Inside Enforcement in the Trump 2.0 SEC

What will SEC enforcement look like in the Trump 2.0 era? Emilie Abate, managing director at Iron Road Partners, joins the podcast to share how policy is shifting, how oversight of secondaries, AI and management fees is shaping up, and more.

Middle Market Growth: Welcome to Middle Market Growth Conversations, a podcast where middle market M&A experts, dealmakers, and other thought leaders discuss the trends shaping the dealmaking community. I’m Carolyn Vallejo, and this podcast is a production of the Association for Corporate Growth. Today we’re joined by Emilie Abate—she’s managing director of Iron Road Partners, and she’s here to tell us about what to expect from SEC policy affecting middle market dealmakers in the second Trump era. Emilie, welcome to the podcast.

Emilie Abate: Thank you so much for having me.

MMG: Thank you so much for being here. Let’s get to know you a little bit better. First, tell us a little bit about your current role with Iron Road.

EA: Sure. So, I’m a managing director at Iron Road Partners—been with the firm for, gosh, almost two years now. We are a regulatory compliance consultant, and a lot of our senior leadership team is former SEC staffers, a lot of former industry CCOs, and I think we bring a really unique lens to compliance consulting, just a lot of the really complex issues that a lot of our clients are facing. I started my career in public accounting doing private fund audits on the west coast, which has been a completely different animal than Wall Street, but I worked for the SEC for close to nine years, in the Chicago office, the Miami office, which they were two very different registrant pools. One was accidental Ponzi schemes; the other one was very real Ponzi schemes that I eventually helped form and lead the SWAT team within exams. And we were looking at anything from market-moving events like GameStop and FTX to a lot of the emerging risks that managers are currently dealing with around AI, alt data, and cybersecurity. So, you know, we’re a growing company and we’re having a lot of fun doing it, and I think we bring just sort of a unique regulatory lens to a lot of our clients.

MMG: Excellent. You’re obviously an awesome expert to speak with about some of the topics that we’re going to be touching on today. But first, just for a little bit of fun, tell me what your first job was.

EA: So, my first job, I was actually a cashier at the local mall for a store that was selling handbags and shoes. And my parents told me that I had to find a job because I was a little bit more shy then than I am now. I’m a little bit noisier later on in life, but I knew that I loved math, and so I applied for this job because it was a cashier role, and I wasn’t confident in going into a sales job. And so it was really a very fun, interesting job and a great way to sort of dip my toes into joining the real world and all that.

MMG: It kind of seems like an ideal job for a teenage girl, first of all, but also for a future professional such as yourself. Were there any lessons maybe that you learned as that cashier that you still carry into your work today?

EA: You know, it’s so funny because I love numbers and I still love numbers, right? And show me a fee and expense run, and I will tear it apart and find all the conflicts. And so I thought taking this job as a cashier, right? All I have to do is input the numbers and be very organized. And my accountant, Virgo self is very much, put me inside a box and I will create space for it. But I remember they had mystery shoppers at the time, and there was no sales associate apparently available for this mystery shopper. So somehow I ended up being the sales associate for this individual who I obviously didn’t know was a mystery shopper. There was a very specific framework, seven steps on how to sell. And obviously I was not trained in this because I was simply the cashier, so I had no idea that I was mystery shopped. And then, the manager came to me probably a few weeks or days later and said, you did a really great job despite the fact that you’re a cashier, but you missed one step. And that was the very last one when you’re supposed to tell them, “Come back and see us again soon.” And I think that taking that lesson away obviously I was not trained in this, but you have to sort of pivot in everything you do. The sales skills are obviously so important for every facet of life. And even as a professional, even if you’re not in a true sales function, sales is so important. But I love just a very formulaic, rigorous approach, and I think that’s a lot of what we bring to our clients at Iron Road. And so, you know, just making sure that we are seeing things start to finish and making sure you’re putting a bow on things at the end, right? Those are all things that we try to impart on our analysts and consultants. And so I think it’s really important for that structure. And so I was able to pivot and I was able to become a sales associate for probably 20 minutes, but I will never forget the mystery shopper.

MMG: The mystery shopper, I love it. Great. Well, let’s get into it. There have been some really major policy shifts at the SEC it seems since Trump began his second term. What are some of the biggest developments in your view, as they affect middle-market investors?

