Episode 14: Let’s Talk FinCrime & Culture of Compliance with Tipper X

Why do good people make bad choices in the workplace? On this episode of Let’s Talk FinCrime, we bring back Tom Hardin, better known as Tipper X, as we discuss the vital importance of instilling an ethical culture to reinforce accountability and put your organization in a position to make the right choices.

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.

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

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

Transcript

Unknown: 0:10

Hi there and welcome to Let's talk fin crime, the show where we explore the human side of financial crime. We cover not only the big financial trends, but how you can truly protect yourself and your assets. I'm Paul Cody, I'm just one of the hosts of season three. I'm in the financial markets compliance business at nice and I'm based in New York City. My career started in trading and sales in financial markets before I became poacher, turned gamekeeper and became a compliance officer. I've worked in Sydney, London, Singapore now in New York. So I think over the years I've seen a fair bit. Today, we're fortunate to be talking with Tom Hart and again, Tom is also known as tip x. And you may recognize Tom from our very first episode in this series, as he shared his story of how he was one of the most celebrated informants in securities enforcement history. aiding in the Wall Street housecleaning campaign known as Operation perfect hedge. This became the largest insider trading investigation in a generation and brought down some titans of the market. As the youngest professional implicated, Tom wore a wire on over 40 occasions to help the FBI bring down its targets. Now today, Tom is a global keynote speaker and corporate trainer on behavioral ethics and compliance. Tom, Thanks again so much for joining us. Thanks for having me again, Paul. Pleasure to be here. Okay, well, I guess, let's kick off what are you? What are we seeing in the market these days? I mean, I think last time you spoke to us, we we've been in in lockdown and or work from home for a little while now or for a little while. And clearly, that's gone on a bit further. And now who knows we might be coming into it again. And certainly in some parts of the world, like my hometown of Sydney, financial markets, professionals are all having to work from home. The thing that's really struck me about the pandemic is things were looking things just changing so quickly. But then again, we think, well, now we're looking towards the end of the year for you know, what will be happening towards the end of the year, time seems to have become a very, very rubbery concept. Where are we now? What are we? What are we seeing right now? Do you think? Yeah, so we're really seeing, I think, in the last sort of 18 months of the pandemic, much more of a focus, I mean, it started before COVID, but really much more of a focus from, you know, global regulators on this idea of individual accountability, conduct. What are some potential opportunities for misconduct to happen, that firms aren't thinking about maybe with everybody at home and now transitioning, which looks like you know, to a few days at the office a few days at home, what are the opportunities for, you know, quote, bad, bad things to happen? Are the firm's thinking about it, the regulator wants to make sure that you're actually, you know, have adjusted your compliance procedures, your your risk procedures, the three lines of defense are all working together cohesively. You know, while we're in this sort of transitional moment, and for me, what I, what I've seen really reflected my talks when I when I share my story around conduct risk and ethics, I always key on this idea of isolated decision making, which I talked about, in the first episode, I made a decision in isolation, didn't talk to anybody at my firm made a decision to make the trade and throw my career away. Unfortunately, fortunately, you have the opportunity, I have my own sort of poacher turned gamekeeper story, myself a bit different than yours. But, you know, now doing these talks, and I've actually seen this resonate quite a bit during COVID, where I'll speak to a primarily financial services firm. And they'll give me an example of an employee making a decision in isolation. While they were at home, just as an example, I was speaking to one large European Bank as part of their conduct training last year, and they had a banker, who was put under pressure by a client on a phone call at his house saying, we'd like you to change this, this covenant and this loan agreement and the bank's loan to them. And the banker was thinking through it and thinking well, and the client said, you know, we'll make it right to you. So the banker was thinking through Well, if I just change this one covenant, who's gonna know but he rightly call this comply read on page 27, of exactly six page document, exactly who would know and he felt he was in this situation about nobody would know if I change this one covenant, I'd make this decision in isolation at home where I don't have compliance as help. Luckily, he actually raised this up to compliance. And I was able to put that in, you know, to my part of my talk, so I think there's a lot of situations. Yeah, where you're under pressure at home, there's nobody around to kind of check you you don't have the lines of defense, maybe as well figure it out, as you did while we were back in the office before COVID. Some more of those situations are coming up, I think, during this this, you know, the last 18 months. So this I guess what you're talking about is you're in an office situation, that that banker would have been Just being able