Fraud has Found Private Lending. Now What?

Steven E. Ernest:

Okay, it's 11:30 and I appreciate everyone being here timely, as they say in the Marines on time is late, so at least everybody's on time and here we are. They have given me some instructions, things I must read to you. These are the rules of the webinar today. A question we always get is, Hey, can I have the slides? And the answer is an emphatic yes. You can have the slides. We will provide them to everybody free of charge. We're delighted that you're interested enough in our webinar one to join us, two to relive it time and again by reading our slides down the road. So yes, you can absolutely have those. I mentioned that that is a popular question we get if you come up with questions while we are presenting today, you can go ahead and shout them into your microphone and we won't sadly hear you because you're far away and we have muted all of your microphones done that on our own.

So it doesn't matter what setting you choose, you're muted nonetheless, however, we're interested in knowing what your questions are. And so if you would put those questions at any time during the webinar that we have today, beginning, middle, and right now, whenever you want, type those into the q and a section at the conclusion of Thayne's comments. We will go through all of those questions in the q and a and we'll answer them as best we can and that'll be interesting and informative for all of us. What we want to stress is that you put those questions in the q and a and you do not put them in the chat. Nobody's monitoring the chat. So if you write something in there, just going to be between you and the internet, nobody's going to see it. Nobody's going to answer your questions sadly. So put it in the q and a, we'll get to it the best we can.

And now we are going to go ahead and get going with the purpose for which we have come here today. So welcome everybody. My name is Steve. I am the Director of Litigation and Bankruptcy at the Geraci Law Firm. Joining me here today. It's my great honor and privilege to have Thayne Boren, he's the President at Sekady and we're going to talk to you a little bit about fraud. A year and a half ago, the firm asked me to give predictions what's going to happen during 2023, and my prediction was that fraud would be on the upswing and it was, they asked me for a prediction at the end of 2023 about what would happen in 2024. And I said the same thing and they said, I couldn't say the same thing, but it's up again in 2024, sadly. So that's probably why you are here today.

And if you notice, this lighthouse in our graphic has a big wave coming at it and it's fracked and it's rusted. That is not emblematic of your businesses, but that wave is the fraud. So you want to protect yourselves and get rid of all those rusts and cracks so that you can avoid the consequences of fraud. So what is fraud? I know that sometimes in taverns, if you're not talking about girls in cars and football, you'll be talking about fraud because it's a popular topic. So fraud, the legal definition, it starts with a misrepresentation. What is a misrepresentation? Well, it's a lie. It can be a lie about anything. I can say I once landed the space shuttle. I can say that I killed a saber-tooth tiger using only a gourd. I could say that I once had a date with Téa Leoni. All of those things are lies surprisingly to all of you I'm sure, but there's more to fraud.

It's not just a lie. It has to be a lie about a material fact. So if you called and you wanted me to be your lawyer and I told you that thing about the saber tooth tiger and Téa Leoni and all that stuff, it doesn't really matter because none of those lies are germane to whether I should be your lawyer or not. It just means I'd like to lie about things. The lie has to be about a material fact. So it has to be germane to what you're talking about. If somebody's telling you that their rental real estate is worth $16 million when in fact it's worth $16,000, well that's a lie. That's material if you're making a loan to them, and we'll delve into most of these things later. But the material fact is going to be the identity of your customer, the financial ability of your customer to repay the value and ownership of their property, things like that.

Those are going to be your material facts. So it can't just be any sort of random lie, but there's more. We're not done with fraud yet. The third element is that it has to be a fact that somebody relies upon. So if somebody tells you a lie about something that's important to the transaction at hand, and yet it isn't something that becomes the basis of the bargain for you, that is you work around it, they tell you that their real estate is worth $16 million, you get an appraisal, then you find out it's worth only 1 million. So you didn't rely upon their lie anyway, you're probably not going to be able to prevail on fraud. So it has to be a lie about something important that you did in fact rely on, but there's more and you relied upon that lie to your detriment. That is you made the loan assuming that the LTV was there for you and the final category in all of this, well, to your detriment.

So you wouldn't have made the loan if you had known about the lie. The final one is damage. Just because you rely on somebody's life, they repaid the loan, doesn't really matter. You're not going to be able to have a cause of action for fraud, but you had damage, so it cost you money. You didn't have the collateral that you thought you did. There was a jar of applesauce in the refrigerator and that was all that you could get for your collateral. You didn't get your money back. The customer had a lien on his property. Something like that has to have caused damage. So those are the elements, but what are the types of mortgage fraud that we usually see? Here's a laundry list of them. The first five are ways that your borrower can defraud you. The last two that we'll talk about are ways that your borrower themselves were defrauded.

So the first five, and we'll talk about them individually, would be causes of action for you the lender suing your customer for having defrauded you. The last two you probably actually would see more of especially these days are ways that your customer was defrauded. We'll assume by someone else, and they would then probably on the eve of your foreclosure sales, sue you and everybody else for fraud and say that they shouldn't have to repay the loan and they shouldn't lose their property because they themselves were defrauded. So we'll talk about all those individually. Asset inflation, that's the $16 million house that's actually worth $1 million.

You don't have to go too far to imagine circumstances where that would happen. Those are just people that kind of, everybody believes that their real estate is worth more than it actually is, but they might have sent to you some documentation which suggests that it had that value when in fact it did not. So the second one is appraisal fraud. That's your customer themself has an appraiser's license and gets a bad appraisal, or it's their brother-in-Law or somebody like that sends in an appraisal from last year, you don't need to spend your money on this one. I'll save you 1200 bucks. Here's a current appraisal, this is what the place is worth. And you say, oh, great, we will loan on that. So appraisal fraud, loan stacking. This one is a little bit more challenging to accomplish, but it does happen. We see it now and again, and this is your borrower has applied for the same loan essentially from five or so different lenders.

And each of the lenders says, okay, title company, you can go ahead and record this lien and we'll fund it so long as we're going to be the second or whichever position the lender thinks they're going to be. And usually it's a junior lien, so it's we're going to be the second or third upon closing. And the borrower then takes three of these five loans instead of just one and takes all of these proceeds and they don't really care who gets to the county recorder's office first to record their lien because those guys are going to be three, four, and five and the customer's going to ship all the money to Switzerland and they don't care about the house anymore because they've over encumbered it. But that's your loan stacking. Occupancy fraud, that's I'm going to use the place as a rental condo and I'm not going to live there when in fact the person's living there with their family or the opposite.

