin interchange regulated interchange and take notes. I was like, okay. So just really caught the payments bug and was fascinated by however, you know, all these things happen behind the scenes and there's so many pieces and moving parts to actually moving money around the world.

And just kept raising my hand whenever new projects came in and we did a huge growth geo expansion Initiative at Braintree over the almost all of my tenure there. So about a decade of my time was spent launching new markets 37 countries in the EEA region Hong Kong Singapore Malaysia New Zealand Australia Canada Brazil and we did the work for India, but it never actually launched so

⁓ very interested in all the ins and outs, know, completely launching these markets. What is pricing like? What's the competitive landscape? How do we actually onboard merchants? What are the regulatory rules? All of these things. So it was a very fascinating learning experience there. And then I consulted for a few years ⁓ for merchants and payment companies. And I have now landed at Aeropay, where I get to talk to merchants every day about why U.S.

pay by bank is the next thing that they need to add to their checkout. I live in Chicago, if you're interested, and I have two dogs, two kids, two horses, and one husband.

Michael Salmony 4:17

That's a very interesting.

Javier Santamaría 4:26

Thank

Michael Salmony 4:26

Fantastic. Now we know everything about you and a very impressive journey

you've had. mean, the brain tree from the start up and then all this global view. That's amazing. But maybe you could tell us a little bit more about the US market because the rest of the world always looks to the US in open banking as being the market driven one, the one that doesn't need so much regulation like we need in Europe. How is that going?

Sarah 4:50

think it's going quite well, actually. I feel like we're at this ⁓ hockey stick moment. There's a lot of things that are coming together, in my view. We ⁓ all know about MIF regulation, and there's regulated interchange in various different markets. We don't have that in the US. ⁓ Banks really like their interchange here, and consumers really like their points and their miles and their cashback.

and things like that. We have whole influencers in our country that have YouTube channels and Instagram, just all about how they can stack their points and do all these things. It's a whole thing. ⁓ So interchange ⁓ obviously can be quite high and merchants are looking for more cost effective ways.

to process those payments, particularly when you're comparing it to debit, because if you're thinking about it from a merchant lens, it's like, it's coming from the same place, right? Like, why can't I get more cost-effective way to do that with pay-by-bank? I think merchants are also looking at pay-by-bank as an interesting alternative from a risk perspective. So it's much more secure, it's much more strongly authenticated transaction versus credit cards or even debit cards.

comparing apples to apples there. And ⁓ it can be a very smooth experience ⁓ in the US, especially on mobile e-commerce or on a mobile device. most of those conversations are coming from, want to save money, ⁓ but then also I want to make sure it's a good experience for my consumers. I think consumers, we've got lot of ⁓ Gen Zs and ⁓ millennials that are

growing up and having more money to spend and they're, know, some are leaning in very hard in the card space and doing those points and stacking and all that. But there's a lot that are saying, I don't want a credit card and I don't want to do that. But they still don't want to carry cash because cash, carrying money around is terrible. So there's all this happening, right? All of these planetary, you know, things are happening, planetary alignment.

but we don't have the regulation like we're seeing in other countries. ⁓ The administration ⁓ is just gone. ⁓ But there are organizations and there are people and organizations like the FDX ⁓ and the CFPB that have been trying to push for open banking ⁓ frameworks and regulations. So what we don't have is regulation or a standard API.

for this actual open banking data itself. We have a menagerie of different ways and methodologies for bringing that information together. And we're still making it happen. So I'm very excited, more so on the framework side of bringing all of this data together and so that the consumer is aware of, the consumer, the other data protections, but also that...

standard way to get this ⁓ open banking data that we then at people ⁓ companies like Aeropay are bringing that data in and using machine learning and AI. I had to say AI at least once if this is a payments podcast, it's a requirement ⁓ to come in and use that very rich data to make better risk-based decisions on a transaction by transaction basis.

Ralf Ohlhausen 8:30

Could I ask you a question there? I mean, you know, ⁓ from a European open banking perspective, I must say I'm actually looking at the US with quite some envy these days. Now, going back to whatever 10 years or so, I guess we must admit that it was on the TPP side that regulation was

Sarah 8:44

Yeah.