to get up and walk down the desk or just, you know, walk, walk around to legal or compliance or something, or just pick them up and say, hey, let's go and grab a coffee or something, and have a sort of an informal chat. And whereas now it's what I'm finding is there is everything's got to be put in Outlook, or everything's got to be put in everything scheduled. And it's much harder just to do that ad hoc sort of, sort of stuff. Are you you're seeing I think that's what is the sort of thing you're referring to here? Yeah, I think even time pressure, which the spanker was under in this situation becomes even more Paramount, maybe, you know, being at home, or he was looking at a deadline to get this done. If he if he just went ahead and got it done. If he, if he did not do what the client wanted him to do, maybe the client would have been upset with the bank, it's a very large client at the bank, they would have pointed this individual out, you know, maybe not being cooperative when he was doing the right thing. So he faced those pressures, very easily could have rationalized Hey, this isn't hurting anybody if I just tweaked this one covenant and alone agreement, but it potentially, you know, would have led to possibly, you know, a career ending situation, or at least employment in this situation for him, which we see. So often in my talks, I see this where if somebody is afraid to raise their hand and run this up, sort of the flagpole, as they say, if they feel retribution or fear that somebody is going to, you know, come back at them. Why are you raising this issue? This is a really important client. Like, I think it's so important that we have this idea that it's okay to raise issues, especially now, and that we're going to hear back on these types of issues from our bosses or, you know, our leaders in the company. But what, what would have stopped that person that banker do, he say about isolated decision making? And that can take I guess, two, two forms? I mean, when you did your insider dealing, you mentioned isolated decision making, but you were working in an office, so you were your decision making process, correct me if I'm wrong, your your decision making process, the decision making process was isolated. Right. But now we've got people who are physically isolated. Yeah. So you know, does that mean they're sort of dwelling on things? You know? I don't know. I just, I wonder how that does. That the word isolated can be taken two ways. But But what would have stopped that person, I mean, that person clearly did the right thing. But to me, it's, it seems like it might actually be a more conscious thing to do it now. Like, as I say, rather than just get up and go on, go over to the compliance guy, or go over to the legal department and just, you know, taps out, you know, just see someone sitting there at this game, you know, Hey, can we have a chat about something, that person that you referred to head to actually consciously pick up the phone or get on a team's call or something? It seems like, you know, really, props to them, because it's actually To my mind, it's actually a little harder to do that sort of stuff now. And I guess that's my concern that you've actually got to be more conscious about doing it now. Yeah, that's the point I wanted to make just, maybe this, this bank, or this individual might be the minority of somebody who who did the right thing. And this was not, you know, breaking the law like I was involved with, but this is a situation that definitely, you know, would have been not following the bank's procedures, of course, yeah, bring this up. And in talking with compliance about the specific covenant and alone, and maybe this is an example of somebody, and the minority of actually doing the right thing, they're just more opportunity, I think, was what I'm trying to say, kind of, you know, being at home today, with this idea, and it seems to be resonating, you know, much more in my talks than before COVID. I mean, it always resonated as a point but like, this is really every time I speak to a firm, I work in an example of a potential, maybe ethical dilemma that people might face at work. And to be interesting, more often than not, it's often a moral temptation, like the right thing and the wrong thing to do. So much of ethics training. I mean, we've all had probably people listening is like, here's an ethical dilemma of like, here's the right decision. And here's the right decision. And what's the more right decision, the professor will tell you. Based on theory, you should choose this decision, this choice or, or even here's a wrong decision. Here's a wrong decision, which unfortunately, happens a lot. What's the least wrong thing we do in this situation? it's rarely ever talked about. Here's the right thing to do. Here's the wrong thing to do. I think people think, well, if I was presented with the right and the wrong, I'd always do the right thing. But what am I talking really about? You know, who you're around what you're seeing in the groups around you going back to my case, I knew these other players in the industry, were engaged in this type of behavior. I felt once I placed my first trade, like really thinking about why did I pull the trigger? I mean, I rationalized, I said, they're all doing it. I felt a sense of like being part of this in group. And what I've learned, one of the professor's mentioned in a paper it's called normative compliance. So a different type of compliance where Hey, the group is doing it. I'm not part of the group. I got this tip and traded. I'm not part of this group. I know it was engaging in it who is a little bit older than me a little bit more advanced. in their career, that I was in my 20s. And now I feel like if they