EA: You know, I think this is a great question, and it’s a very hot topic. Obviously, all of our clients are asking the same questions and we are watching this space so closely. I think interestingly enough, despite the fact that Atkins was confirmed earlier this year and has sort of already stepped into the SEC, I think we’re still yet to see what’s actually going to come out. Obviously we’re watching Atkins’ comments as comments very closely, but gosh, I worked at the SEC for close to nine years under three separate administrations, and it’s starting to feel like the pendulum is swinging a little bit further in each direction. With each administration change, we anticipate seeing some new rules get proposed likely in probably the next six to nine months, definitely custody. We’re sort of keeping an eye out, you know, maybe some around AI, maybe cyber. And then of course, you know, everybody’s hot topic, right? The retailization of alts and what we’re going to sort of see when it comes to retail investors and, you know, them being able to access private markets a little bit more easily. So we’re sort of waiting on pins and needles. There are still vacancies that need to be filled. We did see Brian Daly get confirmed or be appointed to the division of IM, I think it’ll be really interesting to see what he does there, because he brings such a unique perspective as an industry sort of practitioner rather than an academic. But I think a big priority is going to be enhancing retail’s access to private markets.

MMG: Yeah, we definitely want to talk about that and some of the other topics you just touched on, like AI a little bit later in our conversation, so we’ll get to that. First, it seems like there have been some staff reductions at the SEC this year. Could you see that having any impact on things like oversight or exams?

EA: I think it’s really interesting. There’s certainly a brain drain and I think one unique aspect to the SEC, which is different from probably a few other regulators is that it was really a great place to work and I think that there was historically very low levels of attrition. And from what we gathered, there were a number of folks who took either the early retirement or you know, some of the other packages that were being offered. And I think when we look at a lot of the expertise that exams and enforcement has around these, you know, 40 Act vehicles and anything that’s retail focused, they were not necessarily such a hot topic 20 years ago or even 10 years ago. And so a lot of that expertise, there’s certainly a brain drain at the SEC. So I think, even in the exam context, firms should be prepared to spend a little bit more time with examiners explaining concepts and structures and examiners are, you know, they’ve lost a lot of that sort of institutional knowledge as well. So even just private fund structures, right? And how deals are sort of structured and how they ultimately come to fruition, and the nuts and bolts, I think that that’s something that will definitely see from an exam standpoint. I think in that same vein, we’ll likely see longer exams. Examiners have got a ton on their plate, right? And they’re having to do more with less in terms of resources. And so I think you’re going to see longer tails on exams, which can be really frustrating and also as an anxious person myself, anxiety-inducing for a lot of compliance professionals. But just the reminder that, you know, examiners will likely have more on their plate and from what was already what felt like a slow process will be likely even longer. And I think there will probably be a big push around a lot of the lighter-touch exams to rack up some exam numbers, so probably a big push around newly registered firms, right? The SEC is going to come in within usually around 12 to 18 months and just evaluate your compliance program and have you been thoughtful about it, and are you addressing all of the risks or have you just sort of let compliance go by the wayside? Also, some of the lighter-touch check-in exams with firms that haven’t been examined in a significant number of years, we could see more of that. And just sort of looking at the compliance program more broadly, I think we expect to see a lot of that, but it’s just a lot of doing more with less. And we’ll still have to see once the vacancies are filled, sort of how this new SEC is going to take shape. But I imagine it’s going to look very different than the last four years.

MMG: So, I’m noticing a little bit of a theme popping up here maybe for middle-market investors. It’s a little bit of a wait-and-see approach when it comes to the SEC.

EA: Definitely. And I think there’s probably two schools of thought that I hear less with our clients on probably the lighter-touch end of the spectrum. But I think we’re always getting questions like, well, do we need to invest resources, right? And do we need to spend all this time and money on compliance? And I think one good reminder for firms is always that the SEC will generally take a one-to-two-year look-back period when it comes to the exam scope. Obviously they’ll expand scope if they see something that raises alarm bells. And so it’s sort of, yes, we can maybe pull back in terms of just oversight now, but you may be paying the price down the road two years from now. So, I don’t think that now is necessarily the time to just sort of ignore compliance, but I think there’s probably ways that firms can more efficiently use their compliance budget and just really narrow in on a lot of their risks, making sure that things are buttoned up from a basic blocking and tackling standpoint.

