Episode 1: Let's Talk FinCrime with Tipper X

In the first episode of NICE Actimize's podcast, Let's Talk FinCrime, our host Dave Ackerman will chat with Tom Hardin, AKA Tipper X.

Known as “Tipper X,” Tom became one of the most prolific informants in securities fraud history, helping to build over 20 of the 80+ individual criminal cases in “Operation Perfect Hedge,” a Wall Street house cleaning campaign that morphed into the largest insider trading investigation of a generation. As the youngest professional implicated in the sting, Tom was tasked with wearing a covert body wire on over 40 occasions to help the FBI bring down some of its biggest targets in the industry.

In a reunion of sorts, Tom was invited by the FBI-NYC’s office to speak to their rookie agents in 2016 and is now a global keynote speaker, corporate trainer and board advisor on behavioral ethics, compliance and organizational conduct and culture risk. Through rigorous self-examination, Tom took responsibility for his actions as a young professional, used the experience to transform his life and is now on an on-going journey into behavioral science and why employees sometimes make the wrong decision.

Hear the rest of Tom and Dave's conversation by visiting actimize.nice.com/podcast

Want to learn more about Tipper X? Visit his website here.

Transcript

Unknown: 0:05

Hi, I'm Dave Ackerman and you're listening to the first episode of Let's talk fin crime. In addition to being your host, I'm a lawyer, former Chief Compliance Officer, and financial regulation expert based in New York City. I live and breathe financial crime and compliance. But on this show, we explain what it means for you. Every episode will feature conversations with some of the most interesting people we can find. All designed to help you understand what is happening in the financial world, and most importantly, how it affects your daily life. With that said, I am really excited about our first guest. Picture, if you will, New York City, pre COVID. It's a beautiful morning and you're walking to work alongside the other eight and a half million people. Unexpectedly, two FBI agents approach you and flash the badges that begin questioning you about your job right there on the street. The agents begin spitting out details about your personal life. They know where you were last weekend. They know private details about your family. They even know who you spoke to before leaving for work that morning. Your heart is racing and confusion sets in what is happening, then it becomes clear those trades, but it can't be they were just innocent conversations. It couldn't have been insider trading. I barely got any info and the dollar amounts were so small. How could the feds even know? This scenario may sound like a scene from a movie, but this exact situation did happen. At that moment, our guest today went from being named simply Tom harden, and he became tipper x tipper X was the star witness in the single largest insider trading case in US history. So without further ado, I'm thrilled to welcome Tom harden. Hey, Tom. Hey, Dave, it's great to be here on the podcast. Thanks for having me. Know, thanks for agreeing. It's your story is insanely compelling. And, you know, without like all the cool graphics and background effects, and the, you know, to do this type of music, I hope I gave it a little bit of justice. But would you mind kind of explaining in your own words, what what happened? share briefly, I was a young analyst, in my 20s, working for a small hedge fund around 2007 2008. I started to notice that some of my peers at other hedge funds were blatantly trading on elicit inside information, I didn't feel I needed to cross that line to progress in my career, I already had a great see the great firm with a great seed investor. But around 2006, at my firm, we had our first year performance. And we were up about 20%, which was great. But in two of the four out, that's fantastic. Yeah, it was a good a good a good start. However, in two of the first three months, we actually lost money, which really shouldn't have been a problem, we were investing with a one to three year horizon. But after that, those first couple months, my boss came into my office and said, Look, we're a small firm, we're not going to be around unless we start looking for opportunities to make money every month. Now, he didn't say, Go Go break the law, that type of thing. But there was more of a short term pressure on performance than when we started the firm a year before. So just sort of studying setting the stage for my actions next. So fast forward. A few months to march of 2007, I got a phone call from another investor who I knew in the industry. She said that this company Cronos was going to be acquired next week, this date, this price by this private equity firm. I mean, David's sounding like Wall Street, where it's sort of blue horseshoe type of situation. I've never, never gotten a call like that in my career. Now, I knew the woman that called me was always sort of full of rumors, she lived in Silicon Valley, went to every investor meeting, every cell side bust or that type of thing. So was really plugged in and always would call me with the latest rumor but nothing like this type of you know, happening next week. So let me ask you about that. Then, what's the difference then between you know, I mean, I've got an uncle that knows everything about everything. And yet he's still his, his personal performance is like minus 180%. So what's the difference between someone calling you up and saying, hey, I've got a hot tip. And and this? Yeah, I know everybody here, right? Everybody has an uncle or I have a dentist. You know, that always has to. It's always the dentist. I don't