It's just they're manifesting who is going to live there when in fact it's completely not true straw buyer, that's a rich uncle buying or getting a loan on a house for his penniless nephew who has just flunked out of USC, something like that. So those are the five where the lender themself is often the victim of fraud. These last two are ways that your borrower is defrauded themselves. And like I mentioned before, we assume, and I've never encountered a circumstance where the lender was involved in that fraud, but often there are two victims, then both the lender and the customer. So title fraud, that is when somebody will forge some documents, generally a quick claim deed from the actual owner of the house to themselves. And then shortly thereafter after getting this quick claim deed, whoever is the grantee on that quick claim, we'll go out and set out encumbering the property and taking a bunch of loans because they show in the property records as the owner now when in fact the quit claim deed itself was forged.

So the owner who is usually an old lady who lives in the house and has for 65 years starts getting foreclosure notices with someone else's name on it, she's surprised and hires an attorney and they sue and unravel this whole thing. And we find out as the lender's attorney that all this stemmed from a forged quit claim deed, and those have to be notarized. Steve, how could that happen? You have a notary. Well, the notary sometimes is the brother of the quit claim guy and he has disappeared and gone back abroad where he lived or had one. This was a great one. The notary had left her notary stamp and her book in the second drawer of her desk, just like on my desk here, not locked. And anybody who wanted to could just get it and stamp things and then they would be notarized.

You can't do that. The notary has a $5,000 bond, but when you've got a $3 million loan getting back that $5,000 isn't often particularly satisfactory to you. So that's how title of fraud works. The victim directly is the owner of the real estate. The victim indirectly is the lender who is going to have a difficult time getting their money back. But in a moment we will talk about how the lender can recover their funds in that transaction because it will not be from the real estate. If someone has been defrauded out of their interest in real estate, the lender is going to lose that case as far as the real estate goes. So don't expect to foreclosure your collateral and rely on this fraudulent quick claim. It won't work, but we have ways for you to get your money back. So the last one is identity fraud.

Everybody knows what that is. Stolen credit cards, stolen driving licenses when you're on Facebook and it asks, what is your birth stone? And then miraculously three days later it says, tell me the day of your birth and it's going to match up with your Jedi nickname and you put in the date of your birth. Well, what you're doing is giving away all of your personal identification and someone in the Horn of Africa or in India or something is chronicling all this and putting it all together. And once they get enough of these little bits of your identity, they can assume your identity on the internet and get loans and do all kinds of stuff. So if it's not tremendously important for you to know what your Jedi or your prostitute name is, whatever these questions are, probably stay away from those kinds of inquiries on the internet because you're giving away your personal information.

And some of 'em will ask, well, give me the name of your favorite pet and the street where you grew up. Well, it seems like we kind of heard those before. What are those? Those are usually the questions that are asked by the creditors when you're trying to reset your password. So you're just giving away all of this stuff for free. Don't do that. It's not that important to have a Jedi name. And if it is, just watch one of the movies. Make up one on your own. So what are the defenses when you find out you've been defrauded? How are you going to get your money back or how do you prevent yourself from suffering these losses in the first place? Rigorous diligence. Get to know who your customer is. Find out where the holes are. Make sure you know who you're giving $2.3 million to 87% of the time if you match a driver's license to a driver's license number to your customer, that will be a good loan.

87. It's pretty high. If you're in college, you got 87 on one of your exams, you think you're doing pretty well. What's the other side of that? I mean, 13% of your loans are fraudulent, probably not going to help you sleep at night or get through your quarterly reviews. So 48% of fraudulent loans have VOIP. What is that? Voiceover internet protocol. Phone numbers. Not a lot of people have actual landlines anymore, but a lot of people who are defrauding, you have voiceover internet protocol, phone numbers. So if you're matching those and they come back to an island in the Caribbean, it gets your spidey sense up. There is not a single synthetic identity despite what you might hear on Fox News. Not a single synthetic identity has a registration to vote. What's a synthetic identity? That's a fake person. Somebody who doesn't actually exist, they never register to vote.

So if you are interested enough in your loans to investigate voter registration, driver's license numbers, whether they have A-V-O-I-P phone call, you do all three of those things, you're going to have a very high probability of an actual customer and not a fraudulent one. Appraisals with integrity. Know the folks who are on your appraisal panel. Don't just have random names that are behind the screen. Don't accept appraisals which your customer sends to you unless you know how they were obtained and who paid for 'em. It's much better if you pay for your appraisal yourself because that comes with the malpractice insurance assurances from your appraiser. If your customer buys the appraisal and it turns out that it's really wrong and you need to sue somebody about it down the line, well, you don't have what's called privity of contract with that appraiser and they don't owe you anything nor does their insurer.

So the $800 that you're spending on the appraisal is money well spent. If you have one of these days where it turns out you had some fraudulent valuations given to you, verify their occupation, your reputable allies, item five, those are your title insurer, that's your appraiser. Those are the notaries that you're sending out to get your documents notarized, all of those things. And then know your customer. The enhanced verification, that's what I talked about in item one. Do any of those things, you're going to dramatically reduce the likelihood that you ever have to talk to me again or that you suffer losses based on a fraudulent loan. What do you do when you find a fraudulent loan in your portfolio? How are you going to get your money back? Because it's not going to be by foreclosing on your real estate. You can make title claims.

That's what you buy title insurance for. Generally, you'll submit that claim and generally the title insurer will decline coverage because there's a fraud exception in most title policies. But you need to push back a little bit and the overwhelming number of circumstances the title insurance will pay. That's why you buy it. That's what it's for. You've got legal recourse. You can pick up the VOIP phone that's sitting on your desk and you can call me. My phone number will be posted at the end of this webinar and we can walk you through it. There's always plenty of folks that we can sue in these circumstances and get your money back. Third, damage control, what we lawyers call mitigating your damages, make them as small as you can. If this is a construction loan and you haven't funded all of your draws, well stop funding your draws.

