Why Enova Wants a Bank Charter, Not Just Cheap Deposits with CEO Steve Cunningham

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Enova International has spent two decades using machine learning underwriting to serve consumers and small businesses who sit outside prime bank criteria, and its pending $369 million acquisition of Grasshopper Bank would give it a national charter for the first time. Steve Cunningham became CEO in January 2026 after nearly a decade as the company’s CFO, following earlier stops as a bank regulator at the FDIC and as chief risk officer at Discover. He joins the show to explain what a fully digital lender looks for in a nonprime borrower, why credit quality looks solid in his portfolio right now, and how he’s answering the senators and state attorneys general who want regulators to block the Grasshopper deal.

What We Covered

  • Steve’s path from FDIC regulator to Capital One, Harley-Davidson, and Discover
  • Moving from the CFO chair to the CEO chair six months in
  • Enova’s brand portfolio: CashNet, NetCredit, and OnDeck
  • Underwriting nonprime and near-prime consumers versus underwriting small businesses
  • The lift Enova’s proprietary models get over a plain FICO or VantageScore
  • Why all their products use different underwriting models
  • What Enova’s weekly vintage data shows about the health of the consumer
  • Why gas prices matter less to consumer spending than headlines suggest
  • How Enova is using generative and agentic AI across the business
  • The real thesis behind the Grasshopper Bank acquisition (see my podcast with CEO Mike Butler)
  • Steve’s response to the senators and state attorneys general opposing the deal
  • What banking-as-a-service adds to Enova’s roadmap
  • Where Enova wants to be by 2030

Key Takeaways

  • Enova’s NetCredit yields and losses aren’t outliers when benchmarked against what banks themselves report to the FDIC each quarter, Cunningham argues, pushing back on the “predatory” framing critics apply to the company.
  • The Grasshopper deal is primarily about simplifying a patchwork of direct state licenses and bank partnership arrangements, not chasing cheap deposits, though the deposit base is a welcome bonus.
  • Because Enova’s consumer loans repay every two weeks or faster, the company sees shifts in borrower behavior in its own vintage data well before those shifts show up in macro statistics.
  • Small business underwriting at Enova is built around the health of roughly 900 different industry codes rather than a borrower’s personal credit, making it a fundamentally different discipline than consumer underwriting.

About Steve Cunningham

Steve Cunningham is CEO of Enova International, a role he took on in January 2026 after nearly a decade as the company’s CFO. He previously served as chief risk officer and treasurer at Discover, CFO of Harley-Davidson Financial Services, held senior finance roles at Capital One, and began his career as a bank regulator at the FDIC.

Cleaned Transcript

Steve (00:10)
The only consumer product that we will have in our bank is NetCredit, which I mentioned before starts at 36%. The average yield there is in the double digits for that brand. And one of the interesting things about that is, banks file, they have certain regulatory filings that they file every quarter. If you were to take our NetCredit product and drop that into what banks file with the FDIC every quarter, and compare our yields and losses, we would not be the highest yield or the highest loss for that loan category, you know, the non-auto, non-credit card consumer loan. And I think most people probably don’t understand that because of the way we’ve been portrayed, which is not accurate and is lumped in with others who, you know, are not the same as us.

Peter (01:05)
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This is the FinTech One-on-One Podcast, the show for FinTech enthusiasts looking to better understand the leaders shaping fintech and banking today. My name is Peter Renton, and since 2013, I’ve been conducting in-depth interviews with FinTech founders and banking executives. Today on the show, I’m delighted to welcome Steve Cunningham, the CEO of Enova.

Steve took over the top job about six months ago after serving as the company’s CFO, and he brings an unusually broad set of lenses to the role, having started his career as an FDIC regulator before stops at Capital One, Harley Davidson, and Discover, where he was both treasurer and the company’s first chief risk officer. In our conversation, we talk about Enova’s portfolio of brands across both consumer and small business lending, and how underwriting differs between those two books.

We discuss what Steve is seeing in credit quality right now and why he thinks his portfolio gives him a much faster read on the consumer than the macro data does. We dig into how Enova is actually using generative and agentic AI, and we spend real time on the pending Grasshopper Bank acquisition, including Steve’s response to the senators and attorneys general who have urged the OCC to reject the deal. Now, let’s get on with the show.