know why. But it was always asking me for tips because he knew I used to work in the market. Like No, you don't want you want to talk to me. But, so for the woman that called me, she got the information from a Moody's analyst who was working on this private equity deal. So you know involves high yield debt. So was working on that at Moody's. So that's information that was misappropriated from the company, there was what's called a breach of duty of this Moody's analyst completely, you know, ignoring his fiduciary duty not to disclose his client information. So there has to be, you know, you take the information, there's a breach of duty. And that's much different than somebody just calling you with a random. You know, I think there's this rumor, that type of things that actually stealing our nation, that's the crime. it's sometimes hard for people when they hear about it think, well, who was who was hurt, who's the victim? Why is this a crime. And people can really hurt their heads thinking about this. It's not like a Ponzi scheme, where they've Give me your money, and I'm going to go put it in this. And meanwhile, I'm buying cars and houses and that type of thing, which we see a lot of too. So it's not that that visceral reaction of committing a crime, but it really if the company's information was stolen, and they, you know, they're the victim, other people in the market who were playing by the rules, 99% of people, you know, were victimized by the cheating in this situation. So that's kind of what it looks like, illegally. So before we get to that, why you? Why is she calling you out of the hundreds of people that she knows in the industry, to give you this amazing inside information that you could clearly make some money on? I think, and I thought about this for a long time. And the FBI even thought about this, they asked me that initially, why did why did she call you because it didn't really make sense. She called maybe I think she tipped three or four other people. So she had a small circle of people that she talked to anyway. So I happen to be in that that circle of her four people. We talked about stocks every week, and just as any industry conversation. So I think the way she was looking at it was she was about 20 years older than me. And advertently maybe taking on me on as a mentee, and me his or her as her my mentor type of thing. And so I think she felt like through my career, I might be able to reciprocate this type of information. If I made these contacts, these Moody's analysts, bankers, or lawyers, that type of thing, or we're leaking the information at the time, but it's usually a situation of the tipper gives me something, and then I call her back and give her something like the quid pro quo. Gotcha. It was kind of different because there wasn't the back and forth. And that's what the FBI certainly asked me about a lot. What was why you Tom, and I think she was kind of, in her mind, maybe as I progressed in my career, I might be able to reciprocate to her. So okay, so that makes sense. So she calls you up. She has a real tip fish on, this is real information. So what happens next? What did what were you thinking? What was going through your head? Yeah, well, I thought this sounds, you know, extremely blatant. It's the first time she'd ever called with something like this, it will be the first of four times Unfortunately, the first time I thought, Well, it sounds like, you know, something illegal. But what I did was I didn't trade on it. I knew enough, at least at that point, okay. Don't don't make any trades on this. But later that day, I happened to be randomly talking to a friend outside my firm who worked at a prop trading firm. So these are firms that you eat what you kill. If you lose money that month, you're not getting your payout from the firm. We were talking. He was desperate. He was losing money that month. And he said, Do Tom, are you hearing anything out there? I could put a short term trade off. And I kind of felt like, well, I'll help this guy out. But passing on this tip. Now anybody listening to this compliance is thinking, Oh, my God, are you so stupid, but I thought, well, this guy said he was losing money. Clearly, again, clearly, it's not being prosecuted if some of these bigger actors that were in the press later, were not being charged. I mean, one of the big billionaires, every 13 f that came out every quarter, you can see him loading up in 2006, and stocks that were later acquired or a few months later. So my partner and I would look at each other and be like, this is crazy, like this guy is loading up on stocks for years, in the 13 F's. They're being acquired, and there's nothing going on. So maybe this law isn't being prosecuted anymore. So that's kind of like my rationalization through my mind. I tip my friend, he tells everybody at the firm about this thing happening the next week, a few more days went by, he called me and said, Tom, you know, we're all loaded up, did you buy it? I hadn't bought it yet. But as the junior partner at my two person firm, talk about a lack of control, I could initiate in the portfolio, a less than 1% position in a stock without having to talk to my my boss can have a starter position, I had several starter positions that I would work on, you know, do more work, do more research, get more conviction. So I just put it in that pocket of a point 9% position in our portfolio. So what does that mean to the average person so like, okay, I kind of want to shift gears a little bit here, because it sounds like all of this literally sounds like a movie, somebody calls you up, gives you a tip, you you help a friend out, because you're thinking, alright, this is clearly going on in the industry. But the average