MMG: Now, the secondaries market has really been heating up lately. You know, there’s a lot of pressure to return funds to LPs. So, what are you seeing in terms of alternative exit avenues and how the SEC may be viewing these?

EA: Oh, so this is definitely a hot topic across the board. I think middle market in particular is facing a lot of challenges, but I also think that it’s a great time to be a seller in these markets of secondaries. And you know, we’re also seeing a lot of CVs pop up, but secondaries are really, really popular right now. We’re seeing a lot of firms jump into secondaries anecdotally. We’re also seeing VCs that are also looking to register with the SEC because they are no longer just doing pure VC investing. They’re also jumping into the secondaries market. And so I think there’s a lot of risks that firms need to consider when they’re looking at potential exits that are not, you know, anything that’s sort of GP-led that’s obviously going to raise eyebrows with the SEC and they’re going to want to sort of poke in there to the extent you’re under exam. Secondaries, there’s a lot of considerations as well. I think on the secondaries front, valuation is a really big one, and I think there’s just sort of this question out there where you’re purchasing at a discount, but then if it’s being valued using the practical expedient or the NAV, you’re likely seeing an immediate markup. And so are investors aware of this and are they aware of ultimately how fees are being charged? I think, you know, the SEC’s mandate as they start sort of start to shift a little bit, it’s still going to come down to investor protection. And if there’s any way to sort of quantify or prove those dollars and cents that we’re not disclosed to investors fairly or clearly, and is there a way to put any sort of dollar back in the investor pocket? I think at the root of the SEC, that will always be their mission. So, when we’re looking at secondaries, right, valuation is a big area of interest. It’s definitely an issue that a lot of our clients are grappling with as well. So that’s sort of probably the less complex of the two. I think when we’re seeing continuation vehicles pop up or anything that is sort of a GP-led flavor there’s so many different risks that compliance has to consider or the firm just generally should be considering, obviously valuation is a huge one. You have conflicts on both sides. And so what are you doing in terms of valuation? Are you going out to a third party? Are you making sure that we are providing the third party with all of the relevant facts so that they can come to their own determination? And are we actually using that value to conduct the sale? What do the disclosures look like? What are we actually telling LPs? Are we omitting anything? Are we being full and fair in all of the disclosures? You know, what does the auction process look like? Have we tossed out any bids that probably shouldn’t have been? You know, are you maintaining documentation around that process? And how much time are we giving investors to decide to sell a role? I think one thing examiners will always look at is that timeline. And it’s like, well, if this was sort of a rush decision and investors didn’t really have time to digest or ask questions, then examiners are going to start asking a lot more questions around you know, why this CV occurred. And then also another thing to keep in mind, and this is where there’s sort of maybe a disconnect or maybe just a need to sort of be more in sync between marketing and IR. And so, when questions are coming in from investors around the transaction, is everyone being shared the same facts or is anyone rounding certain numbers? Or is are we aligned in terms of how things are being communicated? Because it’s really a risk to the extent that examiners come in and they want to look at those communications and what was shared with investors. And one other thing that I will share on both of these fronts, firms should be really careful with internal communications, especially anywhere where there’s judgment or it’s a conflicted transaction regardless of the administration. The SEC still has the ability to pull emails, pull any sort of chats, right? And if they have an inkling that something is a little bit off, they will not hesitate to pull communications and just sort of start looking for that needle in a haystack. I think it’s come up time and time again that, oh, we have this email where it’s like, I really wish that we didn’t have something like this sitting in writing where it can point the SEC directly to it. So, I think just culturally and from a training standpoint, making sure that you’re training the investment professionals, training the operations team to really be careful about what is going into communications.

MMG: Let’s turn our attention to AI, which seems to be everybody’s favorite topic these days. I know you mentioned it a little bit earlier, so I want to dig into it. There seems to be a greater appetite at the SEC for reviewing AI washing and some of these other AI issues. What do you anticipate their priorities to be as they wade into AI territory?

