KeyCorp (KEY) Earnings Call Transcript & Summary

Good afternoon. I think we'll move forward. Our next up today is KeyCorp, KEY assets at the end of the third quarter, $188 billion market cap, $9.6 billion and on the way higher today as I speak. Key operates a relationship-focused consumer model with 984 branches in 15 states as well as a national digital bank. The commercial business model is unique relative to peers in terms of having a differentiated and comprehensive platform with expertise in several targeted verticals. Earnings last quarter, $0.29 beat expectations. And the one data point that stood out to me was a 50-basis-point increase in CET1 capital to 9.8%. And with us today, we have 3 individuals on my left, Clark Khayat, Clark serves as CFO. Prior to this role, Clark was EVP and Chief Strategy Officer for Key, responsible for corporate strategy, M&A and strategic investments. Angela Mago has been with Key for 35 years and today is the President of Key Commercial Bank and Real Estate Capital. In her current role, Angela is responsible for directing strategic growth and business development activities across the footprint for middle market clients. And then Randy Paine the podium, who is President of Key Institutional Bank, which includes KeyCorp capital markets, Key's institutional and health care real estate platform and Key equipment finance. Randy joined Key back in 1993. We'll start with a presentation and then move into Q&A.

Thank you very much, Terry, and you covered the first slide of mine. So nice work. Very well done. And I want to thank the Board for putting on this conference. It's great to be here and be with you all telling the Key story. Slide 2, you have our statement on forward-looking disclosures. These statements cover our presentation materials and comments as well as the question-and-answer segment of our presentation. Our integrated corporate and investment bank has a comprehensive set of products and capabilities delivered through a relationship model. The power of our platform is -- and the unique combination of a broad set of scaled capabilities along with our team's deep industry expertise that enables us to be a top-tier financial partner for a targeted client set. Specifically, the middle market companies across our 7 industry verticals, you see them on the right side on the bottom of the slide. Importantly, we are truly differentiated in our industry vertical approach. Our deep expertise in these industries enables us to serve our clients using Key's capital or by accessing the capital markets. We also have a meaningful M&A advisory platform, which operates in the C-suite and boardrooms of our clients and drives differentiated relationships and solutions. A great example of this took place just earlier this week when Physicians Realty Trust and Healthpeak Properties announced a $21 billion merger of equals. In addition to serving as a lead financial adviser to Physicians Realty, Key currently serves as lead arranger and admin agent on Physicians $1.4 billion of credit facilities. And since 2013, we've served as an active book runner on Physicians 9 equity offerings and a co-manager on 2 investment-grade bond offerings. We also currently act as the lead sales agent on Physicians' $500 million ATM program. Furthermore, Key also serves as a participant Healthpeak's $3 billion senior unsecured revolving credit facility, and we served as a co-manager on 18 capital markets transactions for Healthpeak since 2018. That's 35 transactions since 2018 for both of these companies. We're also a joint lead arranger to the $500 million Newco loan that was put in place in conjunction with this transaction that will close in connection with the announced merger. In short, there are very few competitors who have as robust a capability set as we have, but they can also collaborate closely enough to deliver it seamlessly for customers. We feel our size is a competitive advantage as most of our competitors are much larger than Key or they cover the middle market as an afterthought. We are big enough to have a developed and proven full solution set as well as focused and nimble enough to seamlessly deliver it to targeted middle market clients. These are very powerful attributes and very difficult to replicate. We continue to benefit from our focus on relationships and primacy, which means Key provides our clients' primary operating income. This has been a strategic focus of ours for a number of years and is evidenced by the tenure of our average commercial client relationships of 15 years. Since 2019, we have increased our average commercial deposits by over 50%, while concurrently increasing our percentage of commercial deposits from operating accounts to 84% as we continue to add and deepen relationships. Our focus on primacy adds to the quality and diversity of our deposit base. In fact, over 90% of our commercial deposits come from primacy accounts. Key's execution of our primacy strategies go well back before 2019, and it has served us very well over the last few quarters. As you can see, our deposit balances have been quite stable despite the volatile environment that we've been in. One of the underpinnings of our strong balance sheet is the quality of our loan portfolio. Our commercial book is mostly made up of [ C&I ] loans of which 55% are rated as investment grade or investment-grade equivalent. Later in the presentation, Angela will go into more detail on how we have strategically positioned our commercial real estate portfolio and why we feel confident about how that portfolio will perform whatever the cycle is. Although we're not focused on growing loans this year, we have continued to support our relationship clients. As Chris Gorman discussed on the last call, we are on target to reduce our risk-weighted assets by $10 billion this year, but we have been very thoughtful in our balance sheet optimization efforts, deemphasizing businesses that does not meet our targeted level of returns, reducing unfunded commitments and of course, reducing loans to credit-only relationships or relationships where we have not accomplished our objectives in terms of that strategy. We have built a business to be able to serve clients through all market conditions with on- and off-balance sheet solutions and this differentiated capability also allows us to distribute risk through our broad set of capital markets capabilities. In 2022, we raised a record amount of capital for our clients and held 23% of that capital on our balance sheet. This year, we expect the percentage of capital held on our balance sheet to return to levels that we've seen typically in the past, as you see here on this slide, roughly 19% year-to-date. Distributing capital off balance sheet provides Key with a valuable fee revenue stream while also taking no tail risk. Turning to my last slide. The strength and durability of our investment bank is driven by our relationship-based strategy and targeted industry vertical focus. 80% of our commercial bank credit exposure is from relationship clients and 60% of our investment banking transactions over the last 3 years were with repeat clients. These relationships are much more meaningful than just the investment banking fees. As a strategic adviser to a CEO, we are in a great position to pull through significant ancillary business that's reoccurring in nature and is very sticky. As discussed earlier, our relationship with Physicians Realty is a very good example of that. We have built this business to be able to serve our clients through any operating environment and provide on- and off-balance sheet financing solutions tailored to our clients' strategic priorities and needs. We partner with our clients to help them build their business over the long term. This is not a market-based trading business. This is a relationship-based solutions business. Importantly, we've been focused on diversifying our capital markets product set. So in one area in the capital markets is not as active or less optimal, we can provide clients with alternative solutions. You see this in the pie chart at the bottom of Page 6, which show the relative breakdown of our investment banking fees in 2018, which was a much different market environment that we're in right now versus our year-to-date results. For Key, this has resulted in a durable investment banking fee product and fee set over the years. And despite the challenging environment this year, we continue to feel very confident about how this business is positioned to perform and continue to grow for Key in the future. With that, I'll turn it over to Angela to give more details on our commercial real estate business.