Ralf Ohlhausen 8:55

seemed to be a good thing, forcing banks to open up. I mean, it looked like it would work in our favor, but it has fired back big time. And it's getting worse. And we're just going through the review of PSD2 into PSD3. And what has been put on the table originally by the Commission would have been

a way forward, so with lessons learned and making advancements, but with what the parliament and the council are proposing, it'll be a step backwards. So it's not looking overly promising at the moment. And ⁓ whilst it has brought some level of standardization, but if those are wrong, if you're getting the wrong standards or if you're getting limited, if you're limited on technology in particular, and that's one of our biggest problems,

when regulation goes into technology and tells you, but you should do it this way or that way. That is where we are now struggling, trying to make way or get things going based on the technology we're given and regulation being unable to really force any improvement because of course it's also not their job to

understand all these what's right and wrong about these API's and etc. So I think that for the last five years or so, and you mentioned already, so that there has been, I think, good growth in the US and with things moving in the right direction, whilst in my mind, in Europe, we've gone the other way.

Sarah 10:36

Yeah, I've seen, ⁓ I've watched from across the pond ⁓ what's been happening over there. And I think that was one of the first things when I was looking at PSD2, I actually read almost all of it. It was a very long time to read all that. ⁓ Not the most exciting read. But in reviewing it, my first question was, how are the smaller banks going to be able to adhere to this? What is this gonna look like? Who's gonna make it? So a lot of different questions.

What happened in the US is ⁓ we have this innovation layer. We have these tech companies that have said, you know what, we're going to figure this out. So we've got a lot of the big banks that have the ability to provide these APIs that tech company, fintech companies can directly integrate to. And then there's companies out there that you may have heard of them and actually Visa and MasterCard have invested in some of them, like the Jack Henrys and

What's another one? Okoya, MX. And then you saw like MasterCard has Finicity and Visa has Tink, although they've now, I don't know if you saw the recent conversation, but they pulled out of the US. So there are these layers that have been put in to say, hey, we know you credit union, because we have a lot of banks in the US.

We have a lot of smaller credit unions and community banks and things like that. And they might not even have one developer. They might have to, you know, pull in a consultant every time they want to make a change to their, you know, back port, backend or customer portal or something like that. So ⁓ we've seen these ⁓ bank aggregators, if you will, that have brought these OAuth type solutions to market. And I think that's really helped us ⁓ as a

US payments industry to drive that forward. So fintech innovation has really been the driver in response to market demand for this payment method. Nerd.

Michael Salmony 12:43

There are companies like Plaid

who famously sort of done this integration without anybody telling them to do it and without regulation. So that's really a role model which we're very envious of. But one thing maybe you can explain to Javier because he represents the banks here, how to motivate the banks because in the US they make so much money. I think it's 180 billion in credit cards fees per year. They must surely hate open banking.

Sarah 12:53

Okay.

Michael Salmony 13:09

even more than the European banks hated. So can you explain to us how you managed to convince them?

Sarah 13:09

Thank

Yeah, so I think we're always gonna be on opposite ends of the spectrum, right? From where I'm sitting, you see where interchange regulation is happening in other markets and the world didn't collapse, right? ⁓ I mean, in Europe, it's 20 and 30 bips. I think some US banks, thinking about average interchange, their hair would catch on fire just thinking about that loss. ⁓

What I think is banks ultimately care about their consumers, right? And I think that if they don't lean in and be there for their customers, they're going to go elsewhere. ⁓ Now, think Zelle is really interesting because it was its own kind of standalone solution. Now it's very much more integrated into a lot of the banks' portals even. I used to be able to use Zelle, app, and now

My bank has integrated Zelle, so I have to go into my bank app to do anything I want with Zelle. So I think they just, in my opinion, go with the flow ⁓ and think about the customers. I think we're all doing what we think is best for our customers, merchants, and then our merchants, customers who are consumers. And at the end of the day,

no matter how much people like it or hate the decision of consumer changes and adoptions, movements in that where the needle is pointing, the consumers drive everything, no matter how much we want them to do something different. And so you might as well, do you want to keep your consumers? You need to have the tools and the options that they're looking for. They're going to go elsewhere. ⁓ So that's always my thought is like, let's educate them. Let's let them understand what they're.

