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JONES DAY TALKS®: The Biden Administration and the CFTC: Are Changes Coming?

The Commodity Futures Trading Commission, or CFTC, has broad regulatory powers to monitor the U.S. derivatives markets, which include futures, swaps, and some options.

Jones Day partner Josh Sterling, the former Director of the CFTC’s Market Participants Division, talks about how the Commission fits into the broader regulatory framework, how it monitors fintech innovations, its climate change priorities, and what market participants can expect from the Biden administration.

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A full transcript of the podcast can be found below:

Dave Dalton:

You've probably heard of the Commodities Futures Trading Commission, or CFTC, and you might know that this independent US government agency regulates the US derivatives markets, which includes futures, swaps, and certain kinds of options. But you might not know about the CFTC’s regulatory and enforcement powers and how it fits into the broader regulatory framework. Jones Day partner and former CFTC Market Participants Division Director, Josh Sterling, is here to talk about all that. He'll also discuss the CFTC agenda, including a look at how the commission is prioritizing climate change concerns, how it monitors technological innovations, and what the CFTC might expect from the new Biden administration. I'm Dave Dalton, you're listening to Jones Day Talks.

Dave Dalton:

Josh Sterling has 20 years of experience in the derivatives and securities markets, both as lead counsel to major companies, and as a Senior Federal Financial Regulator. Josh represents clients that are active in the derivatives markets with matters before the US Commodities Futures Trading Commission, CFTC, the US Securities and Exchange Commission, the SEC, and various self-regulatory organizations. Prior to joining Jones Day, Josh was director of the CFTC Market Participants Division, which regulates more than 3,300 banks, intermediaries, and asset managers registered with the agency to trade derivatives in the US markets. Hey Josh, thanks so much for being with us today.

Josh Sterling:

Thank you for having me, Dave.

Dave Dalton:

Now, you're new to the firm. You came over recently, earlier this year, from the Commodities Future Trading Commission, CFTC, which is what we're going to talk about today. And you got a prominent role there. You were Director of the Markets Participant Division of the US Commodity Futures Trading Commission. Now, how does one come to be the Director of Markets Participant division of the US Commodity Trading Future Commission? How did you end up in that role?

Josh Sterling:

Sure. Well, thanks for that. Well, I'll tell you Dave, honestly, to start it helps to have a very good friend who was appointed to chairman of the CFTC by the president, so that didn't hurt. But all kidding aside, although I did know Heath Tarbert, still do quite well, he's a dear friend. I had had, in the 10 years or so running up to getting the position, focused my law practice quite a lot on the CFTC and a lot of issues in the derivatives markets that came up during the 2008 financial crisis that turned into the financial reform we refer to as Dodd-Frank here in the United States in 2010. And all the work between 2010 and when I got appointed in the summer of 2019 to join team Tarbert, if you will, at the CFTC.

Dave Dalton:

Now let's talk about CFTC. Again, you're in a relatively rare position having been there in a prominent role, and now you're back in private practice. But give us an overview. I think anyone listening here knows what the CFTC does, broadly, but let's talk a minute briefly about how it regulates; what institutions it oversees, it's regulatory and enforcement authorities. I guess, big picture. Tell us what the CFTC is doing.

Josh Sterling:

Sure. We like to say, and it was my chairman who coined the term, the CFTC is the most important regulator you've never heard of. It's a small agency compared to, say, the Treasury Department or the SEC or something, but we have a really large mandate there, we did. The global size of the derivatives markets and the global nature of it is really staggering. If you measure it just by the notional size of some of the contracts, it's over $600 trillion. If you look at just counterparty risk, it's still in the trillions of dollars that far exceeded the GDP of most, if not all, countries.

Dave Dalton:

I was going to say, the US economy is what? A $20 trillion economy or something? I'm probably wrong on that, but it certainly isn't 600 trillion.

Josh Sterling:

No, no. And that's the notional value of the contract, which is obviously the largest way to measure it. So even if you look at risk adjusted or counterparty exposure, it's still trillions and trillions of dollars. So it is the largest financial market in the world, and amongst D20 countries anyway, probably all countries, we're the only agency that has sole and exclusive jurisdiction over the derivatives markets alone. So we had a big mandate in a small agency, but we were primed to the task. And so the way I look at it is, we regulate ... I guess I need to stop saying we, don't I? In a few ways. One, we look at the markets themselves, how is the trading going? Is the trading normal or are there market squeezes, disruptions, manipulations, and scams in the market? So that's sort of market oversight and there's a whole division for that. My friend, Dorothy Dewitt runs.