Peter (03:13)
Welcome to the podcast, Steve.

Steve (03:15)
Hi Peter, thanks for having me.

Peter (03:16)
My pleasure. Great to have you. So let’s kick it off by giving the listeners a little bit of background. You’ve been a few big names in finance. Why don’t you hit on some of the high points of your career to date?

Steve (03:29)
So I’ve been at Enova for about 10 years. We can talk more about that here in a few minutes. But prior to that, I really made a few stops. I’ll hit on them for the highlights here, just so you have a little bit of an idea of the lenses that I look through every day when I’m thinking about running the business. But, way back I started with the FDIC as a regulator in the early nineties, really on the tail end of the S&L crisis. And I bring that up only because I learned an awful lot about the good and the bad. I saw a lot of interesting things in my time there out in the field, obviously with S&Ls, it was kind of a mixed bag. But I spent five years in Washington as well and got a really good idea of how regulators think about the industry, different institutions, how they manage the processes that they own. And an appreciation for the dual banking system as well. I jumped into Capital One after that.

Back in the days when not many people probably knew who they were, and really participated in the rapid growth there, including, you know, I was one of the few guys that was, you know, sort of knew commercial banking. And so, when that adventure into retail branch banking, I was asked to move down into New Orleans when they bought Hibernia National Bank. I was also a southerner. I grew up in the South, so I knew a little bit about Southern bankers.

And so it was an interesting time post-Katrina to help Capital One with that. And I did some other stints along the way with their auto finance segment as the CFO and payments. Before I moved to Chicago with Harley Davidson to really help them and their captive finance company work through some of the post financial crisis issues that they were having.

Interesting, you know, Harley’s a really interesting place. Not many companies have their brands permanently placed on people’s bodies, so it creates a great place, great culture. And then I jumped over to Discover, who was sort of early out of their spin from Morgan Stanley, and joined them as their treasurer to help them expand their balance sheet and grow. And I spent my last few years at Discover before I joined Enova as the first chief risk officer on their executive team, post-Dodd-Frank, and helped them really build out their risk management capabilities that were required sort of in the post-Great Financial Recession era. So I’ve been a CFO, I’ve been a regulator, I’ve been in the executive suite of a large company, I’ve been a CRO. So I kind of have all of those lenses, you know, I know when to brake, I know when to accelerate. And so I think it’s been very helpful as I’ve worked here over the past ten years, and we’ve seen sort of really dramatic growth and actually had a lot of fun doing it as well.

Peter (06:23)
I want to ask, now you’ve been CEO for about six months now, running the business, how is it different from the CEO chair than it was from the CFO chair?

Steve (06:35)
Yeah, I get that question a fair amount, particularly from people inside the company. But one of the things that David Fisher, our previous CEO, now executive chair, and our board did was work on a pretty long transition. My style as CFO as well was, I was a little bit more, I thought about my role as more of a co-pilot with the CEO. A lot of people think about the CFO as more of the accounting and numbers.

That’s really important. But I was also thinking more about strategically where we needed to be to meet the expectations of our outside shareholders and stakeholders. And so, for a couple of years I was really active in making that transition and stepping into a lot of things that most typical CFOs don’t. But with that said, the old adage is, you can prepare all you want, but until you get to the seat, you don’t really know what you’re in for. And I think that’s probably a good way to put it, like being responsible for everything that happens within the organization, from strategy to operations to culture, moving from being on an executive team with your peers to managing those folks, and sort of setting the tone more broadly. So I find it invigorating. I like it, I’m a continuous learner. I try to learn something new every day. I try to leverage those experiences that I’ve had both at Enova and other places to keep us on our toes and moving, you know, forward on where we want to be with the business.

Peter (08:10)
So then maybe we should just take a step back before we go any further and talk about the portfolio of brands at Enova, because you do have a few. Many of them will be recognizable to the listeners here. So, both consumer and small business, which is not typical in fintech, but take us through the brands and your overall approach.

Steve (08:32)
So it might be good to give a little bit of the brands in the context of the history of the company as well. Enova was started back, as a private company in 2004. So we’ve been around for a while, predominantly focused on payday lending as the first online-only payday lender with a brand called CashNet. A few years later it was acquired by Cash America as their online lending arm, and stayed there as a subsidiary, mainly with that brand until the spin to public, which happened in 2014. But just prior to that, David had joined, David Fisher had joined and started the diversification and expansion that you see today. And that started with another consumer brand called NetCredit. So CashNet focuses primarily on our, what I would call our subprime segments.