person has no idea any of this is happening. They call things like insider trading a victimless crime. So why should the average person care? Yeah, I mean, I think overall, when people think about this, it takes away from the integrity of the markets. I mean, most people have their money either, you know, managed by a manager, or they just have it in their pension or their 401. k, they'd like to know that everybody's playing by the rules. And when people aren't playing by the rules and are playing fair, it's important to bring these cases to sort of, you know, keep the integrity of the market intact. So for those of you listening, what Tom was referring to, actually is a, this is an underpinning of the financial market system, the idea that everyone has an equal opportunity. Now, I'm a cynic. I personally don't believe that's necessarily true, because there's always going to people be people that have either more money and influence or more access to information. But the fundamental idea is trying to keep everyone having access to that information at the same time, so that they can do their own due diligence, and make investment decisions. So Tom, but here's, here's the thing. Now, I've said this for years, I've you know, you and I both do trainings for compliance professionals. One thing that I tried to tell not just compliance personnel, but Investment Advisors as well is the average person will ask more questions when buying a cell phone than they will handing over their life savings to a financial professional, because money management is hard. This is why you're paying people to do it. It's difficult. It's, you know, it makes you crazy, sometimes to the point where people just say, I don't want to deal with it. Here you go. Yeah. But then my question to you would be, if everybody's doing it, what's the problem? Yeah, I mean, that's, I don't think is as bad as it was back in 2007 2008, when I was charged, but we saw up until the last two years, cases were down. But we saw I think, a few years ago, about one case a week. You know, we saw that basically, like it might be like a junior accountant inside of a company gets information that his or her company is going to be taken over tips, an uncle who they know is in the market. And those cases are resolved by the SEC. You know, pretty quickly, but this is the bread and butter of the SEC. I mean, it has been for 50 or 60 years in terms of insider trading. It has been down the last two years. But I believe they're still working on these cases. And I think they're sometimes easy cases to bring that other type of financial crime cases, famously 2008 2009. No bankers were jailed on the great financial crisis, there was really a focus on insider trading, because these cases are, I think, easier to present to a jury. This person called this person, this person treated to a jury that's very easy to understand, rather than Miss selling mortgages and that type of thing. So there can be in many cases, the brain and so the SEC looks for a clear, usually a clear situation where there was a breach of the law, a breach of regulations. So before we go to a quick commercial break, I want to ask you one more question. Sure. This was illegal activity. You knew it, it cost you your career. You must have made billions on this on this illegal insider trading activity, right? Sure. No, it happened four times. Just to finish the story real quick. It happened to four times these tips. My boss never asked me the question. So we could talk about that later in terms of being an ostrich putting putting his head in the sand. But that's not an excuse for my behavior. It happened four times. I made $46,000. I never thought about the amount of money. And I never thought about ever being caught. I think for me, I knew other people in the industry were doing this. I knew I wasn't part of the group. When she calls me what the tip I placed the trade and it actually happened. I hate to tell you that because I didn't call compliance or call the FBI that day. I actually got a shot of adrenaline. I felt like now I'm part of the group which is very foolish now looking back 10 years hence, but at that time, never thought about the money and never thought about ever being caught because the big guys weren't being caught. Why would I be caught so very, very foolish, but very common. So but I want to make sure I understand this correctly. And I want to make sure that this point gets through to the audience as well. Your your fund was up 20% which is insane. Like that's incredible returns the average, the average investment investment account, the average like savings account right now is probably like, point 3%. If you're getting any money at all, the average CD is probably around two and a half to 3%. your firm's making 20%. You You have studied all your life, you've worked hard. You're in this firm, you have a promising career. And $46,000 was was what did you in? Yeah, and I had no idea that was the number. I mean, that was my number in terms of being the junior partner in the firm. I didn't even know until the SEC or maybe with the Department of Justice presented that as part of my discouragement so you have to pay back, your elicit your list of dollars that you made. And I remember thinking oh my god, that is the price professional suicide. So that is a perfect place to take a quick break. Stick with us because when we come back, we're going to hear about how Tom really turned everything around and is now using his experience as a real force for good. Risk is a moving target and bad actors never sleep, finding new ways to avoid detection and make it difficult for financial institutions to uncover connected illegal activity. Firms today need a surveillance approach