Josh Sterling:

And then you have the pipes. You do a trade in the market, it has to go and be cleared. And part of clearing is managing risk and we have clearing houses. So we had a division of Clearing and Risk, run by my good friend, Clark Hutchison. Then we have all the people in the markets doing the trades that have to have the risk transmitted and spread out through the clearing system. And those are the market participants and that was the division that I was running, and my friend, Amanda Olear, now is running as acting director. And then we have our top cops for when anybody, a clearing house, a market, or a market participant, is suspected of violating the Federal laws and regulations we had in place. And that's when the Division of Enforcement we get involved, And would do investigations and other work on that front.

Dave Dalton:

Okay. This is broader than I expected, even. I mean, when you describe the different divisions and so forth, I knew the CFTC, relatively speaking, wasn't a huge regulatory body. But I didn't know that it was that diverse and had that much going on in terms of areas of focus or emphasis. Did this evolve or is that how it was set up back when it was set up in the 70s or whenever it was?

Josh Sterling:

Yeah, absolutely. So there has been an evolution in how the agency works. I think its mandate has grown over time. And so originally, as the name suggests, “F” being futures, Commodity Futures Trading Commission, there were only regulated futures and options on futures markets. Everything else that would have been over the counter, swaps markets, if you will, were not regulated. And there were choices made even in the 1990s not to regulate that. That change was Dodd-Frank, and so I think that the size of the markets, and the number of market participants that get regulated, and even the types of markets that there are, we now have swap execution facilities. Which are just for swaps.

Josh Sterling:

And so there has been an evolution of that and we even underwent a reorganization of the agency again in November. We created a whole new division, the Division of Data, among other things. And so there's always change to keep up with the times. And I'll give you one example, in terms of priorities for the agency, we have an office there called LabCFTC, which is set up to help foster responsible innovation in financial markets and areas including financial technology, cryptocurrency, and blockchain and so forth. So trying to be a very quick to respond regulator and move with innovations in the market.

Dave Dalton:

We are going to talk more about that later. I'm always stunned at how quickly regulators can respond, sometimes, with new developments or innovative products or new services and so forth. It's a wonder, because the private sector can move along pretty quickly, but I've noticed a lot of government agencies do a pretty good job of keeping up. It's a fascinating area, period, I think. The securities and derivatives markets and an equally fascinating part of the law. What got you here?

Josh Sterling:

Yeah, no, great question. It's funny, I was an English and Philosophy major in college, but I'd always known I wanted to be a lawyer. My grandfather was the Chief Bail Officer of the city court system. And then as a kid, I watched LA Law and those people just seem to have a lot of fun. I'm not joking. Like, really, that was it.

So beyond that, I'd always had an interest in the law and because of those experiences with my grandfather. And as I got into practicing law, it was really by happy accident. One of the first projects ever I did as a summer associate was trying to write rules and bylaws for, trying to remember, an online platform, and this was the year 2000, for trading electricity bandwidth contracts. And so this wasn't a memo on discovery or an indenture or an M&A document. And I said, "Well, what is this? What are these financial markets?" And took a seminar on derivatives in law school and always found it interesting. So I tended towards the financial markets from the get go. Had some happy accidents along the way of knowing I want to be a lawyer.

Dave Dalton:

It's become extraordinarily involved, I think, since you said you got your feet wet in all this back in 2000, either still in law school or right out. And we look at how the global financial and derivatives markets have expanded since then, it truly is a global marketplace. And now you've got online trading to a degree you couldn't have imagined back in 2000. Just, this has exploded right in front of you, really.

Josh Sterling:

Yeah, no, absolutely. The velocity of change has really picked up. The availability of information and data that can be used as a source of trading. And then the information that trading itself generates, it's almost like a virtuous circle and it just leads to more evolution and growth and, I think, depth and health in the derivatives markets. And so I think that if you're a fan of markets, at least in my case, you're naturally drawn to try to understand how they're regulated, and then find ways to be helpful to clients that are in those markets. Whether it's enforcement actions, let's hope not, helping them with regulatory change and advocacy, or helping them structure transactions. So I think there's just a lot to do to be helpful.