EA: Yes, this is a great question. The team I used to work on at the SEC, they are continuing to spend—we also historically have spent—a lot of time just looking at AI. And when we first started looking at it, I personally was shocked at the amount of expertise that the SEC already had around AI. The SEC has been using AI-based tools, obviously not in an LLM format, but they’ve been using AI for a lot of trade surveillance projects and other ways reviewing ADV 2As and looking for similar disclosures that may be problematic. So they’ve been using AI historically in the past, but there’s a ton of AI expertise at the SEC, both in exams and in enforcement. And whenever the SEC is looking at something new and sort of novel, the first place they’re going to start is with marketing. I think we saw a lot of AI washing type sweeps out there and just how are firms purporting to use AI and are their statements aligning with how they’re actually using it? And so that’s usually the SEC’s first foray into how are we going to understand what the uses are, let’s just pull the marketing materials and start there.

But as we’re working with clients and thinking about how to design thoughtful compliance programs where you’re not trying to boil the ocean, you know, we try to be a little bit more commercial in our approach, but obviously we bring a little bit more of a conservative regulator lens. I think there’s probably two different buckets, or a spectrum really, in which firms should be thinking about AI. I think on the one hand you have a lot of back office tools that are probably driving a lot of efficiencies that are really great for firms, so that’s sort of on one end of the spectrum. The other end, which is where I think we get closer to where the SEC is really going to start digging in, is around investment decision making. And so anywhere that AI is being used on that front, that’s where I would dedicate a substantial amount of resources to making sure that we have policies and procedures around it and that compliance has signed off on this, obviously that IT has been involved from a cybersecurity perspective. What are we allowing to go into these tools? How are we using them? Do you have a big red stop button on your algorithm? All questions that the SEC experts will ask you. So I think it’s sort of looking at AI from those two lenses from an internal standpoint and making sure that you have policies and procedures that are designed to, you know, more so on the investment recommendation standpoint.

But nonetheless, I think cybersecurity is of top of mind for everyone. Those back office tools to the extent they’re intaking sensitive PII or investor information, or even just from a firm sort of reputational risk and proprietary information, making sure that those have been vetted as well. But I do expect to see more on the AI front from the SEC, in what form, you know, I could see exams coming in. I don’t think that we’ll see a ton on the enforcement front right out the gate unless we’re looking at sort of outright fraud.

MMG: You also mentioned earlier the retailization of alternative investments, and Chairman Atkins has also signaled an interest in opening up private investments to a broader range of investors, including retail investors, as you know. Talk about how you potentially see this taking shape.

EA: This is really interesting, and a lot of our clients are starting to explore the retail side of the product offering spectrum as well. And it’s definitely somewhere where we have sort of shored up resources and just intelligence on our side and significant amount of expertise just in 40 Act vehicles themselves. I think the first sort of indication was around the no action letter related to 506(c), where it really gave clarity around the steps needed to verify accredited investor status. I think what was really interesting about that first sort of toe in the water when it comes to opening up general solicitation and just retail in general, is how quickly the no action letter was pushed through. I think it was just a matter of days, weeks, so it was very quick, which historically I think is the industry all can appreciate, right? It’s just been a very long process that was sort of the first indication there. And I do expect to see a lot more 506(c) offerings than we have in the past. Generally, we’re looking in sort of the 506(b) territory, but given sort of this no action relief that’s out there, I think 506(c) is sort of the first domino or the first gate that’s been opened. But I do think that we will start to see rulemaking in the next few months around this in terms of the Atkins comments around the 15% threshold, whether or not that should be in place and why we would need a minimum initial investment requirement for retail. I think I would not be surprised if we saw rulemaking there. And so, I think there’s just sort of a big push, even from a client standpoint, right, and looking at a lot of the private wealth solutions and how can we sort of take this strategy and make it accessible to retail. So, I think it’s great news for firms because there’s so many ways to go to market Now, I will say that it does come at a cost and there is a significant amount of expertise that you need to be able to put some of these 40 Act products in place. Anything that’s going to touch retail, the bar is a lot higher. So, you’re going to need to invest in that framework and that expertise. But then on the flip side of things, I think it’s great, right? We can have more access to retail assets and all of that, but it does carry a significant amount of risk. I think if we look at headline risk, it’s going to come from your retail investors. I think there’s nothing worse than harming Main Street, right? Especially in the eyes of the media. And so, it’s sort of a double-edged sword because it’s great, we sort of are lowering the bar to entry and we can gather all these assets, but at the same time I think that you do carry some risk marketing to retail and making sure that you’re really buttoned up. The worst thing you can do is overcharge fees to retail or have to gate a fund and not be able to let investors out. So, I think you’re really going to have to be thoughtful about compliance and legal as these vehicles are launching and making sure that you have a compliance program set up to be able to oversee products like this. Because the last thing you want is a retail-focused headline and it’s definitely a transition for private fund managers, right? Because you’re used to sort of operating in this more principles-based environment under the investment advisors act. And once you start sort of wading into the Investment Company Act territory, it’s a lot more rules-based and it’s a lot easier to trip up a lot of the rules that are out there and there are a lot of them. So I think managers are really having to invest resources as they go to market on the retail front.