that adjusts to changing tactics and works around the clock. Fortunately, there surveil x, a true AI powered cloud native holistic surveillance suite that an analyze his trading, communications and other surveillance data. Surveillance uses regulation based rules, machine learning, natural language processing, and advanced analytics to effectively detect misconduct and comply with global regulations. When questioning if your financial institution is protecting your money, ask if they use surveil x, Find out more at holistic surveillance calm. So for those of you just joining us, we are here with tipper x. tipper X was the linchpin in the single largest insider trading case in US history. He threw away a promising career because of some poor decisions. But now we're going to find out what he's doing now and how he's actually really making up for that. So, Tom, I applaud you for being able to talk about this, because I would imagine that there is a lot of emotion that that you have experienced over the course of not just the trial, and putting away these people who had created this massive Ponzi scheme, but you know, the toll that it took on you. So if you could please tell us a little bit about the the trial and the people that who made a heck of a lot more than $46,000 on this insider trading kind of scheme, as you call it, and and more importantly, how that translates into what you're doing now. Yeah. Dave, when you set the scene in the beginning, when the FBI approached me that day, it was July of 2008. They said we know about the fourth raids, they knew I was just visiting my nephew and Atlanta for his baptism, baby nephews, they knew they had me. I completely admitted to everything at that point. I said, Yep, I made those four trades. The FBI, you know, was taking all these notes, didn't talk to an attorney for a year, I knew I was guilty. But that day was probably the toughest day of my life. I went to the office, it was 2008 the financial crisis. So you know, we were already doing not well. So when I came in with my face white, it was pretty much like any day. So I didn't set up any red flags at the office. I'm Catholic, I went to St. Patrick's that day for a confession figured it would be a good day to talk to somebody. And I told the priest everything and you probably wondered, like, why did I have to get this guy? My mother tells me he's heard worse. He says in New York City, man Come on, like, hedge fund guys lined up behind me. Exactly. You know, I told him everything. I was like, I don't know if I was suicidal. It was the lowest point in my life. And the priests. Tom, it sounds like what you're saying Tom is 99% of your life, you've done the right thing. But this 1% you've really screwed up. But you can't let this 1% kind of define what you're thinking about doing to yourself or what you think how it might impact your life. The decisions now that you make time going forward, are going to impact your legacy that you leave for your family, your children. And so I don't know who the priest was, but I think he probably saved my life at least that day. I called the FBI and said I'm ready to help you out. I didn't know what that meant. That meant wearing a wire for two years undercover getting people in conversations. I just took orders from the FBI. I had no plans ever to talk about this. As you said it's in my 20s I was so embarrassed. so foolish. throw away my career, you know, Wharton School. You know, Georgia, the Wharton School they have to career over. The FBI actually gave me a call in 2016. So I was sentenced in 2015 to time served. So no prison because of my cooperation, but I'm still a convicted felon. And it's very hard to get a job as a convicted felon, especially white collar crime, and someone's viewed as worse than then, you know, other types of crime because I should have known better. And so the FBI called me in 2016. I thought, Oh, my God, what are these guys want? Now? You know, my wife was probably thinking, what do you do now? And she stayed with me, which is rare? I don't know. And they asked me to actually come talk to their rookie agents. In the white collar crime group in New York about my case, I was one of the youngest people, they charged with 85 people and what's called Operation perfect hedge. And that $46,000 that we talked about, I think was the third lowest discouragement of all those people. So like, Tom, why do you do it? I went and spoke to the rookie agents at the FBI in 2016. And a couple agents said, You know what, I think this could be a really good sort of making lemonade illumines type of story. Not saying Tommy Have you ever successful at doing this because again, who wants to bring Tom and it might look bad for a company. So I went and felt I had the FBI blessing, I had nothing to lose, put together and cold email list of maybe 500 CEOs in New York City. Hi, I'm tipper x. I'd like to talk to you a company a catchy subject line, I got to opens our I'm sorry, got two responses, I get a few more opens two responses. One thought it was a cybersecurity attack because ticker x doesn't sound real. And I said that's another type of training. But another individual said, Hey, come talk to my team. And that individual gave me three referrals. Those people gave me three other referrals. And from there, it's built out the last four years, the talking over to over 350 organizations, as a compliance guest speaker about hey, this is what goes through somebody's mind when these situations happen. It's also evolved into ethics training, behavioral ethics. I've done a really deep dive into behavioral psychology talking to some of the behavioral science experts in the financial services industry, to kind of take my narrative and put in some