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Jean-Guy Côté
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Jean-Guy Côté
2021-05-21 12:37
Thank you very much, Mr. Chair.
My name is Jean-Guy Côté, and I am the chief executive officer of the Conseil québécois du commerce de détail (CQCD).
First, I would like to thank the members of the committee for inviting me to appear today. This will allow me to present some of the vision and analysis of Quebec retailers on Bill C-30 and on the budget tabled a month ago.
As you may know, the Conseil québécois du commerce de détail is an organization that represents the majority of Quebec retailers. The CQCD is Quebec's leading retail industry association. The CQCD's mission is to represent, promote and enhance this sector and to develop resources to foster advancement for its members.
Given the limited time available for my presentation, I will focus on only a few points.
As you know, the past 14 months have been challenging for retailers. The pandemic has accelerated a number of transformations already under way in the industry, including the shift to e-commerce. In some sectors, such as fashion, retailers have closed up shop and jobs have been lost.
The various programs announced by the federal and provincial governments as well as by the municipalities have addressed some of the needs of retail entrepreneurs. The speed with which they were implemented is to be commended, although we believe they should have been adapted as early as the fall of 2020.
The federal budget extends the duration of various programs, including wage support, income support and rent support that were put in place during the pandemic. These programs will be phased out over the summer. While the recovery, confirmed by the very positive retail sales figures from Statistics Canada this morning, appears to be well under way, some retail sectors are still very much affected by the revenue losses incurred during the pandemic. We hope that the phase-out of the various measures will be monitored and that government support measures will be provided again at the first sign of further economic stress.
This brings me to my main topic, interchange fees. These are fees charged to retailers by large credit card companies on all in-store and online credit card transactions. These fees are sometimes very high and are used to fund, in part, the credit card companies' generous rewards programs. As a result, all in-store and online credit card transactions are subject to an additional charge, usually paid by the retailer.
Canada has the unfortunate but justified reputation for having some of the highest interchange fees. In 2019, research conducted by the Federal Reserve Bank of Kansas City, the FED, showed that Canada was among the top countries for interchange fees. Interchange fees typically hover around 1.4% per transaction. In comparison, Australia has reduced its interchange fee to less than 1%, but the example to follow is the European Union, which has capped it at 0.5%.
The significant expansion of e-commerce in recent months has led to a sustained use of credit cards to pay for purchases. This practice will not disappear, but it needs to be controlled. Such control would be welcomed by the retail industry, but more importantly it would be a gesture of fairness. The credit cards with most rewards are often supported by the revenues from regular credit cards of those with fewer financial means. In addition, charities are regularly charged interchange fees on donation transactions. A cap would have no impact on the federal government's finances, but it would be welcome for the finances of the retailers.
We are pleased to see that the budget opens the door to a consultation on introducing concrete measures in the budget update. This was an election promise made by the current government. We are ready and willing to work together to propose innovative and positive solutions for retailers.
Our request is simple: cap interchange fees at 0.5%, as the European Union has done, and eliminate fees charged on the GST or other taxes on transactions.
In closing, I would like to thank the members of the committee for their welcome today, and I look forward to their questions.
View Gabriel Ste-Marie Profile
BQ (QC)
Thank you, Mr. Chair.
Ms. Cardona, thank you for your testimony, which was very poignant. Let's hope the situation changes.
Good afternoon to all the witnesses. My thanks to them for joining us today.
My questions are for Mr. Côté.
Mr. Côté, thank you for your presentation, which was very clear. First, I would like to come back to the interchange fees imposed on retailers by the credit card companies. This rate is 0.5% in Europe, whereas it is 1.4% and can even reach 2.5% here in Canada.
You are asking the government to take action in that area. Is that correct?
Jean-Guy Côté
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Jean-Guy Côté
2021-05-21 13:13
We have actually been asking the government to reduce these fees to 0.5% for a few years. The European Union has demonstrated in practice that it is possible to do so without automatically destroying the payment system.
It is important to understand that, in Canada, debit card payments use a fixed cost system. The fee charged to the retailer is a single cost, regardless of the quantity purchased or the amount of the bill.
For credit cards, the fee is a percentage. For large transactions, the fee charged to the retailer becomes quite substantial.
For small and medium-sized retailers, who don't really have the leeway to negotiate with the two large credit card providers that we are very familiar with, it's a little difficult to have the negotiating power to reduce those fees.
Large retailers, such as the major U.S. chains, have been able to secure attractive rates over the years. However, this negotiating power is not available to small and medium-sized retailers.
Given that the banking system is federally regulated, there is clearly room to control [technical difficulties] more creatively, and at zero cost to the government. This would still help retailers and purchasers, especially since the fees are imposed on charitable donations.