Get started quickly rallying your resources and your ability to both make the loss as small as you can and not make it any worse. And then four is kind of when it's all over and you're sitting on the veranda having a cigar and thinking about how this one went bad. Well, don't just feel sorry for yourself. Implement some strategies so that this doesn't happen again. Well, what are those strategies, Steve? Those are all of these that we just talked about a moment ago. So there you go. That's fraud. That's how it happens. That's a little bit on how you can prevent it, and that's a little bit on what you can do if you find yourself having fallen victim to fraud. And with that, we have an expert in the field. His name is Thayne Boren, and he's going to tell us a lot more interesting things than I just did tha

Thayne Boren:

Thank you, Steve. Yeah, I'm not sure if I can claim to say more interesting things, but we'll certainly double down on a few of the topics and excited to talk to everyone today about this. And as the webinar topic is, fraudsters have found private lending, they've found real estate, they've found that they can make money, and so this is just going to be a growing concern and something that will be a topic, as you mentioned, for years to come. And so just a little background about cicada and what enables us to have some of this expertise and experience is we're a FinTech enabled software company and we have a deep history in making payables payable, automation, workflow automation. And again, our backbone is making payments. And of course we have regulations that we have to adhere to being in that particular section. So that's a little bit about us. We process a lot of different payments for a lot of different folks in this industry like appraisal management companies, appraisers, general contractors, subcontractors, title escrow, private lenders, banks, financial institutions, you name it. We kind of touch it in the commercial real estate space. Go ahead. Next slide if you don't mind.

So let's talk about wire fraud. This is a growing concern for everyone in the industry. Wire and checks still seem to be the prevalent payment method in which folks remit payment for both debits and credits coming in and out of their businesses. And of course, fraudsters have found this. They're exposing this. Let's talk about how they do that. And it's the old method, the primary option of spoofing your email. So what does that mean? A business email compromise or email account compromise are the two primary methods in which wire fraud is going to generate. And again, that is based on somebody gaining access by using phishing attempts to get and gain access to your email accounts. I am sure we have all on this webinar heard that phishing attempts, we all use the same username and passwords. We try to make them as easy to remember as possible and then we repurpose those same emails across the board.

But unfortunately, that is the primary method in which these fraudsters are going to gain access to our very delicate information. Something to consider too, as part of this is while artificial intelligence has helped industries and is certainly prevalent in this industry and growing, it has also helped these fraudsters and write more sophisticated content. They have the ability to go out and gather information about you, about your business through scraping public information and public records and using that all the way down to transaction and transaction details. Then they take that data and that information and that email spoofing and getting access to your information and they view all of the other contacts in your network around these transactions and they have transaction detail and they get very sophisticated in their ability to impersonate you folks within in relation to that transaction like a title or an escrow agent, perhaps your borrower.

And they're able to collect and consolidate that information to make that look very real and very tangible and very accurate around that particular part of the business. And so what's interesting about this from a fraud standpoint is the FBI actually tracks the top 30 ways in which financial crimes and internet crimes happen and why are fraud currently six at top 10? It's actually sitting at seven as an increasing so soon to be a top five fraudulent way in which transactions are happening that the FBI is tracking this through their complaint center. So again, very prevalent growing. It's not going away, but it's the old method of getting access to all of this information through that business email compromise or personal email compromise. So again, be very diligent in some of those things that you're looking at as it relates to your email. And I wanted to touch on just some of the other methods.

Stevie did a great job. Some of the other things like bank fraud, appraisal fraud, check fraud, and there's notary fraud happening and it's getting so far into folks getting aggressive in these spaces that they're actually showing up and pretending and impersonating notaries and having fake stamps and meeting people in public restaurants and showing their faces and things of that nature. So again, it's definitely not something that is somebody sitting behind a computer like you and I, they're actually getting aggressive and getting very familiar and have a lot of content at their fingerprints and fingertips to get very intimate with your information around this. So again, in summary, wire fraud is the electronic communication and defrauding the individual by gathering that information typically through email and through various public records to gather that information, gain access to your accounts, to your customer's accounts, and then posing as you within that transaction to defraud you. And then obviously within the wire transaction itself, you're sending out the banking information, your beneficiary parties, you have all that proprietary and confidential information about your banking institution and they're going to redirect those funds into their bank account and send that bank account wire request on your behalf posing as you. So next slide please.

So here's an example of what that might look like. This is really a payroll scenario, but you can see here, Hey, I'm making a request. This is what this request may look like. Go ahead and let's make this change. And so best practices around this are obviously calling to verify using various verification tools, which we'll talk about here in a little bit. But just a nice example of what this fraudulent activity can look like. Seems very real, it seems very accurate, it's relating to the transaction and they're just simply requesting a redirection of those funds. But that's exactly how it happens is as quick and easy as this. And something that I would share in some of our work that we've done on our side and the educational side of this is there's this perception that, well, I have secure email, right? And so I'm using this where I'm exchanging this document over a secure email.

Well, what does that actually mean? A secure email means that somebody that's trying to hack into your system has a very difficult time because it's encrypted. There's certain malware and spyware mitigation tools that your company's employing, but once that email is sent or once a phishing attempt has been received and there's action taking upon that phishing attempt, you've now opened that door for them to have access to that or whoever the receiving party is on the other side, you're not entirely sure or confident that their emails have not been compromised and that you're actually talking to that individual anymore.

Go ahead. Next slide, Steve. So what are the effects that are happening within the industry? So while this may seem in terms of percentage not significant, 14.5% from 22 up from six point a 5% or rather 6.9% in 21, a nearly 50% swing or a hundred percent swing happening, that number is growing. It's exponential. If you look as far back as 2017 when it was around one to 2%, it continually is growing and graduating within this space. And those particular transactions are not small. And that includes both the monetary loss from perhaps a lot purchase or a lot take down or a wire funding or a deposit all the way up to of course, your reputational damage within your organization, your client's reputational damage, the emotional distress, things of that nature. It has a wide and broad and sweeping impact across the business. And so just last year alone, there was about $500 million in losses within the title and escrow space according to fraud and wire fraud specifically or better said about $106,000 per transaction and monies that were lost or were attributed to financial losses according to fraud.

And so that's a huge number to obviously think about. And then in terms of just perspective about one in every 20 real estate transaction, we'll have some form of fraud or fraud attempt with that, and that number is growing. So that is a huge problem that we're seeing and those trends are now translating from title escrow, traditional banks and financial institution into that private lending funds, control escrow, private lending spaces. So this is something that we're going to have to stay even more vigilant on and be more aware of and spend more time working through our organizations on how to combat that. Go ahead. Next slide if you don't mind, Steve. Alright, so you got to love banks. You've got to love their three letter acronyms or the TLAs of banking. We've got a handful on here. Steve, you touched on one of these, but the ofac, K-Y-C-K-Y-B cent B-S-A-A-M-L and SAR or SARS reporting.