Okay. Well, good afternoon, everybody. Thanks, Randy. Let's make sure we are on the right slide. Yes. I might need some help advancing the slide. A very large area of focus this year has been commercial real estate. We have thoughtfully positioned the composition of our commercial real estate portfolio over the last decade to outperform to the business cycle. Our commercial real estate portfolio has sound credit profile with strong, long-standing profitable relationships. The sector that makes up the majority of our commercial real estate portfolio is multifamily, of which 40% comes from affordable housing. Our clients are well-capitalized real estate owners and operators with scale. Our project loans are generally recourse, low leverage obligations with clean capital stacks. And we maintain a modest amount of construction, the majority of which is an affordable housing. Key's balance sheet positioning driven by our targeted relationship-driven model comprised of activity from our income property group, our affordable housing group and our institutional real estate client base. Our commercial mortgage group generates off-balance sheet financing solutions, helping to generate fee income, servicing income and recycling balance sheet capital. And in a period of rising rates, it also helps us manage risk. And our third-party commercial loan servicing business generates fee income and escrow deposits were Key. And we benefit from insights gained from our third-party servicing portfolio because we service over $600 billion in assets. And this makes us the third largest servicer in the space. Advancing to the next slide, a sector that's been under significant stress this year as evidenced by a tenfold increase in our third-party active special servicing is the office sector. It's important to note that Key has limited on-balance sheet exposure to office among the lowest of our regional peers. And we have limited exposure to B and C class office in central business districts, which is the most challenged part of the sector currently. So I'm now on Slide 8. A relative to Key's position before the crisis, we have derisked our balance sheet and we've exited sectors that have significantly underperformed, focusing on a diverse set of targeted industry verticals. Our loan book is over 70% larger from that period of time from the great financial crisis, but we've repositioned the business to be focused on relationships, high-quality clients and lower risk mix of our business. While commercial real estate continues to remain a focus for Key, we have a much lower concentration in construction loans as we are not doing business with merchant builders and homebuilders as in the past. And as I stated earlier, we have limited exposure to higher-risk areas like office. In multifamily, which is our largest sector, our actual portfolio NOIs continue to grow compared to our underwritten NOI. And importantly, modest leverage financial capacity and recourse held by sponsors across our project loan portfolio represents a significant risk mitigant as asset values adjust over time, and we operate in an environment with higher for longer interest rates. So said simply, our clients have equity to protect and that's a very good thing for Key. We're also delivering more client solutions than ever before, but we're doing it with targeted clients who are well capitalized and modestly leveraged. In fact, approximately 55% of our C&I loan commitments are to investment-grade companies and leveraged loans make up 2% of our total loans. Importantly, nearly 40% to 50% of the Commercial Bank's revenue is from fee income, which amplifies our returns with little to no tail risk in the form of credit outlays. And this is all to illustrate that we've meaningfully derisked our loan portfolio, which we expect to benefit from through the cycle. If we can turn to Slide 9. One of our targeted sub verticals where we have deep industry expertise in affordable housing. We are the #4 affordable housing lender in the country. We remain very bullish on this sector, as it continues to be a substantial area of importance for our communities, and there's a significant unmet need. According to the National Low Income Housing Coalition in its 2023 annual report. There's about a 7.3 million home shortage for the lowest income renters in the country, which means there are only 33 available homes for every 100 extremely low renters. So this massive shortage of affordable housing will require continued investments in new supply, refurbishment and preservation of existing supply and expansion of government subsidies like the low-income housing tax credit. Our clients use the low-income housing tax credits to do those things, develop, rehab and preserve their facilities. And Key competes very effectively as a one-stop shop because we offer a myriad of debt solutions, we provide both equity as an investor and as an equity syndicator raised from other banks principally, mortgage banking solutions, and we underwrite tax-exempt bonds that are inherent in many of these structures. And finally, we offered deposits and payments capabilities relevant to this space, and those are integrated into our go-to-market strategy here. So we think the affordable sector is a great space in which to be a market leader, and the benefits just to save them one more time attractive risk-adjusted returns, multiple avenues for fee income generation, tax benefits, a strong growing need with well above breakeven debt service coverage ratios, significant levels of reserves and extremely low credit loss history. We get community reinvestment act support and, of course, support to our community benefits plans. There is strong bipartisan support. That's one thing our government can agree upon and mandates by the GSEs to support this sector. And finally, there are barriers to entry for new players, given the complexity of the capital structures and the expertise required to compete effectively at scale. So given these benefits, we feel this is the right sector within commercial real estate to be positioned for growth. And that concludes our prepared remarks, and I'm going to turn it back to Terry to lead us through the Q&A.