feel it's okay, you know, I'll do it too. And we saw, you know, with lightboard. And these other scandals FX over the years where just just, you know, request to tweak, tweak the rate a little bit. You know, at the Tom Hayes trial, he said he was just a blessing, like small, incremental, imperceptible moves and the rate and I said, Wow, I was saying this was an immaterial trade I was making we tried to really minimize these decisions sometimes. Yeah, you know, I remember listening to the bonus, the bonus material of your of your previous podcast, and, yeah, that, you know, the Tom Hayes thing stuck in my mind. And, I mean, there are there are many like that, I mean, the, all of those libel fixing cases, you know, you read some of the, you know, you read the transcripts and are asking for, you know, tenths of a basis point movement or something, but you do that enough. And it's, you know, suddenly someone's paying 50 bucks a week more 50 bucks a month more on their mortgage, or something. So it does actually have an effect to the, to the person in the street. I guess, thinking back to the example of that, that that person that you mentioned, looking at it the other way, could it actually be easier for them? If I'm a banker, and I get up from my desk, and I go over to another, you know, another gone, my boss sees me going to the compliance people and talking to them might actually be easier. If my boss can't see me, couldn't actually, okay, yes, it's harder for me, you know, I can't just get up and walk over that person. So there's less spontaneity about it. But I don't have to hide my tracks. You know, if I'm trying to do the right thing, I don't have to hide my tracks, I can actually just go and I can pick up the phone, and no one. No one, none of my immediate team colleagues know that I'm doing that. Could we? Or should we be actually trying to say, Well, you know, this actually creates opportunities to do the right thing, you know, you're not, you're not maybe as preferred if you're a trader on a desk, and all your traders around you, you know, they're all doing a bit of spoofing here and there, and you're not in that environment could actually be a defense, you know, like a barrier, you know, like, like a, like a castle wall that allows a good person to do the right thing, rather than get sucked into the whirlpool of doing the wrong thing. Yeah, that's a great point. It's sort of like we talked about conduct them in sort of parallel that the brother, the brother, or sister conduct is culture. And so what was the culture at the firm before COVID, you know, had that stayed the same in terms of the last 18 months working at home, onboarding now to, you know, new graduate classes into finance. And they're all you know, your recent graduates starting their careers at their apartments with their roommates. And so what type of change? Has there been in the culture? Where were you around people who were doing the right thing, and now you are doing the wrong thing. And now you're at home with the opportunities you said, maybe to do to do more the right thing? But really, do people have a pulse on how the culture may have changed in the last 18 months with their firms? Because we always see these scandals and misconduct happen. And sometimes the banks will say, how could we have known? I think it was one of the largest banks in the US, the CEO a few years ago said, we have 270,000 employees. If we were a city, we'd have a prison. So it was I don't want to say who said that, but it was sort of like this is the cost of doing business. You know, you know, it was so yeah, this is just the cost of doing business. And I think that's really not the right way. Certainly not the way that regulators want you to think about it now. And no, going back to this problem in the culture, if that's the tone at the top, the culture, there's often problems in the culture before the conduct misconduct. Yeah. You know, do you have a blame culture? Is the young person going to be able to raise their hand when they make a mistake? Maybe unintentionally, and get to get the help that they need the course directed? Or do they have the fear of? Oh my god, I made a mistake. But I can't run this up the flagpole? Because a I'll never hear back or be this could just in my career Early. Yeah. So do you? And then do we have like a blame type of culture where people are just blamed all the time? That's, that's your fault. That's your client, that type of thing? Or do we have a more you know, collaborative type culture because the blame culture, not recognizing not sort of learning from mistakes over and over. I mean, we see it all the time can lead to the misconduct problems when people aren't putting their hands up, because they're afraid of, you know, retribution or just not hearing back at all. That's probably the worst thing you would report something and like, never heard back. Yeah. And so I'll get hired all the time and say, Tell them to speak up. And I'll report back to my client later and say, Hey, you guys should also listen up so that the senior management also listen to what's being raised. You mentioned the the no blame culture, I mean, some years ago, or going back decades now, but the aviation industry, for example, went from you know, when there's an incident moved from a blame culture to a no blame culture, you know, and the idea is to get, okay, well, you know, if a pilot does something Wrong, and there's a causes an incident. You know, the the emphasis is on speaking out, yeah. How did how did? How did this pilot get into that position where they, you know, went below the glide slope coming into land or something, you know, it might be that the pilot is a bit of an idiot and deserves to lose their