What do these have to do with us? We're not in banking. I'll tell you what they have to do with this industry. These are all very good items for us to be aware of, to consider incorporating at various levels and capacities within our organization. So Office of Foreign Asset Control, know your business, know your customer, the Financial Crimes and Enforcement Network, the Bank Secrecy Act, and anti-money Laundering Act and suspicious reporting around those activities. And there's another one, customer information profile or sip, which is very similar to know your customer. So just some three letter acronyms or four letter acronyms for us to be aware of as we kind of move through this next part of the presentation. Happy to share more on each one of these as we have q and a or if somebody wants to reach out after the fact of this, we can talk through again how these benefit your business. But really think of this as a blanket statement of what are my resources? Who are folks that are within this industry that specialize in some of these fraudulent activities from a money transmission and money movement as well as from a know your customer and know your business processes. Go ahead. Next slide.

We're moving money. If you think about lenders, you think about title and escrow companies, you think about contractors, developers, we are all transacting funds, we are all moving funds. What are some of the best rails that we can look at moving these funds? And what type of controls do I have and what type of security measures do I have in place as I'm transacting these funds? And I think everybody's very well of a wire. Again, it's one of the primary methods, check being still secondary most common forms of transmission of money, but they also happen to be the two highest components from tracked fraudulent transactions. So again, you look at the slide here, 65% of organizations in the financial world report some type of check fraud and activity. And of course there's positive pays and things of that nature, but checks are very easy to replicate.

Again, this is another area that AI makes it very, very easy for you to go copy and replicate checks, replicate signatures on checks, wires those wire instructions, capturing those wire instructions, pulling them in and using them for nefarious activities. You have a CH payment rails and what do all those mean to us? And it really boils down to what does your business need and what is that transaction and is there a need for good funds law? And are you making an inbound payment request and do you need good funds for that payment request? And if so, then perhaps a wire or real-time payment option is your best option for that. But if you're making an outbound wire and you want to make sure that those funds reach there, but perhaps time sensitive or good funds laws aren't applicable, then perhaps a wire is not really necessary.

Understanding the A CH payment rail and the automated clearinghouse, and what does that mean? Obviously the ability to digitally transmit funds from one institution to another, and that happens in a batching mechanism versus a wire as an individual transaction from one institution to another and settles nearly instantaneous. And really the decision boils down to again, what type of transaction are you conducting in your business? How important is it that those funds are good funds both coming into your organization as well as executing a payment out to the payee? And what type of research have you done around those funds coming in and those destination of those funds? And are you using any type of account and entity validation tools? And something that is a major, major difference as you consider these options is that wires, once those wires have left your organization and that wire request has been transmitted, that settlement happens nearly instantaneous and that cannot be recalled back.

You can certainly contact your institution and try to recoup funds, but your ability to claw back or recall that transaction, you really don't have a lot of options other than trying to work through, heaven forbid, in the event of a nefarious activity or a fraudulent scenario, you have very little or reactionary options available to you. But an A CH actually has settlement timeframes that can be 24, 48 hours and beyond, and you have the ability to recall those transactions. The downside to an A CH of course, is if you're receiving those funds internally, you have to worry about that on the front end of that transaction if those transactions are going to be good funds and could they be clawed back from your business before those funds are released or before you've accepted those funds and they've settled into your bank account. So in terms of safety and safety comparison and understanding the payment rails, they're obviously moving from using very secure methods that are managed by either NACHA or the federal government or the Treasury Department.

So from a security standpoint, excellent there. But in terms of once that fund has left your account and what you want to do with without funds and where it's going and how you want to handle that transaction after the fact is really the consideration that I would encourage everyone to take a look at and understand the difference between those payment rails. And again, I can offer up some additional collateral around this and perhaps a better understanding of how payment rails work. Some other considerations that you may want to have and look at is depending on your banking institution and what that looks like, they may have limits on wires and how much you're able to send via wire based on your banking institution or the receiving institution. Other considerations would be that wires are incredibly expensive and that includes outbound fees for you as the sender.

And the recipient's also going to receive an outbound fee. A CH payments are incredibly cost effective, typically ranging from like 25 cents up to a buck buck, 50 wires are going to be 15 to 25, 30 $5, depending on, again, your volumes and some of those types of things. And then checks, checks. If our industry could do away with checks, I think we would be much better off, but unfortunately that's something that's not going to happen overnight, but still a very prevalent method in which fraud happens and how those transactions are tracked. And we've seen, again on our side of the fence where we have people that say, oh no, I come in and I make the person look me in the eyes and I issue them a check. And I'm like, yeah, but did you check their ID and the validity of their id? Well, no, but I looked at them and I'm like, I don't know if that's a good security control, but I don't run your business so you're going to do you and hopefully it pans out okay for you. But those are some of the scenarios in which I would encourage everybody to take a look at those rails and what are those options that best fit not only the transaction but for their business? Go ahead. Next slide, Steve.

Alright, so what are some of these best practices? Let's talk about those for a second. So next slide. Steve, I loved your comments. The importance of due diligence training, vigilance on fraud detection within your organization is paramount steps that your company is taking to validate borrowers, their transactions. What are the fraud trends? What's happening in the industry? How are people being defrauded? It is going to be very innovative on that side of the fence with these fraudulent transactions, some of the services that are available out there and partnering with people that have certain capabilities around penetration testing, software services around encryption protocols, account and entity validation, working with companies that have system and organizational controls or SOC credentialing. Does your business have a response plan and what is your risk mitigation plan and what does your business continuity plan look like? I think it opened up everybody's eyes this last fall when we had some of the biggest nationwide title insurance underwriters hit by fraud and it crippled their business and they spend piles and piles of money around these types of services and trying to mitigate these fraudulent activities and these hackers and these criminals.

Putting your banking information behind encrypted websites that have multi-factor authentication, things of that nature. And I want to emphasize the human element of your business as well as your clients and who your clients are interacting with are incredibly crucial for your business. You can have all of the gates and all of the keys and everything behind locked doors, but if you give somebody a key to walk in the front door, it doesn't matter what you've done and what investments you've made, you're going to expose yourself and your business. And that includes consistent conversations with your borrowers and your clients and whoever you're remitting payment to, making sure that you're not seeing any suspicious activities within those organization. And some of those recognizable red flags around inconsistent documentation if you're receiving a request for a payment and that seems urgent and they need it right away.