Dave Dalton:

It certainly seems so. Well, since you brought it up, let's talk about regulators. There's an extensive, to say the least, regulatory framework. Both here in the United States and globally. And different organizations monitor activities in the financial institutions, where does the CFTC fit in that arrangement? Where does it play? How does it work with the other regulators and enforcement agencies?

Josh Sterling:

Yeah, absolutely. Domestically, the CFTC has a seat at the big table. That's the FSOC, the Financial Stability Oversight Council, that is a group headed by Treasury Secretary in which all the Federal Financial Regulators participate. And they share ideas, they publish an annual report, and it's meant to be there to keep an overall top down as well as bottom of view of what's happening in different pockets of the market. So we participate like that with the other regulators in the United States. And then there are events that require us to work together, like we saw in the money markets last Spring, we had to be in dialogue with the treasury department, and occasionally the Fed on things in the money markets. And then there are times when Congress tells you that you got to collaborate. So we collaborated very closely with the SEC in some rulemaking initiatives and in responding to some aspects of the crisis in the markets back then.

Josh Sterling:

Internationally, I think the CFTC's opposite, International Affairs, does an excellent job keeping the agency involved as an advocate for the US and the US's own regulation of its own markets. Other regulators around the world, particularly in Europe, take an interest in our markets because they're so big and so well-functioning. Which I think is an outgrowth of a healthy society. And they take an interest in those activities, they want to understand them, sometimes I want to try and regulate them. So we participate in forums like IOSCO, which is the international organization for similar regulators around the world to participate in, to harmonize global standards. And the FSP as well. And so we participate as an agency actively in those international dialogues. And then finally, the CFTC has information sharing agreements, or memorandum of understanding, with regulators around the world to make sure that we can share information with them on a fair and transparent basis for things within our respective ambits.

Dave Dalton:

Now you swerved into my next question, because we do a lot of these podcasts and we talk to people in the cyber security practice, and investigations and white collar defense practice and so forth. And there seems to be this trend of collaboration, both in terms of intra-government stuff here in the United States, the federal and state levels. As well as cross border. I think if there's a theme that revolves around these sorts of conversations, I think there's a lot more collaboration and cooperation than there probably was even 10 or 15 years ago. Would you say that's true with the CFTC? Is there a lot of sharing of information in terms of an investigation or audit kind of things? Does that go on?

Josh Sterling:

Oh, absolutely, you're right. It definitely has picked up. There is valuing in collaboration, particularly when the goal is to get the right result. In some cases, especially so, right perceived wrongs. And by that I mean enforcement. So the CFTC has robust enforcement powers in the markets. You don't have to be registered with the CFTC to be subject to an enforcement action by the CFTC, all you need to do is trade in the markets. And so the exchanges that are registered with and regulated by the CFTC have their own enforcement powers. They will refer or involve the CFTC, if it's violations of federal law and misconduct in their markets. And then there can be criminal violations of the federal commodity futures trading laws as well. And so there's often collaboration with the Department of Justice. In fact, there was a task force, or working group, for commodities fraud. It involved DOJ and the CFTC working closely together.

Josh Sterling:

And we have many folks here, as you know, Dave, from the DOJ who have experience or knowledge of how those parallel proceedings work. I would even say, this is particularly relevant these days, the commodities laws give state attorneys general the ability to bring actions, including in concert with the CFTC. And just last year, former director Jamie McDonald, a very, very good friend of mine and colleague, did bring, through the agency, an enforcement action with, I believe, 30 other state AGs. So that was pretty momentous for the agency. What I would say is that enforcement really permeates a lot of what federal agencies do, particularly at the CFTC. I personally reviewed every action that was going to be recommended to the commission, to take enforcement against a company that was registered the CFTC, and I had 3,310 firms registered with the CFTC that were within my ambit.

Josh Sterling:

So if we had an action contemplated by enforcement against one of those 3,300 firms, I saw the charging documents and I would comment on or offer views on that. When we went out and did our exams, or learned of exam results, and we had evidence of potential violation of the law, or a regulated entity made a report to us indicating that the laws had not been followed, we would report it. Because we can't fix the mistake or the breaking of the law. We can work with a firm that wants to remediate it, but if you violate the law, there's a consequence. And so, we contributed highest ever percentage in my tenure of cases to the enforcement docket. As to before, and indeed I implemented the first ever formal enforcement referral program, between what we call Policymaking Division and the Division of Enforcement in the agency. That led to some significant results against farms.