Thank you, Angela. Thank you, Randy. I'll start with some questions on both -- first off, how would you assess the health of your commercial clients? Are they incrementally more positive, negative? Or -- and then what are the largest concerns today?

So I would say, generally speaking, clients -- our clients feel good about their business. I think their biggest concerns continue to be labor, inflation and, of course, the volatility in the interest rates and kind of resetting to a higher-for-longer expectation. But again, generally speaking, I would say they feel comfortable with their own businesses. I think they feel strongly they position their balance sheets well. But certainly, there's been a little bit more uncertainty relative to the -- some of the macro challenges today.

The only thing I would add is that the last month as you've seen sentiment change a little bit. Obviously, with the breakout of the war in the Middle East and the potential consequences around that risk and a significant move in the belly and the longer end of the interest rate curve sentiment has certainly dampened a bit there. Maybe gets a little bit better today, but we would like to certainly see that geopolitical situation stop as soon as possible and then certainly not expand. But that's been a bit of a headwind. But it's interesting, this economy, as we all know, is different than anything that any of us have experienced in our careers. And for the most part, our clients are saying, our business is great, but we really don't understand what's going on around us. And so that's good. And we certainly see that in terms of our credit book because it's in great shape. So that's obviously a very important factor as well.

We're hearing different views on the pace of recovery in capital markets. What are you seeing? And do you expect your Capital Markets business to return to a more normal level next year?