And we understand that payment workflow and some of those things are certainly problematic across the industry, but when it's, Hey, I need to change my banking information or I need to change my institution and it needs to happen today and I normally receive an a CH or a check from you, but I want a wire today, those are all pretty good red flags that you should probably take a second look at what that transaction is and how to manage those requests internally while still providing of course, excellent customer service. Next slide. So what are the future of payments? We've talked about wires checks, aach H is really kind of the here and now, but the buzzwords across this industry for the last few years have been the real time payments network fed. Now these infrastructures are amazing. They work very similar to a wire in the terms of being able to send a payment in real time, have those payments settle in real time and making sure that those check all the good funds, laws, boxes.

They're at this point looking like they're going to be far more affordable than then perhaps wires have been historically. Really what it boils down to is it boils down to availability. Fed now as an example, have about a thousand financial institutions that have registered and have fed now capabilities. The problem is is you have eight to 10,000 financial institutions in the United States and both of those entities have to have that Fed Now capability, so originating the request and then of course executing the request and receiving that. And then on the real-time payment network, you have that payment network which we're super excited about at the availability of that right now you really have more institutions that would allow you to execute a payment to credit an institution, but for some reason the big four, the big five banks, just none of them want to be able to do the request for payment and initiate that poll in.

And so that's not an extremely viable option on that side of the fence either. We are hearing that the availability of those will be Q4 of this year to Q1 of next year. They said that the last couple of years, so we're not going to hold our breath, but those are really good viable options both for speed of payment and execution, but they also have mechanisms in which, for example, transacting a real-time payment request or that RFP request for payment to then move the money over the RTP rail actually is a request from an entity to you, unlike a wire where you have to be the originator and send that request and expose your financial information through that request to those folks. This will actually give you ability to see the request for the payment and then make an acknowledgement of that, do your validation of that information and then of course release payment.

Some of the other options that we'll talk about here around current safety protocols, if you don't mind going to the next slide, is the ability to do account and entity validation services. So there are a plethora of services in which that will help you match payment information with account banking information. So does Steve's bank information match Steve's name? Can I put those two pieces of information together and can I feel comfortable remitting payment to Steve based on that information? And so unfortunately 60% of fraud is caught after the fact. How can we get more into prognostics around getting those and catching those fraudulent activities before they even happen? And then tools to verify business entity information, address information. I loved what you said Steve earlier about documents and document validation. There are even tools out there that will evaluate the validity of a government issued id.

If you want to go as deep and wide into your due diligence is that there are certainly services out there that handle that. There are services around real-time verification processes around clearing houses of payments. And so there's just a bunch of tools that are out there. It's really more of an awareness and how to best implement those tools within your processes. The great news is a lot of these are digitized services in which you're already collecting a bunch of information around your client during the underwriting process, you're finding out more about the borrower, its project, a lot of that same information that you're gathering can be used to plug into these services. And then of course validate that all that information is real, it's tangible and that you can feel comfortable moving forward within that scenario. And then what roles do software providers provide to you in your business? Obviously we're not going to all go out and build our own databases and warehouses of all this information and store it and things of that nature. So how can we pull in these services to help us within our businesses to procure our interests, our capital, our investors' capital, things of that nature, and go ahead and next slide.

So your due diligence doesn't stop upon underwriting. You have continued exposure through the lifetime of a construction loan. Knowing who and what you're paying for, we feel are very important aspects of the overall risk profile of a project or a file within your organization. Historically it's been managing things through spreadsheets, through email, things of that nature. We've already talked about how email is a great tool. We all leverage email but can also be one of the primary drivers behind fraud and fraudulent activities and fraudulent requests. And so with that being said, fund control is a pretty typical term that we hear obviously within the industry. It typically has a negative connotation. We talk to folks in the industry and pretty commonly we say we hear it's never really a problem until it's a problem, which I think is an interesting statement to make. If we took the same philosophies on buying insurance and things of that nature, we'd probably end up with some pretty significant losses around those things or scenarios in which, hey, we really trust our borrowers.

We don't want to have to do this to them. But what's great is there are tools and services that are available out there that really automate the entire process from cradle to grave for both the subcontractors, trades, vendor suppliers, all the way up to the folks performing the draws, the approvals, things of that nature. So there are opportunities for you to consider within your own organization that not only pre-construction reports and feasibility studies and the appraisals and all those things matching, but how do you have that continuity of security throughout the life cycle of that loan all the way through where it gets closed and of course ends up in a permanent financial situation. So those are some of the things that we really think about in terms of holistically looking at not only the payment and the payment execution, the validation of all the parties within the transaction, but also within the workflow and making sure that those funds are not being diverted or converted and things of that nature.

So go ahead and next slide. So know your customer, know your business. These are typically associated with banks and financial institutions. Regulatory requirements around lending. If you're a traditional, again, bank or financial institution, bank secrecy act, anti-money laundering act. Again, what do they have to do with our businesses? Why would I ever go through this activity? Well, it's exactly what Steve touched on in the beginning of this. It's getting to know your client, getting to know the intimacies of who's involved, who are the parties that you're transacting with. Your KYC process can be as broad and wide as what you want it to be, or it can be skinny down just to where you feel comfortable in which you know the parties, you know the transaction details, some of those types of information that you should be collecting. I believe we have some samples of what they are on one of these next slides here, Steve.

So controls, they should match your organization's risk tolerance, your thresholds. We've talked about training. I'm going to emphasize that all day long for you and for your business. Training is not an event. It is continual training and continual education. We see more sophistication daily and fraud and fraud attempts. And so we're going to double down on that topic and go ahead. Next slide, Steve. So just some examples of what some type of customer due diligence or knowing your customer may look like. Driver's license, physical address versus a PO box. Steve talked about phone numbers. Do these phone numbers match? Have you done a secretary of state search and know that they're in good standing, perhaps beneficial ownership information or articles of incorporation, all of those things. W nine information doing a W nine match. All of those are tools and opportunities without going too far outside of the data and information that you're already requesting from these folks when you're doing your underwriting process to also go through and do a nice KYC and get more familiar with that entity. Get more familiar with the customer, not only your customer who's your borrower, but also the customers, clients that they're working with and getting some information around them in the event that you're remitting payment to them versus perhaps remitting payment directly to your borrower.

Next slide. So in conclusion, the importance of due diligence is paramount within your business validation services and secure method, there are services that are provided in the event that you are wiring a lot of money and that is important to your business in which you can provide secure wire instructions behind an encrypted website that have unique codes that you can share with the recipient that you know is going to directly to that person that has multifactor authentication. Instead of just picking up a phone number that may be spoofed, staying vigilant informed, inform yourself, inform your clients, have policies around these things for your interactions with your clients and let them know that it's not intrusive, but it's protect you and them and those resources that you guys have worked hard to accumulate and those relationships that you've worked hard to build. Have an incident response plan.