Dave Dalton:

Interesting. Interesting. You mentioned state attorneys general a minute ago and it all comes together around here. This little bit of inside baseball for the people listening, but Jones Day just launched a state attorneys general practice. We're actually doing a standalone video on financial markets and what state attorneys general are looking at. I guess this would cover banks, insurance companies, brokerages, and so forth. And certainly anybody involved in derivatives. So it's interesting you brought that up, I just didn't know there were that active, that involved, and had that kind of authority at the state level. But they clearly do, right?

Josh Sterling:

They definitely do. The volume in seriousness of enforcement actions, particularly against financial services companies, will only pick up in this new administration. I don't really think it waned so much prior four years, but I think in the next four to eight years it will only grow.

Dave Dalton:

Sure. You mentioned the new administration. I know we're only a couple months in, but what do you see happening here? Do you see big changes from the prior four years or is it going to stay the course? Or what do you anticipate?

Josh Sterling:

Absolutely, Dave, there will be some marked changes in priorities, which is natural and completely the prerogative of any new administration and a new president. Obviously CFTC is part of the executive, although it's an independent agency, the president makes appointments and can absolutely set the tone and expectations. In that regard, when we do have a new chair appointed, and I've been looking religiously for that to happen, at least as at the time of this recording had not happened, priorities will obviously be around enforcement, which we've talked about, continued strong enforcement of the laws on the books. I think there'll also be a significant emphasis on climate risk and the things like the Green New Deal. I think that's true, generally, one. I think, two, it's certainly true, early days looking at what the SEC is doing with their chairman, Mr. Gensler, a former CFTC chair. And then I say it for a third reason, which is that in last September, an advisory committee of the CFTC, one made up of market participants, put out, sponsored by the CFTC, a report on managing climate risk in the financial system.

Josh Sterling:

And I believe that was the first White Paper a federal agency had done on climate risk in the financial system. And it is a roadmap, not just for the CFTC, but for all financial regulators to take a look at lending activities, financing activities, derivatives market activities. And the way that they have to respond to and address, not only weather events, but also changes in the legal and regulatory landscape that I think we're going to drive changes in, frankly, the sources of energy for our real economy. So I think the CFTC will have a seat at the table because it essentially, although it was an advisory committee, asked for one by issuing that report. So I would expect that to be top of mind for the regulators, not only in rulemaking, but also enforcement.

Dave Dalton:

Interesting. And again, everything comes back together here. And I think, correct, CFTC was, if not first, right there. Because I remember we did a publication, a White Paper or a commentary or something, when that happened. And it was certainly innovative at the time. But we've talked since about the New York Department of Financial Services, I've talked with Jay Tambe about what the SEC is doing. So many of these regulatory and enforcement agencies are taking climate change so seriously in terms of risk management and so forth, if nothing else. If you'll forgive my informality, this isn't feel good, tree-hugging stuff. They're worried about the underlying risk in the portfolios, in the policies you're underwriting, in the loans you're making, so forth. The rubber hits the road in this stuff. These are real issues and they're affecting potentially a balance sheet, right?

Josh Sterling:

Yes, absolutely. There will be efforts, not only to have firms look at their own activities, but in a really meaningful way, assess real costs to them of continuing to support the activities of others that are believed to contribute to climate change. So there's always talk in this arena about stranded assets, which would mean coal oil, gas, stuff left in the ground if you will. And what is the right risk haircut to apply on a loan portfolio that is skewed towards, or includes, loans to those kinds of extractive companies? That's just one example. We could say the same thing for the derivatives book, where you lay off that lending risk. How do you respond to potentials for losses associated with extreme climate events, like more severe hurricanes and the like?

Josh Sterling:

And so I think there's going to be a real effort to assign values and costs, in enforcement context, penalties to addressing climate change or failing to do it. That will very much pick up, and of course, as I'm sure Jay talked about in his podcast episode, you already have the SEC forming an enforcement task force on climate risk disclosure, among other things. And so this is not going away. You have Mark Carney, the former head of the Bank of England, now being a UN special designee, I don't have the terminology quite right, for climate. And they're looking at creating a voluntary carbon market. So you will have a price on carbon or a carbon tax, that seems to be a next step, and the rural landscape for financial services will play out around that.