When a donation is made to any charity in Canada, a percentage of that donation goes into the pockets of credit card providers. In a sense, it is as if a hidden or private tax is attached to the transaction.
Transactions have become much simpler over the years because of the computer and digital systems in place whose costs have probably already been absorbed. So it's hard to understand why we could not have those interchange fees reduced.
View Gabriel Ste-Marie Profile
BQ (QC)
Your message is clear. Let's hope you are being heard.
Another point stood out for me. You said that large American chains are able to negotiate lower rates that give them an advantage over our retailers, which are often family businesses.
I also wish it had been implemented more quickly, because I feel that credit card payments, especially online payments, have multiplied with the pandemic.
Have you noticed an increase in credit card payments to the members of the Conseil québécois du Commerce de détail compared to before the pandemic?
Jean-Guy Côté
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Jean-Guy Côté
2021-05-21 13:17
We are seeing it a lot with e-commerce.
In stores, people can use both payment methods. Debit card payments should always be preferred, because they are more beneficial for both the consumer and the retailer. However, it is more difficult to pay online with a debit card.
Due to the substantial shift of purchases from physical locations to online purchases, credit cards have become a much more widely used payment method. The gradual disappearance of—
Jean-Guy Côté
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Jean-Guy Côté
2021-05-21 13:18
In closing, I would just like to say that people are using cash less and less. The same bills end up staying in wallets for a few weeks.
As credit cards are being used more and more, it's a good time to regulate everything for everyone's benefit.
View Annie Koutrakis Profile
Lib. (QC)
View Annie Koutrakis Profile
2021-05-20 16:54
Okay. Great.
Thank you for that, Mr. Kelly. All of our agents worked really, really hard across all the agencies, but I know that CRA has done a phenomenal job.
I have a question for Restaurants Canada with regard to lower credit card interchange fees.
Can you comment on how these measures are expected to lower the cost of doing business, especially for businesses that are increasingly reliant on e-commerce?
Chris Elliott
View Chris Elliott Profile
Chris Elliott
2021-05-20 16:55
Good afternoon.
It's a great question. I know that interchange fees have been such a critical issue for a lot of restaurant operators. The big challenge, of course, is that a lot of times, those interchange fees exceed what the profit would be off of the sale of that receipt. Sometimes those fees can be so extraordinary that operators actually spend more money and go into a loss because of that. It's a situation where, especially at this time, with most operators operating at a loss, it's become a much more critical issue.
View Peter Julian Profile
NDP (BC)
Thanks to our witnesses for being here today. We appreciate your service during this pandemic.
I want to come back to the issue that hit so many small businesses in my riding and right across the country: the issue of payment fees as part of retail payments. Small businesses are just being relentlessly gouged. There has been a move for some kind of voluntary capping of these fees.
Within the scope of the legislation, or within what the finance ministry is looking at in terms of regulation, is any due consideration being given to capping those fees? Small businesses often end up, through retail payments, with huge percentages of their sales actually going to the big credit card companies rather than to their bottom line when they're trying to get community businesses going.
Erin O'Brien
View Erin O'Brien Profile
Erin O'Brien
2021-05-17 11:35
With respect to the RPAA, there's nothing in this legislation that would give the government authority to address fees. However, there is a separate budget commitment that the government made within budget 2021, whereby it will negotiate lower fees with the credit card networks. It wants to ensure that small and medium-sized businesses enjoy the benefit of that fee reduction and, as well, that any fee reduction would not adversely affect the value of loyalty points associated with credit cards. That does fall under my area of responsibility, but it is not part of the RPAA legislation.
View Peter Julian Profile
NDP (BC)
Where do you see that in terms of timelines? Small businesses are really struggling, as we all know. A lot of them in my riding and across the country have closed their doors. There's no other way to put it, with the gouging that is taking place with credit card companies that are taking 10% of the sales, sometimes higher. It makes the small business folks really struggle for the bottom line, both to establish themselves and also to maintain themselves.
Where do you see the timelines in terms of those discussions and negotiations? What is the deadline that the government has set on that?
Erin O'Brien
View Erin O'Brien Profile
Erin O'Brien
2021-05-17 11:37
As stated in the 2021 budget, the government intends to come forward with next steps in time for the fall economic statement. We will be conducting consultations and will be studying this issue over the spring and early fall, and will come forward with a plan in time for the fall economic statement.
View Pat Kelly Profile
CPC (AB)
Thank you. My questions are right in the same vein as Mr. Julian's.