Have a business continuity plan. Do regular penetration testing for your website, making sure that folks are having good practices around the access implement tools like multifactor authentication, which there are tools out there like AWS and some that really perfect these things. Or of course Google has some of their own things. Internal training. It doesn't have to be incredibly cumbersome. There are lots of reputable solutions out there like know before. I'm happy to share other services that are out there. And then partnering with reputable or good standing companies that are SOC certified, that have gone through some of these processes that have the encrypted websites that you're storing your information behind and that you're in good hands as you start to roll out some of these security measures. And really, again, try to mitigate all those risk scenarios that are now rearing their ugly face within the industry. So those would be our best practices there, Steve, and some of our recommendations. Again, happy to share more on additional insights as we see fit, but I think I'm probably past time here, so we want to move to q and a. Happy to do that.

Steven E. Ernest:

Yeah. Yeah. So partnering with reputable vendors, I can think of two. And here they are right here. So Katie and Gisi, we have some questions in the q and a. This will be good. This is sort of the lightning round. We don't know what's going to be in there. Hopefully we'll know the answers. We've got an expert in things, so he's going to bail me out. Number one from, I love this one. I do fraud webinars and I get questions from anonymous attendees. That's sort of the paradox, but here we go. How does a private lender protect themselves from fraud by a foreclosure trustee? Well, and there are a bunch of questions in here, but I'm going to take them individually from this anonymous guy. So using a reputable organization, there are plenty of them. They are oftentimes not the cheapest. So if you're using a foreclosure trustee that you found on the internet through a spam invitation that you got through your LinkedIn account and they're promising that they're going to save you $623 in your foreclosure, they might.

But a lot of times the cheapest person that you're going to use is going to wind up being the most expensive. So it could be a good deal on a bad watch. Just be careful and know the people that you are dealing with. The follow onto that question, I'm a private lender and hired a foreclosure trustee to process my foreclosure on a defaulting borrower trustee took it to sale and it sold to a third party. Sounds good so far. The trustee converted the sale proceeds. Now it sounds bad for their personal use and I'm out a lot of money, I bet. Was there anything I could have done to protect myself or are there any worthwhile remedies to protect yourself? Again, use a reputable foreclosure trustee. I can think of one. It's right here. Rasi, LLP. We have an in-house trustee. There are many others.

And there're the big names in the industries. If you go to either our conferences, the G conferences, which are Innovate and Captivate held at alternate either the spring or the fall each year or Apple or many of the other conferences, all of the exhibitor forums will have booths with foreclosure trustees in them and you can trust the ones that are at these conferences. So that's one. Is there a way to get your money back? Well, it depends how shady your trustee really is and how elusive. So yeah, you can sue him. Hopefully he has some insurance. Potentially your insurance will cover some of that. Otherwise you're kind of chasing an apparition at times. Was there anything I could have done to protect myself? Yeah, well that's what we talked about. What were the remedies? I've used this company for years without any issues. I'm certainly sorry to hear that.

I would definitely suggest that you don't use them anymore, but I'm sure you already knew that. So question number two from Jason wo Jack, shouldn't the title company wait for the loan to fund the loan until after the mortgage deed of trust is recorded to ensure the title position? Yes. So this is the fraud in loan stacking that I talked about before. The instructions to the title company will generally be record this loan as long as I'm going to be a second position lender. And the reason in escrow states, the reason that you have escrow is to make sure that everybody is getting what they bargain for. Well, at some point you've got to go with funding, you've got to go with recordation, and something's probably going to have to go first. So these loan stacking scams generally will be paid through your title insurer.

Who is the entity that you're talking about? Well, they have done this or shouldn't they have done that? And the answer is probably yes. And ultimately probably that's why they're going to pay you or your loss. So good one. All right, next one, anonymous. And tha, I don't mean to freeze you out of these. If you have things to add, then go ahead and get right in here. The next one, anonymous attendee. Can I sue the appraiser? If the appraiser didn't disclose, there is violation of the building, open construction permit, et cetera, which is already registered at the county. You can try. That's not the first place I would go with that. I'm not so sure that the appraiser can be charged with knowing the building code and checking all the permits and that kind of stuff. I don't know that that's really the appraiser's job.

So you could try, but I wouldn't bet my business on winning that one. If so, within how much time do I have to sue the appraiser? So that would be a general negligence claim. And the statute of limitations on negligence is three years. So you'd have to file that case within three years of having discovered the negligent act. So it's not necessarily the day that they issued their appraisal, it's the day that you figured out that they'd done something wrong. But again, not the best claims. I don't know a lot of attorneys that would take that one on a contingent basis. So get ready or after discovery, after damage is realized, after I foreclosed the wow, this is a big one. After I foreclosed the property and sold the property. So it's discovery. I unwittingly answered your question before I knew you had it. That's what it's when you discover that you've had the damage anonymous attendee. Number three. How can a lender effectively pursue legal action? These all seem to be questions for me. Thay, I apologize. My presentation must have been far less complete than yours. How can a lender effectively pursue legal action against a fraud ring?

A ring. Well, whoa, my question just went away. You've got to do some investigation. You've got to figure out who is involved in the ring. You're going to start with law enforcement, so you're going to make complaints to your state and local authorities, your federal authorities as well. There's a website called I-C-C-C-I believe, and they do some investigations for you. I wouldn't expect the Marines to show up and start chasing everybody down, though law enforcement has other things that they're paying attention to these days, sadly, and you're probably not going to get the response that you want, but you definitely want to make all of those complaints because it's what you pay your taxes for. So you might as well. I'm curious about the impact of threatening fraudsters with FBI involvement or other legal consequences and how such threats can pressure them and to cooperate.

So this is a great one, and there's so much in there. I love this question. Anonymous attendee. Thank you so much. So threatening criminal punishment in order to elicit civil gain, which is what you're talking about. I'm going to call the cops if you don't give my money back to me. That's what you're saying. I can't do that. No lawyer is allowed to do what I just said, threaten criminal punishment in order to elicit civil gain. It's in our rules of professional responsibility. But if you are not a lawyer and if you are not a member of the bar of any state, you can do that if you want. You can say that. You can rattle the sabers and say, I'm going to have agents, Scully and Mueller, and they're going to break down your door and they're going to put you in jail if you don't give my money back to me.