license. But there might be background systemic things that that happened. And I think the aviation industry has has benefited from a no blame culture and made made it safer for all of us. So to the extent that, you know, as the saying goes, You got more chance of getting getting hit by lightning than then having something go wrong in an aircraft, you know, in an aircraft these days. So, I mean, it would be I think it would be great if we were able to move to that no blame culture across the finance industry, but I'm not sure if it will happen. Yeah, I think the aviation Koch Industries have modeled like where we could go. And I think sometimes people say, well, that's like life or death, like the plane that goes up. And Boeing, obviously, we saw, had their issues over the last couple of years, and the CEO resigned, because planes were falling out of the sky. And then one, one, pushback and finance as well, it doesn't really affect people's lives, like like, like, you know, a plane if they fix it. Exactly. And there was one stat where since the financial crisis, I wouldn't say 500 billion in fines have been paid for misconduct, that capital from the bank could have been used to underwrite 5 trillion in loans in small businesses to individuals and wasn't. So I would shift the, you know, hey, we're 270,000 employees, we'd have a jail if we were a city, I'd actually say no, you know, this actually does have a systemic impact on society, if you have to pay all these fines in Canada, right loans, especially their last 18 months of people really, really struggling with you're talking about hundreds of billions of dollars in fines. I mean, you know, a lot of our 401k plans would or pension plans, depending on where you listening to this wrong would would probably have shares in banks as part of their investments. So if if your bank if your pension fund has a decent shareholding in a particular bank, or a number of banks, and those banks are all getting fined, you know, 10s, hundreds of billions of dollars, that's going to affect the returns on your 401k on your pension fund, if nothing else, but also as you say, that hit to the balance sheet Someone has to pay. I'm not saying the authorities shouldn't be finding they should be putting these, you know, they should be making clear that this behavior is unacceptable. But the point I'm making is that these fines aren't victimless, and these things do affect us, the man in the street level or person in the street level. Hey, listen, we should take a little break here. You've brought up some things about conduct and culture and tone from the top that I'd like to explore in little great detail. So I think this is a great place to take a short break, and we will be back in a moment with Tom harden aka tipper x. Internal fraud isn't something most firms talk about, but it's a huge problem that drains over$4 trillion from the global economy every year. And the sad fact is most fraud and other harmful employee actions are only discovered afterward, despite red flags and 85% of investigated cases. But now there's a way to proactively spot at risk employees with a luminous combination of breakthrough behavioral science and AI you can see the early warning signs that let you stop trouble before it starts. Visit elomina.com to learn how right we're back with Tom harden Wall Street insider trader turned FBI informant turned speaker and trainer on ethics and compliance issues. Tom before the break we were talking about culture and tone from the top and we're talking about some big numbers you know the old story billion Hebrew billionaire and pretty soon you're talking decent money. And you mentioned you were talking about the libel fines and FX fines and all this. And we're also talking about, you know, the culture from the top and one one comment that concerned me and I'm going to paraphrase very much here to sort of anonymizer but one one, sort of a few comments that were made when these fines were being levied was all you know Yeah, it's a big fine, but our bank can handle it. We've got plenty of capital in the bank, you know, $2 billion fine chicken feed and we lost we lost x billion dollars in these trades and you know, we lost another couple of billion to find that's, you know, it's going to be a you know, to two cents APS hit for the quarter and Okay, they're trying to You know, safer oil, you know, we're still strong we've got a massive balance sheet you know, this doesn't affect us don't take your money out if you're a depositor and for our shareholders this is you know, it's a it's a small hit but we'll continue on. But at the same time it I wonder if it is subconsciously if it sort of downplays the by doubt by by consciously trying to downplay the financial impact. They're potentially subconsciously also downplaying the cultural impacts, like 2 billion bucks what they owe, you know, is that, what do you think about that message? Is it a kind of a mixed or confused message there does that, which is more important here try to keep the shareholders onside or trying to say to the employees now, hang on, guys, this is a $2 billion hit to us. This is a big amount of money, you know, we shouldn't be doing this. I'm not. I'm not privy to those banks, internal communications. But I wonder which way the culture needle points there? Yeah, no, I think to your point, there's still a problem, I think, with the compensation, sort of, you know, in the industry is still being focused, you know, incentivized on on short term decision making. And there's still pretty weak mechanisms for accountability. And I think like if we were able to change the compensation structure to actually risk of clawback if the decisions you're making today, 123 years from now, as we saw, as