of those elements. And so now, I've been approved for ethics training for attorneys for CPAs. For cfps. For cfps. for individual Institute, ay ay ay ay, the otters unit by a Val. Yeah, exactly. Man. I get confused with these acronyms. So there's ethics training, there's compliance training, I just come in I share a real world story, it's it's so often got to hard to share stories, sometimes inside companies have bad stuff that's happened because the employment attorneys, you know, put the kibosh on that we can't actually talk about something here. So I can be the case study for you know how things can happen and what I was thinking at the time and how it can be prevented. And so personally, that's the part that I love about your story the most is, this is not simply just another cautionary tale that we can read about in the newspapers or hopefully seeing a movie one day, this, you really took something that was, as you said, the lowest point in your life, and you're making real actual change. And personally, I think that's admirable, that speaks to kind of what the priest said, You're 99% of your life has been really upstanding and you're taking, you're taking that poor decision, you're really doing something good with it. But so let's I want to touch on something real quick. You had mentioned that in the case that you were the the witness for you were the third lowest discouragement, the 44,000 that you made was the third lowest. So what was that? What was the most people made from this? Was it 100,000 150,000? I think Roger Roger rhogam, the billionaire who was sort of the the big target of this investigation, I think it was high, I want to say high eight figures. So that's for his firm, I'm not sure about what his personal take was. So it was maybe 70 or 80 million, it doesn't escapes me right now. 70 or 80 million. Now the 46,000 46,000. So, so essentially, what happened was through your efforts in trying to cooperate with the FBI, you helped essentially take down an insider trading ring that was moving markets and actually making it unfair to the average investor to the tune of 10s of millions of dollars. I mean, the FBI gave me a chance to turn my life around that day. And I just I took it. I mean, I knew what I did was wrong. And if there were at some, some times they could ask, why did you cooperate? You know, why did you turn to take these other guys down, I just felt like they were giving me a chance to do something positive after I'd done something negative and I took the opportunity to do that. So let's take this shift this a little bit. So the average person who is who we're speaking to right now, is probably hearing about this and thinking, Okay, so the markets get manipulated. Who, who is watching this? You know, you'd mentioned that you're doing ethics trainings for compliance officers. I'm a former Chief Compliance Officer. Are we just terrible at our jobs? Do we just suck at this? Or is it? Is it something else? Is there? Is there somebody watching out for this type of behavior? Yeah, so a couple of things to think about there. since the financial crisis, I saw that I think from the operational risk exchange, where banks and financial institutions submit their information. Last year, they said $600 billion of fines of misconduct type of situations have occurred in the industry since the GFC. So the last 10 or 12 years $600 billion, and a lot of that now, is financial risk. So we're not we're talking about financial crime, or, you know, the library scandals, the FX scandals Tell me if I'm getting too much in the weeds, but we're talking about that we're also talking about non financial risks, we're talking about mis selling to customers, which is more the ethics training $600 billion. I think another stat from LexisNexis I left up here is we spent, the industry spends like $200 billion a year on compliance systems and risk systems and that type of thing. And we still have an issue. And so some ways to think about this is I think, compliance needs more of a seat at the table. Every company I speak at always hear that they're under resourced, I think, yeah, I think that they need to have more of a personal relationship with the business. If you're, if you're in the client seat, make sure you frame yourself as the protector of the business person's career, and you're not just there to catch them in footballs. It's so often I see, or I hear from companies that all compliance is just trying to get us. And I think we have to reframe that, that you're there. As the career protector, you have to know who your partners are in the company, you have to have great relationships with HR, with maybe the head of strategy with internal audit, if you're just on an island by yourself, doing the training that's based just on the rules, that's a terrible place to be because you're not going to have the pool the messaging inside the company to get these resources for the program. So if any of you are curious as to why you should care. And although this is a really compelling story, you weren't really making that connection to your daily life. Think about what Tom just said, that is an average of $60 billion a year over the course of the last 10 years. That is a lot of movement. And there are dedicated men and women just like he and myself, who our entire job is to try to ensure that everything is fair for you. So your investments with your investment professionals, your 401k, your annuities, all of this money gets pulled together and put in his put into this great big machine. That machine we are trying to make sure is as fair to you as possible. And part of that job. stems from lessons learned from the case that Tom was a witness in this, this massive 10s of millions of dollars