So these are, much more thin file, no file, much lower credit score folks who need credit but aren’t very well served at all, except by some higher cost, really higher cost alternatives. And we try to meet them with our CashNet installment loans and lines of credit. We don’t do payday anymore. And so the NetCredit brand was a move adjacent to that and more of the near-prime segment, where we also have the lines of credit and installment loans. So we built those brands, in particular NetCredit, over beginning in around 2013 and beyond, and expanded that through the years. The focus in that area is more on helping people with some establishing of credit with bureau reporting and helping them in their financial journey. We started around a 36% APR and the average is, you know, a double-digit type cost for these customers. And so those are the two large consumer brands that we have in the US.

They’re very well known. You may not know them because you’re not in our target market, but they’re very well known across these customers, very well respected. And we have a lot of brand equity across the customer sets that we serve. We had started around that same time, 2013, 2014, some small business lending capabilities. And we grew those, not as quickly as our consumer brands, but they were doing very nicely. It was a very competitive space prior to 2020, a lot of growth without necessarily thought on profitability. So it didn’t really match with the way we manage unit economics around our company. But as things started to settle out, we found some opportunities to continue to expand. And then with OnDeck in 2020, I would say we doubled down, tripled down on our small business aspirations. And today OnDeck is the brand that we go to market with, with our small business customers. Again, a very well-known brand across the different channels that we use and the customers that we serve.

Peter (11:34)
I interviewed David Fisher and Noah Breslow right after that deal closed back in 2020. And it was the pandemic and the PPP and everything that was going on back then were incredibly disruptive for small business lending. But it sounds like that opportunistic acquisition has been a real winner for Enova.

Steve (11:55)
You know, I call it, I’ve been around M&A a lot in my career. It was a unicorn kind of deal. I think everyone came out, you know, in a much better position. I think the shareholders of OnDeck did very, very well, if you go back and look at the price for which they acquired Enova shares and where those shares sit today. And, we acquired a complementary business to that consumer DNA that we had that, while not a perfect offset, it’s a great complement to how we go to market, that as you pointed out is differentiated from a lot of other companies we get compared to, which are typically just consumer and, in many cases, play in a more narrow space with more narrow products than we do. So we’ve created a pretty unique capability that allows us to navigate different operating environments and still deliver really strong results for our shareholders.

Peter (12:49)
So let’s just talk about underwriting for a minute, because I’d be curious about your approach. You’ve got, you know, nonprime, near-prime consumer, you’ve got the small business side, which, I mean, obviously these are still the consumer credit of the founder of the small business is going to be important. But tell us a little bit about, do you have like one engine, or do you have two completely separate sort of underwriting models?

Steve (13:17)
Yeah, so just to give a little bit of context, we are a fintech, and at the heart of everything we do is the technology and analytics that we’ve built and developed over the many years that we’ve been in business, as well as the expansive customer behavior data that we’ve developed over the years across both portfolios. So we have proprietary technology that allows us to be nimble in terms of how we, you know, make changes to product characteristics or go to market.

And we’ve invested heavily over the years in that, as well as our analytics engines. And so each one of these segments, our subprime, near-prime, small business, they’re all pretty different in terms of the customer characteristics. The products are different. And therefore the way you underwrite, and the credit models and the analytics, are, you know, slightly different. At the heart of it, though, is the discipline around how we underwrite.

But on the consumer side, obviously the consumer business is a lot more homogeneous. And by that I mean it’s very employment driven. And so, understanding, if you think about a consumer’s ability to repay, we’ve developed a lot of capabilities, in our investor relations deck on our website you can see where, for example, in our NetCredit business, if you were competing with us with just a VantageScore or a FICO score, we get about a 30% lift in repayment predictability from our proprietary models, which is the value of that experience and that customer behavior data that we’ve had access to and built over the years. So that’s kind of the thought around, there’s a lot of things that go into how we model, and the models that we use, and how we migrate those and redevelop them over time. It’s not something you do every day. You don’t need to do that.