you mentioned, some of the, what was going on in Australia, you know, you're actually gonna get clawed back your bonuses, we actually saw that happen with one MDB, the major investment bank, and what with that, where they actually clawed back the people who were very high up at the bank in terms of working with one MDB and perpetuating that fraud. We saw a clawbacks there. So I think the risk of clawbacks compensation, more much more individual accountability, rather than like I can make this decision now for short term profits. And whatever fine, the bank incurs down the road, they'll just handle it. I mean, we're getting there in some jurisdictions more than others. But I look at like, again, I always come back to what are kind of the structural causes of misconduct risk, and it's the short term compensation, kind of middle managers, maybe having weaker accountability. often talk about Yeah, to at the top is important, but what's the mood at the middle, like, Oh, yeah, the CEO, and that shareholder letter, he or she is saying this or that, but that's just sort of virtue signaling, which is a big, a big term now, like, that's not actually how it works here, there's really no accountability at middle management. And really, you know, who you're who you're bringing into the firm, are the individuals that you're hiring, maybe between firms, bringing in different types of, of cultural norms. The example we started off in the beginning of the episode with the banker making the right decision not to change that covenant, he actually told the compliance officer at his old shop, this is pretty common to be done just to please the big client, and it couldn't be put under the rug and compliance was okay with that. So are you bringing in people, you know, cross hires that are bringing a different type of culture, what they were exposed to, to your to your company. So I would always look at those three types of pillars for how that we, you know, look into crystal ball in terms of what could happen at the company, rather than just looking at the past. bounce around out that bounced around that and see where you are, in terms of, you know, frameworks, and that type of thing for thinking about conduct. Which brings us nicely to discussion, I think about conduct and culture and things like smcr in the UK, and, you know, the regime that's coming up in Singapore, and Australia, my home, my hometown. But before we move on to that, you mentioned, the idea of, you know, roommates and new grads, and so on. And I think one of the regulators, last year mentioned actually brought that out as a specific risk. And saying, Well, you know, now you've got, you know, say college buddies who are now working for two rival banks. You know, one of them joined bank and the other joint bank B, and, you know, they're roomies and they're literally working across the kitchen table from one another, and how do you stop? You know, how do you stop the information leakage? You know, the, you know, Jim over here and Bill over here and you know, Jim's talking about a takeover and Bill's, you know, working on a trading group or something how you can't you just hear it, you can't stop yourself hearing. And I think this is where the, this is where it becomes very difficult for conduct to percolate down in remote working. I mean, so you should we have a bit of a chat about sort of the setting the culture and conduct and all that sort of gear because I think that's it's it's increasingly an important I mean, it helped the financial the UK regulators, the Financial Conduct Authority, change their name to reflect our focus is on conduct. Yeah, it's a big thing. And they've I've been most impressed by it by them that FCA often puts out these sort of papers. And very, very thought provoking. And they've obviously hired some behavioral scientists to kind of flesh out what do they want to see from from the banks. And to your point, I know that they raised that flag a year ago about the sort of increased use of WhatsApp in the apartments at home, where you're sharing, you know, potentially sensitive information, you know, from your employer, which we can do surveillance on, I should just plug By the way, that's right, though. There are vendors out there. That's right. You know, so the FCA is really on top of this, I think with the new hires, especially to, it really just goes back to the type of training you can onboard them with, I've been lucky enough to kind of be a part of that the last couple years, there's just one of my favorite talks where you're 22 years old, you're fresh out of university, you only think good things could happen, then I come in there with a different story, you know, unfortunately, my story, but fortunately, I have the opportunity to, to kind of shed some light on how this can be made, where your career can go a different way. So I think going back to what not to do, you know, when you're at home working, I think if you can really set the tone right in the beginning, you know, first week of their career, this may be going on in other banks or other places in the industry, this is not what we would tolerate it all here. And really, you know, at one strike type of situation, and you're out if you want to strike that tone, you know, this is something you should never be doing, sharing confidential information. And I think if you just set that tone at the beginning of training, you know, that that's going to reverberate, you know, through the organization, especially with the younger people, that's sort of like a, like a, you know, there's no ambivalence, because I don't know if I talked about before, but kind of ambiguity is really kind of the enemy of ethics and compliance. So if you're giving ambiguous messages