that made people wake up and realize this is not a victimless crime. This is something that is going to affect every single one of us. There is a there's a saying in finance, when the US sneezes, the world catches a cold. And you have to be very careful when choosing what to do with your money. But at the same time, when you give that money over to a professional, you want to be able to have the confidence in them, that they're doing the right thing for you. And that they are being watched by individuals like us who know the rules, know what they can and cannot do, where those boundaries are, what the rules of the game are. And that way, when you're playing the game with the 10s of millions of other people, you have just as fair shot as everybody else. So Tom, I just want to in the last couple of minutes before we kind of go to our additional content but summarizing this for everybody at home, I kind of want to ask you the one thing that you have seen or learned since doing this, you said you spoke to over 350 organizations at this point what what's the one One thing that stands out what's, what is what are people either doing or not doing? That is just constantly surprising to you that you're meeting all these people? Well, first off, I mean, pretty much that everybody that hires me wants to do the right thing. It's very rare that somebody brings me in it does, wants to do the wrong thing. They don't want, you know, instructions on how to how to do it, that I'm not the person for that. So putting the front everybody must do the right thing. I think what we tend to need to focus on is we focus so much on what has happened in the past incidents we've had inside the company and try to learn from those. And we're not as focused on the what could happen. When companies from the regulator's are kind of being forced now to think about their culture, and things that could happen. Some of them push back on this, you know, why should we think about that we should just look at things that that have happened and learn from that. So we kind of have to evolve there. And we need more of a principle based, I think, focus compliance instead of rules based. Yes, we have to go through the rules and regs but compliance. So often, the training is really more about should be more about specific training for the person's role. And too often, it's just education. Here's the latest rule. And rag, it's often written by attorneys, obviously, it doesn't sink in. And so I think we're seeing one terrible attorney friends now that are compliance officers, I don't want to bash them. But let's not feel free to do it all the time. Let's change the framework here from compliance education to compliance training. And even in your training, it's so hard to make it you know, really stand out, I wouldn't even tell people what you're training them about that way, see if they can actually figure out what issue you're talking about, because anti bribery could mask itself and the ABC type of thing. And seeing if people can actually pick out the issue the risk issues in the training that way, at least you know, that it stayed with them. So there's more things we can talk about there. But I think we're headed in the right direction. I've never seen the regulator's as focused on kind of conduct and cultures we have the last couple of years globally, that's great. But I still think companies need to look at what could happen is that just trying to figure out why things happen in the past. And we often have a terrible that our root cause analysis, we blame the bad actors, we throw the bad apple out. So that was a bad apple, we hire somebody who is a senior person in compliance or risk and say they're gonna figure out what happened and it happens again, so we don't really look at the barrel, we just look at the apple. I think that's a great place to end this conversation. And I really appreciate you joining us, Tom, thank you so much. And for those of you listening, I want to leave you with a couple of parting thoughts here, especially with what you know, things that we can learn from Tom his story and what he's doing now. The first is really about this idea of isolated decision making. And if you ask anybody in our industry, who our job is to watch, and to prevent people from doing bad things, but it also is to educate and help them help you. Part of that is making sure that no one is making a decision in isolation. And I encourage you to do the same. If if you're questioning something, if something doesn't smell right, or it doesn't feel right, ask speak to someone making that decision in isolation can oftentimes be a recipe for disaster. It's probably not and it's probably benign, but it's never a bad idea to get a second opinion. And the last thing I want to leave you with is how do you prevent being taken advantage of buy these types of forces? And really, it's, it's about educating yourself. Don't simply just read the news and and walk away Take a little bit of time, try to figure out does it affect you? If so, how, have that conversation with your financial professional, have that conversation with somebody in your family who happens to be really good at this stuff, see if there is something that you should at least be cognizant of. And that way, if the warning signs are there, you can find them. So with that, I'd really like to thank you for joining us. Tom and I are going to keep this conversation going and to hear the rest of it. Visit atomized dot nice comm forward slash podcast. We hope you'll join us again in two weeks for our next episode. But if you can't wait until then, drop us a line at podcast at nice optimized.com Thank you very much. I'm your host Dave Ackerman and can't wait to speak with you again.