⁓ what the benefits are and why they might want to use it or they might want to go with a card. ⁓ But then also we can just come up with a new fee on cards and we just come up with a new scheme fee and it'll be fine ⁓ or a chargeback fee or something. But that's kind of where I'm sitting. But Javier, I would love to hear your thoughts on that from the banks.

Javier Santamaría 15:27

Yeah, yeah, I do have a different understanding on how the process went in Europe. And where we are now is a consequence of the pressures put by TPPs and fintechs on the regulators. And I think somehow they got what they were asking for. And that was the response of the regulator, very much influenced by the fintechs. And the problem years ago was that it was understood there was a confrontation in between banks and fintechs and TPPs.

and which shouldn't have been addressed in that way. Because the regulator forgot was the citizens, the consumers, the customers. And ⁓ they enacted regulation benefiting or trying to benefit one part of the industry against the other instead of focusing on really the needs of the customers you have been ⁓ commenting quite rightly. So I think we are here.

And we are in a situation in which we are far away from a market equilibrium point, I would say. And what we need in Europe is to come back to a market equilibrium point, to some kind of balance that we are missing. And we need probably to do some shortcuts and maybe we can learn some lessons from the US on how to come back to a more market-led environment. And my question to you, Sarah, is...

For instance, and you mentioned this ⁓ conundrum of the API standardization. How do you tackle with that and is there anything you can tell us so that we can also try to solve that issue in Europe?

Sarah 17:10

So what we, like I mentioned, it's a bit of a hodgepodge at the moment, ⁓ but we have ⁓ an organization called FDX ⁓ and they are writing a standardized framework ⁓ that will, I think, help that a little bit, ⁓ more than a little bit, a lot of it, ⁓ will help quite a bit. But I feel like we're already 60 to 70 % of the way there. It's working.

⁓ I think adding the standard framework and protocol will just make it easier for us to work together and to talk together. I think there's a lot of players and there's a lot of stops on the train of any transaction that's happening. And y'all know from the card side, mean, transaction, know, ⁓ messaging cleanliness or lack thereof can really affect things like acceptance rate and authorization rates and that

data being then pulled into if there's a dispute or something at the end of the road. So getting that bare minimum data elements that we want to send and having standardized messaging, I think is only going to elevate that. we are in a point where it's nobody else, typical Americans, Wild West, we're like, well, no one else is going to do it. So guess I'm going to just jump on in and figure it out. And that's kind of what's happened. And a lot of smart, thankfully, ⁓

the smart brains have put together ⁓ what's working quite well today. think what we're seeing in some of the news ⁓ articles as of late from JPMorgan Chase and Plaid ⁓ renewing their ⁓ data access contracts and things like that is just evidence that we are moving in this direction where it's getting ⁓ enough attention that the big boys and girls are saying,

we need to think about this. That's what I'm most excited about and I will definitely be following along very closely is pay by bank was a bit under the radar, especially for the banks. I think they were like, yeah, it's happening, but whatever. It's not a big enough deal for me to think about. ⁓ Now it is. And we at AeroPay, we've always paid for open banking data. ⁓ We don't screen scrape or do any of that. So

We're just kind of looking around for like, okay, so same, same, same old, same old. ⁓ That's great. ⁓ But what I really do like about FDX in particular, just coming back to that screen scraping and different methods for bringing that data in. True open banking data, as y'all know, is that API driven, like you were mentioning, Ralf. It's not screen scraping. It's not ⁓ penny drops and those kinds of things.

It's going to make things faster. It's going to allow for more innovation. It's going to allow to, it's the data richness that you don't get outside of API driven data that you get from open banking ⁓ is really what I'm the most excited about.