to people, and there's kind of gray areas where they don't really know they should be doing that can be a problem. I mentioned in my first episode, when my boss came in and said, we have to make money every month when our goal is from, you know, years, two months, the opportunity, you're having a good quarter, but that was but he came in and said we got to make money every month. Yeah, yeah. So the opportunity then, implicit in that was I don't care how you do it. So that was a very, somewhat ambiguous message, does he care in my cross the line in the industry or not? And then I placed the first trade, he says nothing, he must think it's okay, he would have fired me. You know, I buy this stock, and two weeks later to take it over, like, come on, like, that's the stuff we've ever traded before. But he didn't want to know, he didn't want to ask the questions. And so I see this sometimes today, where, as a senior manager, you could maybe be in a situation where, you know, you are an ostrich, where, hey, don't tell me about, you know, that comment needs to be changed and want to know about that, or other examples where you can't be an ostrich like you have to be willing and be asking the right questions asked, you know, follow on questions in terms of potential misconduct type of situations where it's so much easier just to close your eyes and see, I didn't, didn't see that happen. So, huh? Oh, yeah, that Junior trader though, or a rogue operator, they, they, you know, I didn't know what was going on. And they clearly did it and actually compliant that compliance departments to blame, because they should have had the systems and controls in place to detect it. And they were asleep at the wheel. But me the senior manager, um, you know, I didn't have anything to do with this. I think what you're saying is that view, you know, under the senior manager, accountability regimes, that just doesn't fly anymore. Yeah. And I think back to like compliance as a partner to making sure the CEO has that, that partnership with the business some oftentimes and say, Well, if compliance has an issue with this, they're gonna flag it otherwise, let's just, let's just keep going. So I know, it's often talked about culture of compliance, and how do we get a culture of compliance? Well, if you have a culture of people who are just going to follow the rules, or the laws, and then you have a situation where it's kind of a gray area, like the, you know, tweak this covenant, it's not breaking the law, but and there's no rule, there's no rule for Oh, let me look into compliance manual. There's no rule for this, I guess I'll do it, you have to have sort of like, that's where the ethics comes in. Also, okay. You have a culture of rule followers, but you don't have people making the right decisions in the gray area. Is that something that that really, I think should be more a part of our training to? Really, you know, am I willing to be held accountable for this decision? At the end of day, I would just say, ladies and gentlemen, in the training, are you willing to be held accountable for the decision you're about to make if the compliance officer can't even sort of gameplan every different decision in the gray area you're going to be encountered with, you know, over the course of weeks and months ahead, but are you going to be willing to be held accountable if you're not going to be held accountable for the decision? You know, don't make it? Don't do it? Yeah, actually, you mentioned something that, you know, back in the early days, my compliance career I started, I was called upon to do the induction training for I was working at a law firm and a large firm and I was called upon to do the induction training for some new hires in the front office. And I'd listened to my boss do a couple of days, but I developed my own retainer, and I said, similar to people in front of me, I said, Okay, two things. Firstly, can you explain this, this this derivative structure that you're putting together? Can you explain it to your grandmother? Yeah, if you can't Okay, you're you know, you're a PhD in mathematics or something, and you're selling this to a to a corporate and so, but figure out how to be able to explain it to your grandmother, not, you know, don't have to great, great detail, but just, you know, if you can, if you could write down on it on a piece of paper and say, well, we're doing this, this, this and this, and this is the outcome, that's fine. The reason I mentioned that the second point is that if this goes wrong, then you need to be able to explain this to a panel of 12 people who called a jury who are on the jury and nothing against juries, I'm big believer in, in juries, but you know, the makeup of juries, often people who, who kind of don't have anything better to do with their time than be on the jury. Now, that's not I shouldn't say it in those terms, what I'm getting at is they, you know, they, they they're not the people who sit on a jury are probably not going to be finance professionals. Right? And so they people who come from all walks of life, who don't have a finance background, and you're going to have to explain this and defend your what you did to them. And I remember seeing a few people sort of sit up when I mentioned that, and it's like, oh, you know, hopefully, maybe I hit I hit home with a few people. And anyway, can decide nothing. It's people who get emotional injuries, I think it's a great service and a good civic duty to carry out. Yeah, we're doing all this stuff on, I had to just dropping off points there. I love the grandmother test. I also use that like, would your grandparents be happy to see the decision you're about to make on the front of the Wall Street Journal? And I can tell you