Somewhat. Be careful about that, but probably you can. The jail part, I don't know that I would do that. You're not allowed to threaten people that they're going to go to jail. But if what you intend to do is avail yourself of law enforcement or government remedies, you're certainly capable of sharing that with your customers. I would advise you or counsel you not to do that unless you actually intend to do it. Don't just threaten people with things that you're going to do if you don't intend to do them. Because what then are you becoming yourself a fraud? And we don't want to be like the folks who are defrauding us.

Thayne Boren:

And Steve, I'll just chime in there real quick. In the event that obviously there's a financial transaction fraudulent event, that's where that suspicious activity report comes into play. And you can submit a suspicious activity report through a bank or a financial institution, or again, there's payment processors such as cada that can help you submit those suspicious activity reports. And somebody in the fiend world will take a look at that. And in the event that it's merit, FBI involvement can get there if again, it's deemed necessary and depending on the transaction type.

Steven E. Ernest:

Laura, thank you. Anonymous attendee number three, Roman K. What tools slash vendors can we use to verify a driver's license? Thayne, can you think of anyone?

Thayne Boren:

You can use us there are out there like, Hey, there you go. Shameless plug. There are plenty of others. Depending again, on how deep and wide you want to go into that process. There are other validation tools out there like n Lexis, LexisNexis, there are plenty of vendors that can help you with this, and so happy to talk more about what that might look like and what the need is. And if it's us, we can certainly point somebody in the right direction.

Steven E. Ernest:

The general answer on that one though, Roman is a private investigator. If you don't have one with whom you are familiar, get to know the good folks at Sekady, they can help you. Right. Jim Paulina, what recourse is available if a legit appraisal or is way off in valuation or misleads? Things like access? Well, just because an appraiser makes a mistake doesn't mean they're a bad person. So they carry a CGL corporate general liability insurance just like everyone else. Everyone makes mistakes. I have a good friend who said, doesn't matter what you're doing 5% of the time, you're going to screw it up. How do we have enemies if we have friends that are giving us great advice like that? So any appraiser can make a mistake down again, and that's what they have insurance for. So if they have made a mistake in their appraisal, it doesn't mean they've defrauded you.

It just means they've made a mistake and that's why they carry insurance. So you would ask them for their insurance information and make a claim. If they won't give it to you, you can sue them and God bless them. They're going to get in touch with their insurer at that point and they were on a roll with people using their real names. Can Thayer, are you saying that if a borrower, not you, the lender pays for the appraisal, but the appraiser puts the name of the lender as lender client on the appraisal that you the lender, do not have the appraisers insurance behind the report? Wow, that was a long, and I saying that if the borrower, okay, so I'm sorry. The lender, the appraiser puts the lender's name on the appraisal, but the borrower pays for it if the borrower pays direct. Now, see, none of these are going to be hard and fast rules, but if as a line item in the closing you have the borrower paying for the appraisal, that's a bad fact. It's not going to necessarily be dispositive. I like that the customer on the appraisal is the lender and not the borrower. That's a very good fact for you and I think probably you're going to have the benefit of the appraisers insurance in that case. Not perfect, but probably you're going to be okay. So that one, I think that you've set up your process the way it should be an anonymous attendee. He's back. Here we go. Should all or any of the safety protocols apply to private lenders that we would be using for funding?

I think so. Individuals and or organizations in the PML industry, all of the safety protocols apply. I don't know what safety protocols you're talking about is all. Maybe that was tha slide, but I think those were suggestions that he was making and the more of those you implement, I think the better off you're going to be. Tha you got anything on that one?

Thayne Boren:

Yeah. It really boils down to if we're talking specifically around K-Y-C-K-Y-B or know your customer, know your business, those can be very, very heavy and very intrusive and you can go through and some of the stuff that you talked about, Steve, where it's like, did you drive a 1997 Honda Civic answer yes or no, and ask you a series of questions or do you eat applesauce every single day for launch? And some of those types of things, there are series of questions that you can go through and make it pretty intensive or you can just do some the scenes data gathering collection and put all that and assimilate all that information together to get you comfortable. It's hard to prescribe not knowing the business. What is the best process for you? We can certainly share best practices deeper than what we did on a singular slide, but at a minimum, those name, physical address, phone number, articles of incorporation type things are I think very good items to have. So you know who you're doing business with and you can get familiar and oriented with those businesses.

Steven E. Ernest:

Yeah, yeah, the applesauce that's really using your gord. Nicely done. Katie Manard. Does verification of deposits have a place in due diligence when working with developers who have large deposits and withdraws going in and out of their accounts? This is a great one for you.

Thayne Boren:

I want to make sure I get this question. Would you mind reading it one more time?

Steven E. Ernest:

Does verification of deposits have a place in due diligence when working with developers who have large deposits and withdrawals going in and out of their accounts? So this is like somebody, a developer making a subdivision and every draw is enormous. Does verification of deposits, is it important in those circumstances?

Thayne Boren:

I will tell you, I think it is very important, right? We're dealing with large sums of money and if that's your private wealth, how would you treat that private wealth and knowing where those funds are coming from and going to and validating that information. So doing ledger reporting using tools such as bank account deposit validation, seeing transaction detail and information where those funds are being pushed out to. Those are all services that can be provided to you and that you can use and require of your clients. And I think that's a really good way to get comfortable with where your money is going. And again, those tools are available. There are plenty of services, shameless plug, again, we're one of those services, we can do that for you. We can guarantee that your funds get remitted directly to the payee if it's the person performing the work versus just releasing funds directly to a borrower as an example. So yes, there's a few different ways that you can slice and dice that scenario, but I think that is an excellent idea for a good best practice.

Steven E. Ernest:

Yeah, I think that's right on just because they're a developer and they seem reputable and they've always done what they were supposed to do in the past. Well, what do people do when things start to go pear shaped? They kind tend to take the money that's supposed to go to the sewer guy or the electrical guy or the person that showed up to lay foundation for 15 pads and they use that money to pay their kids' student loans instead of pay those guys. And you're not going to know about it for a month and a half or so, and the way you're going to find out is you're going to start seeing a bunch of mechanics leads being slapped on your collateral. And if you haven't been exposed to mechanics liens yet, good for you because no matter when you recorded your security interest, the mechanics lien is going to jump right in front of you and it's almost impossible for you with a lot of those.