Ralf Ohlhausen 20:19

But talking about motivating the banks, far we've tried three ways. Initially by, well, what you've done in the US now for many more years, which is essentially using the interfaces which are there, which are user interfaces. Some would then lead to screen scraping, others would be API interfaces. ⁓

That could also be API based, all the corporate interfaces are APIs typically. But that was sort of stopped by the regulation, in my mind, far too early. Before there was actually any relevance. And then we tried to motivate ⁓ the banks by regulation, so forcing them. But as we know, the...

I think the real question is how do we get good APIs? Everyone wants good, so on our side, want good APIs, but how do we get them? So ⁓ we've tried with force compliance, but then the way this was imposed didn't lead to good APIs. It led to absolutely minimal APIs and basically, or as bad as they could get away with, essentially.

And then we've tried now for a few years on a collaborative way. call this SEPA payment account access scheme, SPAA, ⁓ where we're trying to get to actually paying for it ⁓ for good APIs. But that is also not working, at least not yet. because the interest on a bank side is really not that commercial, really, especially not as the whole thing is sort of very small.

compared with the, well, all the big, much bigger fish they can fry and have to fry elsewhere. So therefore, paying for API access isn't the thing either here, which is why I think the really only way that works these days, and for me, this is exactly why it has been successful in the US is that the, the TPPs have accessed the banks through whatever was there, be it

web or mobile, be it scraping or be it API access, whatever, and then ⁓ bring it up to a point where it becomes relevant. So maybe becoming a pain point. And of course, from a bank's perspective, the use of the automated use of a user interface is not what they want. ⁓ if and when that becomes a real nuisance, but only then

they would think about, okay, well, how can we make this better for ourselves? So the bank side, so the bank wanting to make it better, they want to basically lure the TPP away from a user interface into using a backend API. But of course, that would only work if that API was really as good or better than what the TPP was using otherwise. For me, that is the secret. But unfortunately, we're

Well, we're stuffed here at the moment, ⁓ somewhere in the middle between those three options, and we're really more towards regulation and paying, and neither of them works.

Sarah 23:42

And how have actual payouts been for y'all in Europe? Because I think the reason I ask is one of the areas where I've seen very interesting pockets of alignment with everybody is actually in payout. So for those on the podcast that don't know, we have two instant payment rails. We are years behind Europe in that regard, but we do now have

two different networks, FedNow and RTP through the clearinghouse where we're actually able to do 24-7 real-time payouts. And then there's RFP ⁓ that is soon coming, ⁓ which would be instant ⁓ deposits or pull transactions. we have seen consumer loves getting instant payments because that's a new novel thing for US consumers. ⁓

The banks ⁓ and everybody is able to charge more for it. And merchants can usually at least cover their costs ⁓ for it because consumers don't care to pay. We have Venmo, we have Zelle, we have PayPal and all of those. And if you go through the consumer customer experience when you're trying to transfer or withdraw money, they say, we'll send it to you via standard, which is three or four days, or you can pay a nominal fee of $2 and you can get it instantly within five to 10 minutes.

And most people are like, sure, that's not even that's like a third of a Starbucks, you know, here. So they don't care to make that payment. But everybody is really liked that ⁓ that win. So I think to your point, Ralf, you've got the banks feel like they're getting their bang for the buck. The consumers are excited and the merchants are excited. So I think we have to find that middle ground where everybody feels like they're getting their fair shake ⁓ and that nobody's losing out and that the customer.

wins. But I don't know, you guys have had instant like P2P and you've been able to do that for so long, that's probably old news and not exciting for Europeans anymore, right?

Javier Santamaría 25:49

Yeah, but I think that also somehow fire backs. Because for instance, because we are so proud of the instant payments, now in Europe we are imposing it everywhere. So that has become the priority for the regulator. The regulator has decided that that's the top priority, regardless the citizens' wishes. And beyond that, it's not only the instant payments. We are also imposing the verification of payee, which

Michael Salmony 25:49

was Javier's old outfit who organized that.