in my situation, no, it's like, I like to pivot on that. And another thing, going back to really more about decision making, I shared this framework in some of my talks, it's like four questions, is what you're going to do legal and ethical, of course, will the right decision be made for the client? Will this decision reflect the shared values of our organization? And the fourth one we talked about? Are you willing to be held accountable for this decision? And so where people choke up most again, we go back to is the accountability. So just wanted to throw that in there? Yeah, well, I mean, your your, your, your a well qualified person to be able to talk about the accountability side. And I guess, you know, I've spoken to a few, a few people who've been paying for the wrongdoing. And and I think, you know, currently, if I'm wrong, but a common theme seems to be once they once they they hit with it's like, well, yeah, I didn't actually realize the full impact of on my life of what I was doing. And I guess in the in those induction training, I'm trying to sort of bring that to them and say, think about this, you know, and you as you say, you need to be accountable, which, as we say senior management, accountability regimes, that's why they call that's why that word is used. We've we've touched on a bit of culture and conduct we've also touched on on COVID. I guess, what are you what's worrying you at the moment? Are there any any trends in the market that sort of you're concerned about things were going off the on or off the wrong on the wrong track? Yeah, no, I think today, specifically in securities markets, I think disclosure is becoming a major issue. I spoke to hedge fund a few years ago, and I got an email from like a billionaire hedge fund manager guy earlier this year. I thought, Okay, he's not he's not offering me a job. What is this? He said, Tom? Yeah, I had you when, a few years ago, we love to talk, I think you should really look at what's going on. If you another topic, what's going on in the market with spax, which are special purpose acquisition companies who said, I think we think there's fraud here. We're doing a lot of research. We're short, a lot of these. So they're betting the prices are eventually going to go down. As I looked into this, you know, I'm not allowed to trade stocks anymore. So I don't really follow the market as much as I used to. But I really started looking at the market dynamics, the machinations more this year, and if people aren't familiar, so a spec is a special purpose acquisitions company. It's like a shell company that's set up by investors with the sole purpose of raising money through an IPO to acquire other companies. So it's sort of a blank check company. So a SPAC is usually created by a team of institutional investors, Wall Street pros, you know, hedge funds are the sponsor, they have a fixed date to actually get the deal done. So you think about if they only have a year or two, to get a deal done, there's some type of potential conflict or negative incentive there where I'll just find, you know, if it's the 11th hour, I'll just find maybe more of a garbage high risk company to do a deal with and the most importantly, I think, for here on these specs is the target company is able to negotiate its own valuation for the company and the public market with the SPAC sponsor. Normally people might know and an IPO process, the markets going to set your valuation the bankers price it. And more often than not, the bankers are too low. You know, we'll see first day trading stocks up 100% right. And so there's been more thoughtful you know, direct listings happening. The last the last one or two years, but coming back to specs. So they set these valuations. And most importantly, the sponsors, the bankers, and the lawyers can make the deal with this high valuation and kind of cash out some of their investment at that higher valuation. And who's left with the liability is actually the CEO of the target companies that they've acquired. So the CEO, make presentations and give five years of forward looking financial statements. What you're not allowed to do as a public company, you can't IPO under current, I think pretty much every regulator in the world and start giving five year forecasts for how big your revenue is going to be that hockey stick graph for 2026. And the specs do it over and over. So this sort of well known hedge fund managers like says I should look into this, I start looking into it. I can't believe this is even allowed to happen in public markets. I don't want to name any stocks, but like there was a vertical farms, these vertical farm specs that was valued at over a billion dollars back in March. It had no revenue, negative gross profits, they were selling $1 apples, it cost them $5 to make a $1, Apple and CNBC or I should say, financial news network had the CEO pumping the stock early in the year, retail or being the sheep led to slaughter in this situation. And now the company has in the last few weeks. So those those five year forward looking statements, we're not going to come anywhere close to that. And the first publicly charged CEO we can talk about as a company Nicola, which is the electric truck company, which people might be familiar with where the truck rolls down the hill, and a multi billion dollar valuation. The SEC said okay, this is like, this is like fraud. And so the CEO was charged. And this fact pattern is happening quite a bit like I don't know what the SEC is doing right now in terms of their work. I know they're always understaffed, overworked, underpaid, but really like this is should be the number one priority. These disclosures, leading retail sheep to slaughter at these high valuations with financial