But that’s very different than the SMB side of the shop, which I would say is much less homogeneous. So we are in all 50 states, we underwrite, and we lend into 900-plus NAICS industry codes. And so unlike employment, which can be a lot more cyclical, on the SMB side, there’s opportunities and risks at all points in the cycle. I can go back in COVID and tell you like back then, trucking and distribution, for example, everybody was buying online, those are fantastic businesses. Janitorial services today, those aren’t great businesses. So just to give you an example. So we underwrite the business. We’re not underwriting the proprietor. It’s not a personal loan. And so we are looking at the underlying financial capability of that small business to repay us.

We do take personal guarantees from the proprietors, which is a pretty common practice in commercial lending. But it is different from the consumer side in that we are underwriting these unique businesses on the SMB side.

Peter (16:19)
And would you say, right now there’s still a lot of uncertainty in the economy, is credit quality staying reasonably strong on both the consumer and the small business side of things?

Steve (16:30)
Yeah. So we had our call, our earnings call a couple of weeks ago, and that sounded a little bit like a broken record. There’s a lot of concern in the media and the press about different things that are happening. There’s a lot of headlines, but we tend to peel it down. And so if you take a step back on the consumer side in particular, the employment situation is actually pretty good. It’s been pretty stable. Unemployment claims have been low for a really long time.

And in addition to that, wage growth, if you just look at average hourly earnings, has been keeping pace or exceeding inflation for quite some time, which is really important for purchasing power and repayment capabilities. And you’ve seen over the past couple of months consumer spending is hanging in there pretty well, despite the concerns about energy prices, which I talked about a couple of quarters ago. And I’m not the only one saying this, but gas prices, spending on gasoline by consumers as a percent of income, is actually pretty low. It’s like a low single-digit spend. You wouldn’t necessarily think that, but it really is. And what you see is, if gas prices double, you don’t see the proportion of spending on gas double. People adjust their behaviors, and people aren’t static in the way they adapt to things.

So, what we see in our portfolio, and listen, we’re big enough that we actually have probably a pretty quick read on what’s happening, because our products, our repayment frequencies tend to be every other week or faster on our consumer book. They tend to be shorter duration, and the loss emergence is very quick. And so just as an example, every week the team and I look at what’s happening with the initial defaults on the vintages.

In the loans we’ve put out over the past few weeks, are they in line with the expectations that we have around our unit economics and the ROE frameworks that drive our decision making? It’s always a correction, right? So you’re never perfectly where you want to be. Sometimes you’re too aggressive, too conservative. So we’re making adjustments constantly in our environment. But it also kind of gives you a good read. Like if things were not going well in the macro, you would start to see it showing up more broadly across geographies and channels, marketing channels and other things. And that’s just not what we see. We see sort of our normal calibration. And I think we probably have a quicker read on what’s happening in the consumer, at least the consumers that we serve, than what you’d see before it shows up in the macro statistics.

Peter (19:11)
Okay, so I want to talk about AI for a minute. I mean, obviously Enova’s been using machine learning models for a long, long time, but I’m more curious about generative AI, agentic AI. How is that sort of being used inside Enova today, inside the small business side or on the consumer side or just internally? How are you becoming more efficient with those technologies?

Steve (19:38)
Yeah, we get asked this a lot given that it’s really entered the conversation a lot over the past couple of years. I talked about this a couple of quarters ago on our earnings call. We are typically not the one out there waving the flag on AI for a number of reasons, right? We kind of let the results speak for themselves. But we have been a machine learning shop for a long time, as you noted, which is really just applied AI. And so we feel like it’s much better for prediction.

So for example, on the underwriting side of things, I think you need to be careful letting the machines make all the calls without some human intervention, given the requirements around compliance and disparate treatment of consumers. If you just let the machines run the whole program, you could end up in a bad spot. But I would say everything that leads up to those decisions that feed into those models is fair game. And we’ve actually been using generative AI for a long time.

We, again, don’t go out and talk about it for a number of reasons, but in particular in the proprietary software development that I’ve spoken about, we’ve been using it in our coding environment for a long time, as well as in our contact center, which has allowed us to be a lot more nimble, allows us to be more efficient, very quick. But increasingly we have been using it across our organization. So every person in the company has at least one tool on their desktop that is, you know, their research assistant, their editor, personal analyst. But we have been applying it across workflows. So we have a number of agentic tools that apply across the organization in different spaces. It’s been focused on speeding it up for us. And increasingly, think about some of the applications for us.