Yes. So we do expect the environment to get better, but it's a pretty low bar, right? The first half of 2023, if you look across capital markets, it was operating at kind of issuance and activity levels associated with the great financial crisis with the tech bubble and certainly the deep recession that came on the heels of that. And we're in a very different environment than that. You've got very strong growth here recently, I don't expect it to continue at that rate. But you're going to have to see debt get refinanced. You're going to -- there's a lot of capital out there in the private equity community. And so we do see things getting better off of the trough in the first half of this year. I don't think it's going to be a hockey stick, but we do expect next year to be better than this year.

And then other than investment banking, what will drive fee-based revenues within the commercial business?

So we've been very focused on primacy as Randy said. So we've got significant opportunities on the payment side. I think our wealth business is another area where we've had a terrific intersection across all of our businesses with wealth. So we see there's being a lot more upside. It's really kind of an extension of primacy in a lot of ways as we get close to the owners of the business and help them with planning and ultimately, execution through a liquidity event, which we're able to support them in many ways. I talked about our loan servicing business and special servicing is an area where, as loans go into default, it's a nice countercyclical revenue stream because we get paid to work out those loans. So we're seeing those fees start to ramp. So that's been obviously good activity for us. And within our affordable business, we've been ramping up our community development lending equity platform where, as I mentioned, we raised capital from other banks. And that business, we started late a couple of years ago, about 18 months ago, and it's ramping and building. So that's another source of fee generation that will continue to grow for Key.

Yes. The only thing I would add is you've heard Ken Gavrity talk about embedded banking in our commercial payments area. We continue to be excited about opportunities there where we can take our payment solutions, embed those into software and other tools that are very sticky for us, provide a great client experience and our technology vertical within KeyBanc Capital Markets is where a lot of those customers sit. So in terms of building that sticky reoccurring relationship, we're excited about that opportunity.

And Angela, outside of office in our special servicing business. Any other observations or comments you'd like to make?

Office is probably the sector that's reared its head dramatically, right? We -- as I mentioned, we service off balance sheet about $600 billion in loans, and we are special service around about $200 billion. So special servicing has grown. A year ago, it was about $2 billion. Today, it's about $6 billion. So it's gone up threefold, but office is 70% of that number. So it's over $4 billion, and that's grown tenfold. So that's clearly the area that's under the most stress. I would say retail has improved. Multifamily has been relatively consistent in terms of the percentage of assets that we're seeing and largely dealing with kind of mismanagement poor sponsorship and then interest rates and maybe a little bit of overleverage. So that's -- but clearly, office is the story, I would say, in special servicing.

And what gives you the confidence that as you shrink the balance sheet, shrink risk-weighted assets, you're not harming your franchise and how has that impacted your ability to service your clients?

Yes. Great question. So as I hopefully you all know, we've taken down risk-weighted assets by $9 billion this year, $7 billion in the third quarter. It's important to understand, though, that half of that $7 billion came through just a change in methodology associated with some assets that were already on our books that we're now getting much lower RWA treatment on those assets. So the assets are still here. They're very high quality. They're even better returning now with the new risk-weighted asset treatment. But no impact to certainly the client experience, our relationship or our P&L. The rest of the reduction has come through, as I said earlier, really through natural attrition in our book. Our book is short. So it's constantly churning. And we're making decisions to exit businesses that have excellent relationships that aren't truly relationships. I mean, we're all in relationships and they go both ways. And if they don't go both ways, then they're not in relationship. And so we need to have multifaceted aspects to -- around the -- those relationships, are not just credit-only relationships. And so as we've gone through this process, Angela and I, we look at every significant transaction that Key does in our commercial businesses. And we're not just spreading this like candy across every part of the business. We're being very targeted in areas that no longer fit our relationship strategy in this new environment. But areas that continue to be key to us and core like affordable housing, like renewable energy. Certainly, the areas that we cover from an industry standpoint, we're taking depth hand to those decisions and being very, very thoughtful about how we execute on not only supporting our clients and our important relationships, but also preserving the very good reputation that we have that, like I said earlier, it's going to be there to support our customers through any market environment.

The only thing I would add is as I talked a little bit about our integrated real estate business, and we've got a commercial mortgage banking platform linked to the banking platform. We've been actively recycling capital as the yield curve was inverted earlier in the year, we had a great opportunity to work with our customers to refinance early, right? And to put them in a better position and also to naturally help us recycle capital. So it's worked out nicely actually.

Have you been tightening lending standards and what's your near-term outlook for overall asset quality trends?