news popping these issues is a real problem. And I sometimes scratch my head, when I see the regulators really focused right now is the number one priority, some of these ESG KPIs, which I don't want to be this is very important. It's good, they're looking at this. But I don't think to me, this is just my personal opinion. I don't think climate KPIs and listed companies should be the number one priority. Now for the SEC, like I think it should be these disclosures, these fraudulent, forward looking statements. If you have limited resources, please, please focus on protecting retail investors that, you know, the climate KPIs or Chairman gains, or just came out in Twitter last week, and said, we're really going to look into, you know, human capital disclosure, it's like, that's one of the last things investors need disclosed. They want to understand the financial guidance from the companies and how the compensation structures work better. So that's sort of like me on my, my sort of standing up, instead of looking at what I'm seeing now calling it out, you know, the more No, that's why not I, as you were, as you were talking there, my mind cast back 20 years to the tech wreck. And, you know, the.com bust, where someone would start up a company and, and, you know, these companies were having, you know, stratospheric valuations on on forward looking projections have no revenue or no, no profit making for some years, but then it was expected to go crazy. Now, if you happen to get into Google or, or Amazon or at that time, then great, you're probably picking back on your yacht in the Caribbean these days. But a lot of them just, you know, destroyed shareholder value. And so I mean, do we do you think we're kind of looking at Tech wreck? 2.0? Yeah, I mean, you feel feel free to not answer that if you don't have no financial advice, of course, are nothing but I just think history doesn't repeat, but it off if it often rhymes. And so I think what we're seeing today, in this specific disruption that we'd lost you for a sec is history doesn't repeat, but it often rhymes. So I think what we're seeing today in this specific sector of the market, will have many of the same outcomes where there's no revenue, negative gross profit companies, selling $1 tomatoes cost them $5. To make, it just doesn't the Business Economics don't work, the unit economics don't work. And I think we're starting to actually see it play out. So if you were shorting these stocks back in January in February, and this was part of the market, it really actually has provided some alpha for the short sellers, even though the markets been going up because the sector is coming down. But I look at these and I put on my old financial analyst hat and I think these are zeros or at least $1 stocks, and they're still trading at seven $8. So I think that's going to work itself out. But we also like to see the regulator's kind of stepping up and, you know, bringing more enforcement actions against these companies. I don't know if the CEOs because they have the liability don't understand the potential liability they're exposing themselves to when they're working with the bank. As the lawyers, the sponsors who are much more savvy than they are potentially. So I don't know if this is something they're not aware of, but like, when they go on, right and making these these forward looking statements, which are nowhere close to hitting, I think that has to be the number one priority of the regulator. At this point, if I was, if I was ever to run a regulatory agency, this will be my number one priority. But I guess if you've if you've started, I think it used to be the case, you know, I guess I'm going back 2030 4050 years, you know, a CEO of a company would have come up through through the company, you know, started and started a junior somewhere and been in the business or that industry for a while, and then made their way out. Whereas these days, you know, entrepreneurialship, as entrepreneurship is alive, and well, but if you're, you know, 26 years old, and you've, you've come up with some idea for an app and you're doing it in your, your mother's garage or something, you probably might not be aware of the you know, what you can and can't say, I don't know, just just a thought. Yeah, I think I think there's something to that. Look, Tom, we've, we could talk about this all day, and actually for, for the bonus content, we will go a little a little longer, but I think we should probably it's been a really interesting discussion and probably should, should wind it up and maybe look to have you back again, at some point, if you don't mind. That will be completely up to you. But look, thank you for so much for speaking with us today. And as always, it was really enlightening. But this is your business now. So if people want to get in touch with you all, learn more about your work. How can they do that? Sure. It's Tom Hart, and it's tipper x, calm tip Rx, that's all my informations there. I get presentations and during the pandemic, I've actually gotten more into creating courses for Association so I've been doing creating ethics courses too, so you can reach me there and find out more about me. Great, and to our audience look, thanks again for listening. And please don't forget to subscribe. If you have an idea for a show or have a suggestion for a guest that you'd like to have on. We'd love to hear from you drop us a line at podcast at nice atomized calm so that's podcast at nice act demise. That's Nic a CT imize.com. And don't forget we do have bonus content for every episode available at ACC demise.nice.com forward slash podcast. Look out for the next episode on your podcast service. And Tom. Thanks again for being with us on Lex talk in crime.