So like we’re always staring at, what’s the top of the funnel, from a marketing point of view, and how are we converting all of that down to customers? And so, what you want to spend your time on is letting the machines gather the data and quickly understand the takeaways based on the relationships across those things. And you spend most of your time figuring out what to do next. Right. And so flipping that you know, that’s a good example of how we’ve been able to flip that a bit so that we spend a lot more time on what are we going to do in the market next, versus trying to figure out what’s actually happening. And so we are definitely ramping it up as it relates to efficiency, agentic management of our workflows, and increasingly, the insight-driven information that allows us to move more quickly.

Peter (22:25)
Okay, so I want to switch gears and talk about the Grasshopper acquisition. Grasshopper Bank announced several months ago, I think it was late last year. I interviewed Mike Butler, the CEO of Grasshopper, on the podcast last year. I’ll link to that in the show notes for everybody. But I’d like to kind of have you talk about the thesis here with the acquisition. Is this really about cheaper deposit funding? Is it about the national bank charter, or really about building a digital bank?

Steve (22:54)
Yeah, the answer’s yes, kind of to all those. But let me give you a little bit of context, because this isn’t something that we just started recently. It even goes way back to, if you remember pre-COVID, there was a fintech charter concept with the Office of the Comptroller of the Currency. And I remember making a trip to Washington to talk with the agency about that, prior to COVID. So we’ve had conversations with the OCC and the Federal Reserve and states and the FDIC, over many years, to think about a bank charter. And for us, it’s a bit about how do we simplify going to our market. So today we have direct licenses, we support commercial banks through servicing and partnership arrangements that want to make the types of loans that we made to customers in their desired footprints. So

think about the complexity of all those product variations on our operations and our compliance operations. So that was the thesis behind it. I mean, we have a robust balance sheet and our funding programs have worked really, really well. An added advantage really is the deposit capability. That wasn’t the thrust, which, in my experience, has typically been the thrust of a non-bank moving into the banking space. So we had it a little bit flipped. So, over the past several years, we were really focused on finding, and we decided a long time ago we weren’t going to go de novo. We wanted to buy an existing organization that provided complementary capabilities, that had infrastructure and skill sets that we could extend across the combined organization. And we talked to a lot of different organizations. We also did not want branches, because we’ve never had physical locations and we wanted to continue that digital-first journey. So when we found Mike and his team, who were part of the Radius deal with LendingClub way back, we felt like we found the right, you know, the perfect partner, kind of checked the boxes that I just described. And we were able to reach an agreement. So I feel, I mean, I’m really excited about the opportunities that are in front of us, and really a lot of the initial value that’s gonna come from the deal is just us simplifying our existing NetCredit brand that’s gonna be the consumer brand in the bank, and being able to simplify how we go to market there, and then leveraging the things that Grasshopper does really well, in particular the deposit-gathering capabilities that they have.

Peter (25:36)
So this move, as you are well aware, has not been without controversy. We’ve got some senators, we’ve got some state attorneys general, consumer advocates that have urged the OCC and the Fed to reject the deal. So what’s your response to the people that are very concerned about this?

Steve (25:57)
First off, I’d say, when you’re doing something new, as I’ve told our team, you’re gonna have people speaking out on all sides. That’s just the way it is. And we’re used to that. We’ve broken new ground over the years, and we’ve had people speak out against us that sometimes they don’t actually understand what we’re trying to accomplish. But if you take a step back, there’s about thirty percent of the US population that has, you know, a FICO score, for example, below 680, that are not really served by banks at all outside of maybe a checking account. So their credit capabilities are pretty limited. It’s a fragmented approach of trying to find people in their state that can offer them credit. And in many cases they’re left with alternatives that are not great. So our mission all along has been to try to serve those customers responsibly, with very disciplined approaches that tie into returns that are linked to market expectations, not trying to keep people tied up in debt forever. And we use very risk-based approaches, right? So it’s not a one-size-fits-all, as I described. We’ve got multiple price points and products across our brands. But I think most importantly, the thing that’s misunderstood, and some of the things that have been shared publicly, is that it’s not really accurately representing the bank that we’re creating.