If I heard what you said correctly, that there's a plan to have a plan in the fall economic statement, that's as far as the government has gone in fulfilling the promise of reducing credit card merchant fees and their cost to small businesses.
Erin O'Brien
View Erin O'Brien Profile
Erin O'Brien
2021-05-17 11:39
The government intends to outline the plan in the fall economic statement. That's correct.
View Pat Kelly Profile
CPC (AB)
Okay. It's a plan, as opposed to tabling legislation that would implement the commitment it made in the budget.
Erin O'Brien
View Erin O'Brien Profile
Erin O'Brien
2021-05-17 11:39
We're giving due consideration to the critical paths and will be consulting in the near term. We will outline the plan in the fall statement.
View Pat Kelly Profile
CPC (AB)
I have another point, then, on this. You made reference in your remarks on division 8 to increasing competition in this area, which is really because the key to better consumer experiences is choice. How will this increase competition in this area? The regulations you're contemplating, or the objectives of the regulations you're contemplating, may well be sound and necessary, but not likely to increase competition. When you add regulation to compel businesses to all conduct themselves with the same processes and procedures, you're not increasing competition and you're not likely.... I'm hoping to see something that will help out our small businesses, who pay the brunt of transaction costs in retail.
I'll let you just maybe address competition and what you mean by increasing competition.
View Gabriel Ste-Marie Profile
BQ (QC)
Thank you for clarifying your intentions as regards division 8. That makes me feel better.
The second issue I want to talk about relates to credit cards.
In the budget, you laid out your intentions to limit interchange fees, or to ensure small businesses are treated more fairly in relation to big merchants, which have the ability to negotiate lower credit card interchange fees. In the budget, you indicated that next steps would be outlined in the fall. Why did you not go ahead and implement the measure through Bill C-30?
I would remind you that a Liberal member, Linda Lapointe, brought forward a private member's bill to address this very issue in a previous parliament. Her bill was delayed twice, before she was appointed to a position within the government. She then had to abandon the bill.
As I see it, action is urgently needed, especially since the pandemic has hurt small businesses and deepened the inequity between small and large businesses. Why, then, did you not bring the measure into force now?
From what I gather, putting it off means it may not be implemented until after the election.
View Chrystia Freeland Profile
Lib. (ON)
Thank you for your question.
My understanding is that, overall, you support the direction we've taken. That is a positive sign. Thank you for your support.
I agree with you that, from an economic standpoint, small and medium-sized businesses have been the hardest hit and greatly need our help. That's one reason, if not the main reason, why we made it clear in the budget that this was what we intended to do.
We understand that the COVID-19 recession hit small and medium-sized businesses incredibly hard, and we also understand that, because of the pandemic, they are now more dependent than ever on virtual transactions and credit cards. That is why we clearly signalled our intention to move forward on this. I hope we can count on your support.
Jean-Guy Côté
View Jean-Guy Côté Profile
Jean-Guy Côté
2021-04-20 16:21
Thank you, Mr. Chair.
I want to start by thanking the committee members for the invitation to come here today to talk about the positions and issues of the retail industry, the day after an important day in the parliamentary calendar. The tabling of a budget is usually one of the most significant events of the year in Parliament. We're very grateful for this invitation. It will also give us the opportunity to respond to the various parts of the budget in real time.
I've been the chief executive officer of the Conseil québécois du commerce de détail for four weeks. This is all new. I used to keep a close eye on the Canadian economy as a researcher and associate director at the Institut du Québec, which came into being as a result of a partnership between HEC Montréal and the Conference Board of Canada. Over the past few months, I've been able to keep track of the measures announced by the government and adopted by Parliament to resolve the economic issues surrounding the pandemic. As a result, I have fairly specific knowledge of the issues and the items tabled.
The Conseil québécois du commerce de détail represents thousands of retailers in Quebec. A number of these retailers are based in Quebec and have their head office in Quebec. However, some retailers are based in other parts of Canada and carry out many activities in Quebec. We share a significant number of challenges with other retailers across Canada. The Conseil also represents many small retailers, meaning people who have one or two stores, or one or two doors, as they say in the retail business. We're aware of the various challenges that retailers face, depending on their size, to ensure a proper return to business.
We're still in a crisis. The pandemic is ongoing and the lockdown is relatively challenging in other parts of Canada. In Quebec, some areas are more locked down than others. In some areas, certain retailers can't conduct business as usual because of the number of cases. The third wave is still very severe. The issues identified as of March 2020 are still ongoing. In the end, the programs in place are still just as relevant.