Javier Santamaría 26:19

It's also something functional and valuable for the consumer. But then that has become the second priority. So the problem is that open banking is not there. It's not first priority. It's not second priority. comes like seventh or eighth priority. I couldn't say that now banks are against open banking. The only thing banks require is that there is open everything for everybody. So equal and level playing field for everybody.

Beyond that, they are not opposing, necessarily if there are other priorities on top of that, they will have to serve those other priorities which have been set by the regulator. And that somehow crowds out the possibilities and the options for many other initiatives, which may be even more valuable for the public and for the consumers rather than maybe VOP or having instant payments for everything, which may not be.

the need for tomorrow but for a longer term future. But that's my view. And I think we are very much ⁓ in a paternalistic way directed towards something which maybe is not well aligned with the needs of the market really. And that's where we are standing up right now. In that situation in which we are led.

We cannot decide by ourselves which are the projects, the innovation that really the market needs to be implemented, but we are driven by what comes from the regulation.

Ralf Ohlhausen 27:56

Yeah, well, there is a little bit of movement there, especially on account to account payments in Europe, especially in relation to ⁓ regaining sovereignty for European payments, ⁓ independence. And of course, that is hard to achieve in the card world. therefore, account to account and instant payments is the obvious route to go, which is exactly what we're doing. And

banks are doing that too, well driven by regulation. but now I think increasingly also maybe by desires, or we have big bank to bank initiatives. And in actually many of them started as national payment, instant payment solutions. And they always started as a peer to peer person to person thing like Swish and Vipps and twist and twink and, and

Because that was the way to gain a critical mass before you can actually turn that into an e-commerce or into a retail payments solution. You have to have either a critical mass either on the merchant side or on the consumer side, because if you have neither, then you are in that chicken and egg situation where you can't get off the ground. this is coming. And as you may know, we also have now the ECB coming in from the sideline there with a

with their own e-payments solution. so we're, which is all sort of account to account movement. So we have a growing space there. But ⁓ from my perspective, unfortunately, not so much on the

⁓ on the open banking side of it, which is a shame because that is what we have just implemented. We spent so many years with every payment account in Europe is accessible. It's the one and only electronic payment system that allows that that gives us actually sovereignty today because if whatever anything goes wrong with the with other existing electronic ones, there is only one left to reach every every person in Europe. And that is open banking or cash.

But the electronic version would be be OB. but there's one thing I wanted to well, we have to come back. You mentioned already the commercials there and I think JP Morgan coming out with a big requirement there on one and getting paid for all that data access and data exchange. What's your view on that?

Sarah 30:33

I think it's just par for the course. think it's just an evolution of where we're at. The big banks are gonna, all the banks, right? They're gonna look for a way to, whether it's card, whether it's pay by bank, whether it's a loan, whether it's just like, they're taking their little nickels and dimes or maybe a little more with each of these things. And I think they see what's happening and

⁓ going in that direction to say, under the guise of, well, we want to help foster innovation, which I think they do. think Chase is a great, ⁓ in the US, they drive a lot of ⁓ payments and banking innovation because of their size and they can do those things. ⁓ But this is my surprise face.

whenever that that announce, okay, I'm like, oh, look, we're charging fees now for this kind of, you know, but these were happening, you know, with a lot of these bank aggregators already today. So it's, it's not a huge change for us. I think it's to me, it's just a directional, okay, this is, this is the shift to this is this is the direction that we're going here. And just going to be watching other banks, you know, may follow suit, we'll find some kind of equilibrium here at some point, but

At Aeropay, we've always wanted the best data, ⁓ the most and best data that we can get. ⁓ And we were willing to pay for it. And other companies that are providing a pay-by-bank network ⁓ solution ⁓ also have been doing that as well, because there is a lot of value. And I think this is something that people may not think about on the surface when you're talking about pure costs. But where I'm at at Aeropay,

That extra data allows me to send more bad transactions away ⁓ and accept more good transactions and protecting ⁓ our merchants, protecting our consumers, protecting everybody. We're making the decision to approve or reject that transaction. We don't have issuing banks in an account to account world that they have their algorithm and they have all this information about their consumers.

are relying on open banking data to make good decisions. So it's part of the cost of doing business as to how we see it at Aeropay. I think a lot of other people that are in this fintech realm are seeing it. But it is a shift from 10 years ago where you weren't having to pay for screen scrape thing and penny drops were not that big of a deal. But that was before AI. mean, not obviously AI was around, but not how we have it today. ⁓

a lot of this information being passed more easily. So I think it's just an evolution of where we're at. ⁓ That's just my opinion.