Dave Dalton:

There's no avoiding this. Well, we just recorded a podcast last week, I think, on the European Central Bank and what they're doing in terms of their loan portfolio. And they're investing in green bonds and they're taking other measures. So this is a very real thing, and thankfully, the firm has people on top of this and people like you that are sensitive to it. I don't know, I don't pretend to have my ear to the ground for everything, but this came up kind of fast for me. I was barely aware of what ESG was a year and a half ago. And here we are, this is big stuff all of a sudden.

Josh Sterling:

Absolutely. Yeah, David, and Europe has a new disclosure regime around green investments to address things like greenwashing, where you say you're virtuous in investing in green things and you're really not. So I think there will be a penalty or an enforcement component to this even more so as we go along. And what I do like about the firm is that we have the capability in the major money center jurisdictions to deal with these issues, not only from a regulatory perspective and a regulatory advocacy perspective, but also in doing the actual work of the transactions people are using to respond to these incentives. Lending, finance, acquisitions, what have you. But we also have the capacity with our Issues & Appeals Practice, and others, where it's appropriate and make sense within the law to voice challenges in court. Because that's an important thing to do for clients where the circumstances call for.

Dave Dalton:

Let's switch gears for a second or maybe rewind a little bit. Earlier in this conversation, you mentioned cryptocurrencies, blockchain and so forth. Financial technology and innovation is moving forward very quickly, what does an agency like the CFTC do in terms of approaching issues like that? Where are they right now?

Josh Sterling:

They're pretty close to the bleeding edge. And I think that was a deliberate choice and I credit former chairman Chris Giancarlo for being a thought leader on that. And he continues to be that with his work on the Digital Dollar Project and other things. Under his leadership, the LabCFTC was created, and it really is an open space for innovators to come in and talk about ideas they have. Not everything is a derivative, but a lot of things like crypto tokens are commodities, and so you can write a derivative on it we regulate it. But why it matters, I think, even when we have applications of FinTech, they're more banking focused or non derivative focused, was put really well by another regulator to us. It was the former acting Comptroller of the Currency, Brian Brooks. He came and spoke with the leadership team at the CFTC. Great, great person, obviously. Real thought leader. He had been at Coinbase beforehand. And he basically said, crypto is having a role as a currency, a unit of account, historic value, things like that.

Josh Sterling:

It will really require it to become less volatile than it is. And one way you can control for volatility in an asset is to have a deep, liquid regulated set of derivatives markets. And so even if you have coin or currency, a blockchain technology that is not itself expressly involved in derivatives markets, you could probably write a derivative on it. And if we have markets that can smooth out or at least channel the volatility of the price action into a market that's two-sided, that will be massively helpful to the uptake of crypto for broader applications. I think that's a main monetary, if you will, reason for the CFTC to be focused on it, to help the US continue to lead in financial innovation. And also just to keep abreast of things that are going on that will affect the way trades are booked and cleared in custody. You can do a lot of that on the blockchain, we're not there yet, but a lot of minds at the agency are focused on that.

Dave Dalton:

Sure, sure. It's an interesting time for things like this and the firm has been very involved in blockchain technology. For the last several years, a bunch of our lawyers got together, did a book, we did a series of videos and podcasts and so forth. And the other theme that kept coming through there was, it's a balancing act. It's a tight rope. You don't want to stifle innovation, but you also have to regulate enough so that the bad actors are fleshed out and the consumers aren't hurt. And that's always the case, right? But in a new technology, in something so new, when maybe even the people who are living this, eating and sleeping this, they don't know what all the risks are, sometimes. It's a fascinating time, I think, to be involved in this financial product, isn't it?

Josh Sterling:

It really is. From an enforcement point you make an excellent observation because I do think ... It's an old adage. It's tired, I'm sorry, bad facts make bad law. And unfortunately, certainly the CFTC has run into some bad facts, but there's got to be a more foot forward way to do it. And I think that's what LabCFTC is all about. Just like the Innovation Office at the SEC, I would say. And yeah, it is an exciting time. I think that, just like 20 years ago we were using flip phones and still had dial up, I wonder what paying for things looks like 20 years from now. Where knowing where all your assets are will look like 20 years from now. It'll look remarkably different. And I think, given the way things go, it'll look better and it'll be better for the customer.