The only consumer product that we will have in our bank is NetCredit, which I mentioned before, starts at 36%. The average yield there is in the double digits for that brand. And one of the interesting things about that is, banks file, they have certain regulatory filings that they file every quarter. If you were to take our NetCredit product and drop that into what banks file with the FDIC every quarter, and compare our yields and losses, we would not be the highest yield or the highest loss for that loan category, you know, the non-auto, non-credit card consumer loan. And I think most people probably don’t understand that because of the way we’ve been portrayed, which is not accurate, and is lumped in with others who, you know, are not the same as us. And so we are very proud of what we do every day, in terms of trying to find opportunities to fairly and responsibly serve these customers in the US who really don’t have a systemic way of meeting their needs and, in many cases, are left behind. And so that’s been our mission all along. We think the bank will extend our capabilities there with some of the efficiencies that will come along with that. And I think the administration has pointed to their desire to bring activities like ours into the national banking system. So we aren’t shying away from regulation. We’re bringing more regulation upon ourselves, and we welcome that, and the opportunity to become a national bank and a bank holding company.

Peter (29:08)
So then would you continue the Grasshopper, like the banking-as-a-service offering? It’s not a business that you’ve been in at all. Is that part of the long-term plan, to keep developing that business?

Steve (29:21)
Yeah, so from an Enova business point of view, NetCredit and OnDeck will be the two, lending products we bring to the bank. We’re not planning to run a bank as a utility. We’re planning to become a bank. Grasshopper brings, as you point out, some fantastic deposit-gathering capabilities, not just direct to consumers and small businesses, in particular, but the banking-as-a-service business. And I really like that business. I think they’ve done a phenomenal job building that business. We have a whole group of the population that likes to use apps to perform their financial services. And that’s really what the banking-as-a-service business is about, it’s like enabling some of these embedded finance providers that touch a lot of different customers to be able to provide those services, and being their bank. I think about it as another channel that I think is going to grow very quickly, and one that we’re pretty excited about. And, Mike and Grasshopper, they also have some lending capabilities that we like a lot. The SBA lending programs that sit sort of adjacent to OnDeck. They have a secured, you know, an auto loan. All of our loans today are unsecured. So that’s a nice adjacency to some of the things that we do on the consumer side as well. So this truly is about combining two organizations that have cultures that are very similar, and that’s really, really important to me. Culture is a really important part of being successful in a merger, and I feel like the two organizations are similar. And the bonus of having the complementary capabilities and products to become sort of the leading digital bank is extremely exciting.

Peter (31:08)
Okay, so last question. Let’s assume the deal closes before the end of the year, which is the plan. What does Enova look like by, say, 2030, and how will you know that the Grasshopper bet has paid off?

Steve (31:22)
You know, you look ahead a few years, we’ve talked about some of the economics that we expect just from the things that we do today. So I think, number one, we’re gonna be a larger organization. We are going to be a leading digital bank. And so what does that mean? That means we will have a suite of products beyond what the two companies have today that keep pace with the customer sets that we serve. So on the consumer side, and particularly the small business side. And, making sure that we are staying current with the convergence of payments and banking and lending. So the innovation roadmaps that we will pivot to very quickly after we close are going to sort of lay that foundation. I think everyone’s really excited to get to that work post-close. But I think we are going to be a unique organization that is meeting the needs of an underserved population, in an advanced way, with some of the best technology and people in the industry working with us.

Peter (32:27)
Okay, well it’s a great place to leave it. Steve, it was great to meet you and great to dive deep into what you guys are doing at Enova. And thanks for coming on the show and best of luck.

Steve (32:37)
Peter, thanks for having me. Great to see you.

Peter (32:46)
I think it’s interesting that Steve’s explanation of why Enova is buying a bank is a little different to what has become the norm. Most fintech lenders that go down this road are chasing cheap deposits. Steve said flat out that wasn’t the thrust for them. It was about simplifying a business that currently runs on direct state licenses and bank partnerships across dozens of product variations. The deposits are a bonus. That’s a meaningfully different reason to want a charter, and I think it explains why they were willing to wait years and be picky about the target. If the simplification thesis holds, it may end up being the more durable reason to own a bank. Anyway, that’s it for today’s show. If you enjoy these episodes, please go ahead and subscribe, tell a friend, or leave a review. And thanks so much for listening.