Thayne Boren:

If your borrower has a lot of heartburn around that, that's probably red flag number one because these services are not intrusive. It's literally probably a 45 minute set up to get access to that type of information and you're ready to go. So again, red flag number one would be if they have tremendous heartburn with you knowing where your money is going.

Steven E. Ernest:

Yeah, yeah, good one. All right, next question, Jim Paulina, this is a good one. I like it. Is it realistic to have a notary video record the borrower in real time by FaceTime or WhatsApp so that you can compare the image on the driving license? It's certainly possible. I'm not going to tell you what your notary can and can't do. I was at a conference last week and somebody told me that they always get their notary to take photographs of the person who is signing the documents and sends those photographs along. So down the road when somebody says, no, that's not my signature. No, I didn't sign any of that stuff. You have pictures of them and hopefully the pictures match. So yeah, if you're notary do it and the customer doesn't have sort of shyness or privacy concerns in that regard, I think it's a great idea. Go ahead and do it. Yes,

Thayne Boren:

Steve. Validation, validation, validation on that front, speaking less maybe on the notary side of that, but one of the more increasing types of fraud that we're seeing is through Zoom and teams and go-to meetings where I'm an nefarious actor, I've gained access to your email, I want to set up a meeting that you and I can converse with and I want to talk through this transaction. I've gathered all that information through my active research around the transaction and combing through all the emails and public records, but man, I'm going to put a static image of my face or the person I'm pretending to be their face up there and say, Hey, I'm having audio issues and video issues. I'm just going to put a static picture up here, but I'm going to go ahead and talk to you about that. That isn't increasing method in which people are gaining access and continuing to validate information to get the fraudulent scenario that they're searching for. So they're going at pretty great lengths to do that, including having webcams conversation. So just a little nugget to add on there.

Steven E. Ernest:

Yeah, thanks. And you say that as both you and I have static images of ourselves on the screen, but well we're moving for real high North Thane are attempting to defraud you, Aton and bird. The next question, are there any real cases where fraudulent borrowers actually get caught? Yes, so for sure, we're painting some grim pictures here, but I would say in 60% of my cases that I have, the people who have defrauded, everybody are found. Now the next question is do they have any money or has it all disappeared by the time you get them? And that's even a smaller percentage because generally speaking, the miscreants have abdicated the realm and they either spend or send the money somewhere else before you get your hands on 'em. But sometimes you can unwind those transactions. I'll tell you, the overwhelming source of recovery for lenders in these circumstances is insurance, though. That's why you're buying it.

Thayne Boren:

Don't be a part of the two thirds that catch it after the fact. Try to get in front of those things and validate that information on the front end, which is less effort than trying to recover things after the fact.

Steven E. Ernest:

Terry Wallman, you cannot threaten police involvement before you actually report the matter to the police though after you have reported the matter, you can then advise the baddies. The fraudsters I guess is what he means that you have reported them to the police. So there's a tip from Terry Wallman where you have it anonymous attendee, he's back, whoa, where this thing keeps moving. Anonymous attendee. Is the appraiser liable if they appraise the value too high, which caused lender to lose money? Yeah, so that's why they have CGL insurance. It's just general negligence. Terry Walman, here he is again here in Canada, does not matter who pays for the appraisal, but for lender to be able to rely on appraisal report and sue appraiser for negligence or worse. Okay, now he's telling us how things go in Canada. That's good. Anonymous attendee. If we sign an NDA non-disclosure agreement with a third party company who would sell our mortgage notes out to other note buyers, does our NDA automatically extend to their clients? The answer generally no. And if ever personal information leaks out, do we have a case, a case against whom? I would wonder, can you sue your broker or the person who bought your loan? Yes, the answer is yes. And they would hopefully have insurance for a circumstance like that.

Angela Vic, regarding occupancy fraud, this is one of mine. How does one best verify a borrower's actual residential address? Best way, since you put that word in your question, you would actually go there and knock on the door or have somebody go there and knock on the door and see who answers and see if it's your customer. See if they know your customer. See if your customer really lives there. If they gave you a credit application and they told you what kind of car they drive, is that car parked in front of the house? Here's another one. If you don't want to drive out to their house and knock on their door, have 'em send you two or three utility bills that have their name on 'em. If it has their name on 'em, I think there's a reasonably good chance that they live there.

If it doesn't, I think there's an overwhelming chance that they're going to have some excuse for, oh, well my roommate signed the gas application or something. If they have these excuses, spidey senses, my questions are disappearing. Terry Wallman, again, fraudulent lady, was caught, ran upstairs, jumped into her bathtub and slit her wrist. This is quite a tale when the statement of claim was dropped off to her unexpecting husband at their front door. Okay, well that one could be a TV movie or Steve Story hour for heaven's sakes, Jim Paulina. Is there any way for me to verify how long a borrower has been banking with a particular account number saying that's a you question?

Thayne Boren:

There is a long and short answer to this. I will give you the shortened version. It really depends on the institution. The ability to go back and pull down data around the length of a time of long an account has been opened really depends on the availability of that data that we using. Our services are able to go research that. So it's independent of each institution. Typically smaller institutions give you less information. The ranges that we typically see is 60 days to two years. Usually we can go back and see as back as two years.

Steven E. Ernest:

Yeah, good stuff. Well, we have answered a hundred percent of the questions that are in the q and a and depending on how you gauge our time, we're either 20 minutes over or 10 minutes under Thayne. Do you know any good jokes? Got anything to tell us for 10 minutes or should we let it go?

Thayne Boren:

Maybe some inappropriate ones. So I'll pass on jokes. But yeah, there was a lot of questions around appraisals and for those that maybe aren't aware, a lot of the states and jurisdictions have ethical committees and boards that you can report information about those companies. So that may be an opportunity for folks to look at which states and jurisdictions that they may be having some problems in and give them an avenue to make that information available to interested parties that want to curate that information and perhaps act on it.

Steven E. Ernest:

Okay. A few minutes ago I mentioned with one of the crime reporting questions that you can use the Internet Crime Complaint Center and the website for that is www.ic3.gov and that's a pretty good resource for you. I will also put that in the chat so that folks can find it there. But once again, I, the letter I, the letter C, the number three.gov and that's a good place to play around and start if you think you've been defrauded Thayne, I want to thank you so much. This was informative and enjoyable and thank you for being here.

Thayne Boren:

Appreciate the time. Thanks everyone.

Steven E. Ernest:

Alright, have a great day everybody. Thank you too. Bye.