MMG: Now, let’s go back to exams. You talked a little bit about this—things like the brain drain, there might be a longer exam process, but let’s talk a little bit in terms of the SEC’s priorities here. How do you see examiners approaching things like management fees?

EA: Yes, I think that’s another great question. So sort of at a 10,000 foot view, I think it’s interesting, we are definitely seeing exams continuing to be opened and the number of exams that are conducted each year, that number historically has been reported to Congress. I imagine that they would continue to report that number. And of course the SEC does not want to say that we did less exams than we did the year before. You know, historically they’re able to get to about, I want to say, 10% of the investment advisor population. So they’re not able to get to a ton of firms each year. And so again, they’re having to do more with less. But interestingly enough, we are seeing exams still being opened. There’s been just a flurry in the last few weeks as well. And of course this is all sort of anecdotal, but I think we’ll see a lot of the, I don’t want to say lighter touch, but I think exams are sort of going to go back to their bread and butter. So, we’re seeing exams around very specific targeted issues where we’re not necessarily coming in and opening every single risk area, we’re going to look at one or two things and do a deep dive there. Also seeing exams, like new registrant exams coming in and saying hello or the SEC, here’s your 10 item request, let’s tell us what you have going on. Or either even things like a corrective action exam. So, examiners will come in and say, last time we were here we noted these three items in our deficiency letter you said that you would undertake these steps. Show us what you have done to correct this. And so that’s where you may end up with sort of a shorter timeframe between exams, again, sort of thinking about how examiners can get creative with doing more with less. So I think we’ll continue to see exams being opened.

I think one other interesting point with the return to office mandates for the SEC, we’re seeing examiners still go out in the field and maybe examiners would probably have a a shorter commute out in the field than maybe they would going into the office. But we’re definitely still seeing field work. So that’s something just for firms to be mindful of. I know in this post-COVID environment, a lot of exams have been virtual. I mean we’re all obviously operating in a very easy virtual environment, but examiners are still certainly visiting firms. And so I think it’s sort of business as usual for exams for now. We’ll have to see if there’s a new exams director, we have not obviously seen that yet. There’s likely going to be additional pressure to sort of perform, and so pressure on metrics and making sure that we’re hitting our exam numbers. So I think for firms it’s really important to clean up things where you can, especially big picture things like required books and records, make sure we have everything just sort of accessible and that’s not something that you want to alert examiners about if they ask for a record and it’s not available. Things like making sure your annual risk assessment is robust and you’re identifying conflicts, that’s something that examiners will look at. I think they’re going to come in sort of high-level, big picture, and just make sure that compliance is really on top of the business. But that said, conflicts will always be something that examiners will look for. Are investors aware of the conflicts that exist within your structure? Be it the use of an affiliate or the way that you conduct valuations or the way that you’re charging fees. Those are all really important things, so you want to be careful with things that are easy to quantify. And where we see this come up on exams typically is things like management fee calculations. We’ve seen a lot of examiners sort of start digging into LPAs and read how the management fee clause is structured and then go in to really understand what is going on to the extent that you’re charging on invested capital. So looking at things like what comprises the management fee base? Are you capitalizing transaction costs and have we disclosed that we are things like dividend recaps, how are you treating any ROC? How are you treating dividends? Are you reducing the management fee base or are you not? Those are all questions that examiners are asking. So, from a management fee perspective, I think we may see less of sort of an enforcement appetite to go into the granular management fee type calculations, but I do think that examiners are going to continue to push into things like fees and expenses. How are you allocating fees across clients? How are you allocating fees between the manager and the funds? They’re going to want to understand your process there. Again, fees and expenses are something that’s very easy to quantify and examiners will ask the advisor, what are your intention on recalculating this and repaying the funds? So that question’s always sort of out there. And then I think just in the market that we’re in, valuations are obviously of utmost importance to a lot of the firms out there and just given sort of market stressors. It’ll be interesting to see how examiners sort of look at valuations. Impairment has also has also been a focus of exams and that impact on the management fee base when we’re talking charging on invested capital, has the manager undergone a review of their portfolio and do you have any investments that are hovering at zero that or marked at zero that have not been removed from the management fee base?