Dave Dalton:

Absolutely, absolutely. We're getting close to out of time, Josh, but I want to finish up with a couple of things. We talk about technological innovation, which was a blockchain so forth, but tech can help with enforcement and rulemaking too. Is the CFTC using technology or data driven programs to meet its enforcement regulatory objectives? And how's that playing out?

Josh Sterling:

Yes, absolutely. Data are a huge part of the CFTC programs and a few salient points on that. One is, in the reorganization we created a new division of data to get a handle on the volume of data that comes through the CFTC and handle it in a more coordinated fashion. For a variety of programs, rulemaking, guidance, and I also believe in enforcement. The enforcement division of the CFTC has market surveillance within it. So when they look into markets, they look to brand cases based on the data we see. In my own division, the first thing I did when I showed up, and I had two full-time equivalents I could hire, I hired two quants, great guys.

Josh Sterling:

And I said that I ought to be able to look at a dynamic, real time, day plus one map of open positions between major asset managers, major consumers of commodities on the one side, and their brokers or their dealers on the other side of the market. I think it ought to color coded and I think I ought to be able to run time sequences so if I see something I can pick up the phone and call the bank. We made that and we called it Real Time Access to Pool Trading Results, R-A-P-T-R, RAPTR. Obviously had an enforcement, or at least investigation of these [inaudible 00:28:14], and we were able to do that. They cut through it, and within less than a year, we had that day plus one view of what's going on in the market.

Josh Sterling:

Which I think just makes us a better consumer of data and a better user of tax dollars and better able to have intelligent conversations in real time with regulators. I had remarked that if we had that data tool last March and last April, I would have known with a great degree of certainty more about what was going on in oil trading, when the price of oil went negative. Meaning if you had oil, you had to show up and give someone money to take it from you. That's odd. We would have known a lot more, at least within my division, of what that meant for the brokers that were doing those trades. If we had that tool, and now we do, so heaven help us if we ever need it again. But it's there. It's not only the prevalence of data, but it's the ability to manipulate it.

Josh Sterling:

I guess I'll leave this area with one thought. There was actually a case against a major bank, it was very data intensive, and this was all reported in the papers. The commission put a pause on the case because they didn't have the tools to analyze the data properly to bring the case, but they knew there was something there. They paused, they put the money in, built the data tool, extracted the information they needed to support the theory of the case. And they took it to a successful resolution for, what I think, was close to a record high penalty against that institution. So data and the use of data by regulators is definitely hitting people's pocketbooks.

Dave Dalton:

No doubt, no doubt. And you've proven there, with that example, it can be effective, that's for certain. That's for certain. Hey Josh, this has been great. Thanks for your time today. We're talking again soon and I think that conversation will focus on enforcement actions, which we got into a little bit today, but specifically how the U.S. Department of Justice and the CFTC coordinate and work together. Again, that's a very client focused topic with a lot of interests, so I'm looking forward to that discussion. Welcome again to Jones Day, though Josh, but anything else you want to sign off with or let the audience know?

Josh Sterling:

Well, Dave, thank you so much for setting this up. I look forward to continuing these conversations. I think the next time we speak, we'll be hearing more from another partner who has a recent DOJ vantage and background and we'll talk about parallel proceedings and so forth. I think the ability to talk to clients about that, and to help them plan for responding to actions that could go parallel, go criminal if you will, is very important and we want to be part of the solution if those things happen to our clients. But thank you very much.

Dave Dalton:

Look forward to those discussions, Josh, and we'll talk again soon. Thanks again for being here today.

Josh Sterling:

All right, thank you.

Dave Dalton:

You can find a complete biography with contact information for Josh at jonesday.com. While you're there, be sure to visit the Financial Markets practice page, and also our insights page, where you'll find podcasts, White Papers, newsletters, commentaries, videos, blogs, and other informative content. Subscribe to Jones Day Talks on Apple Podcast and other podcast platforms. As always, we thank you for listening. I'm Dave Dalton, we'll talk to you next time.

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