Michael Salmony 33:31

Can we dig a little bit into that? Our time is almost over, but you did mention AI, right? I the US is famously pushing that topic and it looks to some that all this clever stuff that we've built over the years with APIs and fintechs and TPP and open banking is being bypassed now with AI because it will just sort of log on and do its magic without adhering to any regulations, to any standards. Do you see that way or how do you see AI?

Is it a threat or a help to open banking? How would the two compare?

Sarah 34:04

I think it's such a double edged sword, AI, although my grandma was like, is this going to be Skynet? Is this like Terminator? going to like robots going to be in our brains? I was like, no, they're not that smart yet. ⁓ From a payments application, I'm very excited about what we can do internally, but you have to really consider, there's a lot of things you have to consider.

I don't think everybody has thought these things through because everything is just evolving so rapidly is ⁓ when we're able to contain an AI machine learning model in a company like Aeropay or Visa or whomever, it's closed, it's contained, it's controlled. ⁓ Whereas you're looking at some of these. ⁓

ChatGPTs and these big learning, open learning models, they don't have guardrails necessarily in places they should. And so the area where I'm looking at is more of that agentic AI, where the AIs are making decisions ⁓ autonomously with guidance from people. ⁓ That to me is very exciting and cool as a consumer, but it also thinking about

the other side of the coin. It's like, oh God, my AI booked a flight to Milan that's cost like $20,000 and it's non-refundable. That's not what I wanted. I said I wanted a beach vacation. I talking about Florida for like 500 bucks. So I think there's that, but I think similarly to crypto, not exactly the same, but I think there's...

what are the ramifications and I don't think we know yet. And that's the thing that's just a little scary for me as an individual. ⁓ And I would love to, that's one area where how do we put in guardrails so that we know it's AI? How do we, if AI is involved in some way, that's just knowing. think that's the biggest scare for me is like, is this AI or is this a person? Like, I don't even trust pictures.

emails and stuff anymore. So ⁓ that's my

Ralf Ohlhausen 36:27

Yeah, I

think that those I think those guardrails, that's exactly the thing. And so we got to look at how to secure this. But if you ask me, ⁓ a agentic AI, or especially the agentic commerce that Visa, Mastercard, PayPal, all them, that is screen scraping 2.0 or 3.0 even, really. So it's just a nicer name for it. And ⁓

Sarah 36:49

Yep.

Ralf Ohlhausen 36:54

So it's not about that scraping or not because the internet is all about scraping. The question is how to secure it. So how to put the guardrails, how to make sure that we, well, credentials are being used in a secure way, shared or not, but secured, secured. It's about security. It's not about technology, it's about security. So how can we add the required security and preferably without

telling which technology to use or not to use because it's about securing the technology not to forbid it. That's, I think, one of the things we should, well, we have to learn here in Europe.

Sarah 37:37

It's not the same, but I think PCI is similar. It's like, hey, you should not be writing down full credit cards, full of PANs on a sticky note and have it at your desk. You shouldn't be doing these, creating those best practices and having checks and balances to ensure that these companies are doing those kinds of things. So you don't have breaches, data breaches and things and the like.

Javier Santamaría 37:52

you

Michael Salmony 38:04

Very good. think our time is up, unless there are any last-minute emergency comments to make. I think I would like to thank you, Sarah, in the name of Ralf, and Javier, and myself, and all the people watching, because you've been completely fascinating. It's been really good to see how your part of the world works. So thank you very much for sharing that, and I look forward to seeing everybody watching at the next episode. Thank you.

Sarah 38:32

Thank you so much for having me guys, it was so fun.