I would say we've always been disciplined. So I think from that perspective, I mean, we certainly, when it comes to new business, as we've managed our capital committee, we've set higher expectations relative to returns and again, fulsome relationships. But I think in terms of risk management, I think we've always been good risk managers. And our outlook is good. I mean our NPLs have been very stable. We're certainly seeing more elevated crit class in this environment, as you would expect, as we work through the cycle and it kind of rolls through different sectors. But I think we feel very bullish about our credit quality.

Maybe one last question before I open up to the audience. Clark, any comments on the outlook for the fourth quarter or for 2024 that you'd like to add?

I was getting comfortable sitting...

I was going to get...

No other -- I mean, really just confirming guidance that we gave in the call a few weeks back. And then we'll update 2024 as is kind of a regular process on the Q4 call. The only guidance we've given so far, the '24 is just flat, stable expenses from core '23 to '24.

Any questions?

Erika Najarian UBS. I have a question and a related follow-up. So I want to reask the question the I ask on your conference call. So it's pretty clear to a lot of investors with the NII tailwind looks like for 2024. And I think the big debate about the stock continues to be your adjusted regulatory capital ratios. And on one hand, it makes your PE super vulnerable to moves in interest rates. Like you're seeing today, it's a good day for in KeyCorp, in other days when the 10-year was selling off was a bad day for KeyCorp. So as you think about that vagary and as you think about 2024, how do you balance more RWA mitigation that may not impact clients, but clearly, with credit-linked notes could impact NII and sort of getting to the capital solution a little bit more quickly, the capital build more quickly versus protecting that NII trajectory. Like walk us through sort of the tension in terms of that decision as you think about '24.

Yes. So let me maybe start earlier in '23, which is I think when we hit March, April, it was all about liquidity, all about capital and kind of earnings will be earnings because you got to show those two things up. I think as we've gone through the year, we've demonstrated a lot of stability in deposits. I think as we've called debt, bought back debt, paid down FHLB advances. I think that liquidity position feels very good. I think our CET1 under the current rules, to be fair, feels very good, given the 50 basis points that we grew in the quarter. And so we've gone back to instead of sort of over prioritizing those at the expense of earnings, trying to balance the trio. And you'll see us do -- we call debt, not just because the liquidity felt strong but because that pulls some NII back in, we'll continue to do that. So under any current guidance under the NPR. And I know that's not exactly the question you asked, we feel very confident we'll be a very strong adjusted levels going through the phase-in period. The question around marked capital today is a different question, and I know investors are looking at it. It's not something we're trying to solve in the moment because it's not necessarily the rule in the moment. We're very mindful of it, and we'll take steps to insulate AOCI impact. So we talked about payers that we put on. We talked about terminating the swaps. We're trying to do what we can in the relative near term to insulate the moves really the 5-year part of the curve is really the most sensitive. So we're trying to take advantage of places where we can. But as every quarter moves forward, AOCI comes down, those start to -- those market capital ratios start to look good. So time is our friend. If there are huge spikes in the rate curve, then we'll assess those at that time. But given where we think we are and where we're headed, I think we're doing the right things to balance all those pieces.

And just a quick follow-up question, and this might be a stupid question. Could you help us think about, is there any incremental capital impact once you're the commercial real estate assets that you're servicing go from regular servicing to special servicing?

No, that's off balance sheet, all fee-based.

Clark. I guess you know the game show, Jeopardy!

Yes, I do.

So the answer is the Board has no intention of cutting this. Do you have the answer?

I know exactly what you want the answer to be, but let me just put some context around it...

Okay. So the real question is, if you're not -- you made it clear, the Board doesn't feel a need to cut the dividend right now. So because it doesn't reflect your current earnings don't reflect your earnings power. So can you give us a -- just a step up from where you're earning now to why you think you can kind of grow into your dividend?

