[Capital Stack]

Scott, actually Webbank is a not an fdic but has an industrial bank charter in Utah. They don't fund anybody directly, but act as funder of record on loans for Newlogic, and others, because of loan regs. Their not actually the money but the servicing the loans.

[jbrown]

The issue with using a bank charter to service a product like ODC and New Logic is that those companies are now subject to regulatory review. The OCC and state bank regulators have, by extension, the right to review, audit and inspect any 3rd party relationships. So in theory the OCC could go to CAN or ODC offices for an audit. The regulatory bodies also have the right to tell the bank to terminate any 3rd party relationships at their discretion.

Scott, actually Webbank is a not an fdic but has an industrial bank charter in Utah. They don't fund anybody directly, but act as funder of record on loans for Newlogic, and others, because of loan regs. Their not actually the money but the servicing the loans.

[Capital Stack]

The issue with using a bank charter to service a product like ODC and New Logic is that those companies are now subject to regulatory review. The OCC and state bank regulators have, by extension, the right to review, audit and inspect any 3rd party relationships. So in theory the OCC could go to CAN or ODC offices for an audit. The regulatory bodies also have the right to tell the bank to terminate any 3rd party relationships at their discretion.

Great point JB