I think it’s really important to be familiar with your offering documents and look at your partnership agreements and make sure that you know exactly how you want to interpret it. I think that’s really important, especially in this sort of period of market stress. And I think as we look at where we are in the regulatory cycle, we’re obviously seeing market stress, which usually leads to some sort of market event, which then increases regulation. But I think at the same time we’re also seeing an SEC with less resources than it previously had. And we are also seeing retail continue to increase their access to private markets. So I think in a way there’s a lot of things that firms really need to be thinking about because the SEC is certainly going to have their hands full and I think that they’ll really be looking in on those areas of perceived harm and that’s where just quantifying anything that can be quantified, you just want to make sure that you’re tightened up.

MMG: Yeah, there are so many things that from a compliance standpoint firms really need to be looking at. And you know, our conversation today, we just covered a ton of ground here, from the SEC’s staff reductions to its approach to AI to valuations on the secondaries market. So, kind of wrapping up our conversation here in this era of maybe friendlier enforcement, you still mention that it’s not the time to pull back on compliance, so do you have any additional advice for private equity firms and other midmarket investors when it comes to SEC oversight?

EA: Yeah, I expect under this administration and typically what we see under a Republican administration from an enforcement standpoint is less of the let’s sweep everyone into some sort of action that’s been conducting very similar conduct. I think we’ll see maybe one or two cases that really make an example out of firms. And so obviously you don’t want to be that example case. So, I think we’ll see less of sort of like the e-comm type cases where you’re looking at a broad swath of firms, but I think from just a nuts-and-bolts compliance standpoint, those books and records are going to be ever important. Looking at your compliance manual and making sure that you’ve updated it, looking at your risk assessment, making sure that you’re touching on all the changes to the business. I think as firms start to expand and you see more GP-leds and we’re seeing secondaries and maybe there’s sort of a shift in strategy, I think that’s all things that compliance should take note of and you can show an examiner, we have addressed this, right? We are aware of this, we are taking note of this, we’re overseeing it. I think those are some really important, you know, steps you can take. And then I also think conflicts management is really just the biggest piece of how to sort of help examiners understand the thoughtfulness that’s gone into your business. And so I think those conflicts logs and have we taken inventory of all of the potential conflicts that we have as the business is shifting and as we’re doing, you know, more unique transactions making sure that compliance and legal has really done the best that they can to either make sure that the disclosures are out there, whether it’s in the ADV or the offering document, and then making sure that you have mitigating controls in place to manage those conflicts. I think those are the heavy-hitting, big picture issues that you can use to help examiners understand the thoughtfulness that’s gone into your program. And the last thing I’ll say on this front is using a tool like a day one deck, this is something that the private funds unit at the SEC has historically asked firms for. There’s certain regional exam programs out there that have also made this request. It’s basically a PowerPoint presentation of your entire business. And when they send over the initial document request list this day, one presentation will have, gosh, I don’t know, maybe 15, 18 components that the SEC is asking you to sort of show them at their day one presentation. And then they will use that to inform how they conduct their exam. And I think it’s a really, really important tool that firms can use to sort of frame the risks to their business. The last thing you want to do is be caught on your back foot. If the examiners come in and they’re like, Hey, you have two weeks, give us your day one deck, oh my gosh, that is going to be a significant undertaking. So to the extent that you can sort of prepare this day one deck and present the risks in a way that shows that there’s thoughtfulness that goes behind a lot of the compliance controls and all of that, I think that that’s a really important tool that firms can use to sort of set the tone for the exam going forward. And we do it with a lot of our clients and I think, you know, it’s also just great practice in terms of how are we going to present to the examiners and put the PowerPoint up on screen and let’s just do a dry run through this. So I think that’s a really important tool that firms can sort of use and be prepared for just in case they get that call.

MMG: Definitely speaks to the importance of being proactive here. Emilie Abate with Iron Road Partners, thank you so much for joining us. It’s been a pleasure.

EA: Thank you so much for having me.

This transcript was prepared by a transcription service. This version may not be in its final form and may be updated.

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