Yes. So look, I won't -- without giving guidance, I'll just put it in the context of today as a proxy for where we're going, and it's not exactly correct because rates are changing and the world is going to be a little bit different going forward. But if you just go back and look at the headwind from swaps and treasuries this year, $340 million in the third quarter, 80 basis points. $340 million in the second quarter, 73 basis points, $319 million in the first quarter, 72 basis points. If you put all those in NIM and NII look strong, that would have added in excess of $1 billion of NII this year. Had we been in that position? We wouldn't be probably having the conversation. I wouldn't be asked to play Jeopardy! on that question. So again, the world going forward will be different. The rate profile will be a little bit different depending on what Fed funds does and where been it goes. So it's not exactly the same. But if you just look down at what the core business is doing, we feel very confident supporting that number. If that were different, we'd have a different conversation. But candidly, if you just look at the core drivers, and that's part of why we wanted Randy and Angela to be here today to really talk about what's happening underneath all the high-level conversations. Clients are feeling good, credit feels good. And while the transaction volume isn't where we would always want it to be or expected to be, the general underlying trends are very good. So when we look at that and we think about the long-term nature of the dividend, the long-term trajectory of the stock, we feel confident...

Randy, you showed that -- this is Manan Gosalia Morgan Stanley. Randy, you showed that chart that showed commercial deposits up 50% versus 2019 levels. Obviously, the flip side of that is how much of that is core, how much of that can still move out in a higher for longer rate environment. Key is clearly on the lower end of peers in terms of how much deposit betas have gone up. So can you talk about how much the back book is repriced what's going on, on the competitive side there? And anything that could give us more comfort that deposit betas can remain lower for Key relative to peers.

Yes. I'll hit on the commercial deposit trends, and maybe Clark can clean me up on the rest of our deposits. But the commercial deposits move very quickly. Many of them are indexed. There aren't many treasurers that haven't woken up to -- money is not free anymore. And so we really certainly don't see that accelerating, but it will move as rates move. But I think as rates are more likely to move down than up on the short end. I think going forward, the fact that we're indexed will help us. And so it -- I don't expect an acceleration with regard to our commercial deposit base. And in terms of the stickiness of it, we talked a lot about the operating nature of it, but really just to kind of bring that home, when you think about your own personal life and your own, you probably all do online banking and the thought of moving that to another bank is probably not something that any of us want to go through. But if you're one of our commercial customers and you have hundreds, maybe thousands of accounts with us that are doing business with hundreds, tens of thousands of vendors and customers, you just can't move that quickly. And so that's why we talk so much about having an operational relationship. And we've been doing this for a long time. And that served us very well through this period, and that's why we'll continue to do it because it provides that stability.

Yes, just I'd add maybe 3 things on the commercial book. One, when you think about the deposit book from '19 to '23, some of that is new clients. Some of that is getting deposits from clients because we just weren't always focused on doing that. And I think the most important point, which just underscores what Randy said, is 96% of the commercial deposits we have come from clients who have an operating relationship with us. So I don't worry about the balances leaving. The question is, what is the cost of keeping them in a changing rate environment. But we know these clients we're talking to them kind of daily, weekly. So to Randy's point, it's somebody want to move operational deposits, we know it, and we'd be talking to them before they went down that path. So I do think that book is very sticky from a balance standpoint.

So like some other regional banks, you've been downgraded by the regulator -- by the rating agencies. I think all 3 rating agencies have downgraded you, so you're BBB kind of lower end of the regional banks. You've also got spreads sort of 3% plus. You've given a fairly wide range of potential issuance from the long-term debt proposal. So I'm interested why the range is wide given that it's still just a proposal, do you issue now, do you wait? And then if you do issue, do you pay down, I don't know, like FHLB and kind of lock in a 3% negative spread? Or what would you do with the issuance?

Yes. So I think our view of the long-term debt rules right now would be kind of south of $5 billion as a number. The reason to issue today, frankly, would be to issue out of the bank and get that grandfathered forward. And then the trade-off question is, is that spread differential issuing out of the bank beneficial enough to take on any debt today? So we've really been managing. We bought back debt or call -- we've bought some debt, we've called some debt. We've brought down advances. So we, at the moment, feel very good about that. I think that's exactly the question we're talking about. And the other piece we're trying to figure out is when do we think those ratings could potentially change given the trajectory of earnings capital liquidity going forward. So I certainly don't think we would issue it all next year. The question is how much of the gap and for reference point today, the gap really are binding constraints RWA and the RWA binding constraints at the IDI -- it's not at the holdco. So that's really where the delta is. So again, that makes kind of the thought of issuing at the bank level, not only checks that box, but a little bit more interesting just given the gap. So we're not going to issue it all next year. We may issue some. If we issue some, I think it's likely to be out of the bank if we get there before the rule is final.

With that I think will wrap up. Thank you, Clark, Angela and Randy.