We can also see that the pandemic has affected industries in different ways. Health care and education have spearheaded the response to the pandemic. Tourism, hospitality, arts and culture, and retail suffered far more losses than other industries that were able to remain open and continue their economic activities. As a result, each industry's response to the pandemic and experiences during the crisis differed.
However, all our members are telling us something important: the pandemic comes on the heels of the completion of a major transformation in the retail industry. I'm talking about the digital shift that started nearly 20 years ago and that has dramatically transformed the retail landscape and the jobs within it. The pandemic is a powerful catalyst for this transformation.
Here are some key statistics. Over 11% of sales are done online, which wasn't the case before. In addition, 62% of people now use their credit card to make retail purchases, a much higher percentage than before. Lastly, 86% of people who shop online do business with companies outside Canada. They purchase from foreign retailers, mainly American. As you can see, the retail landscape has changed dramatically in recent months.
The federal government's response and the subsequent measures adopted by Parliament were still significant. In the early months of the pandemic, the response was very aggressive. In our view, this was necessary to meet needs. The Canada emergency response benefit, given its universal nature, was able to maintain the income of Canadians and increase the savings rate. This will make it possible for the economy to recover much more strongly than if nothing had been done. In addition, the Canada emergency wage subsidy has helped our retailers maintain the employment relationship with their employees. This was necessary in a situation where certain positions were severely understaffed. There was also the Canada emergency rent subsidy. This subsidy kept commercial establishments open when the pandemic subsided enough to allow some businesses to reopen.
Other measures could be put in place. I'll elaborate on that, if I may.
During yesterday's budget presentation, we were very surprised to hear that the issue of interchange fees, the fees charged to retailers for credit card payments, would be revisited. The government has the opportunity to regulate this issue. This would cost the government nothing and would give retailers and consumers some relief. It would give them the chance to participate in the economic recovery, which we hope will be as strong as possible in the coming months. I'm optimistic about the coming months.
I hope to be able to provide appropriate answers to your questions in the next few hours.
View Gabriel Ste-Marie Profile
BQ (QC)
You oversee the Payment Card Networks Act, so as I understand it, you have the authority to investigate interchange fees. I would like to know whether you have the authority to make that information public. I'll explain.
Apparently, because of the pandemic, the number of credit card transactions has skyrocketed, both in person, to avoid physical contact, and online, because people are staying home and making more purchases on the Internet. First, can you confirm this boom in credit card transactions?
As elected officials, we often hear that these transactions result in higher interchange fees for merchants. In addition, consumers seem to be more dependent on credit cards and, therefore, on credit.
Could you tell me what kind of investigation you have conducted so far or are planning to conduct?
Judith Robertson
View Judith Robertson Profile
Judith Robertson
2020-07-07 16:04
Perhaps I'll first explain where we fit in the credit card network operators, because it's a complicated area, with many parties.
The network operators like Visa, Mastercard and Interac also work with individual parties like the merchants, the banks that issue the credit cards, and then of course the consumers.
Your question is about the relationship and the charges between the merchants and the payment card network operators. Our role in that relationship is governed by a code of conduct that is principally designed to ensure that there is proper disclosure and information about charges so that merchants know what they have to pay. That's just a little background on our role.
We do agree, and we have seen reported the increase in transactions taking place, either by debit or credit. That is absolutely valid. We do not know whether that will continue or whether it's a permanent change or a temporary thing, but that is something that we are monitoring.
View Gabriel Ste-Marie Profile
BQ (QC)
Thank you.
As I understand it, then, a code of conduct requires that Visa and MasterCard honour their own commitments. If we wanted to change that, it would be our duty to pass a new bill in the House.
Comparisons are often drawn with Australia and the European Union, which regulate interchange fees. I will digress for a moment. In your response, you talked about the relationship between the merchant and the credit card company, but you also spoke of the consumer and their reliance on credit, which is reflected in their credit card usage. The banks and credit card companies were asked to be flexible during the pandemic, but we are quite disappointed with what we've seen so far.
With respect to the Payment Card Networks Act, how does Canada compare with Australia and the European Union, where legislative changes have been undertaken to rein in the credit card companies' power?
Judith Robertson
View Judith Robertson Profile
Judith Robertson
2020-07-07 16:07
I'm going to ask Teresa if she has some information on an international comparison of fees. As I say, we monitor compliance with the code of conduct, as opposed to setting fees or regulating fees.
Just before we see if Teresa has something to add, I'll just say that the relationship between the bank and the consumer is of course governed under the Bank Act. There are separate regulations there that we also monitor, including the disclosure of the cost of borrowing.
Teresa, I don't want to put you on the spot, but do you have any information on an international comparison of exchange rates, or is that outside our purview?
Teresa Frick
View Teresa Frick Profile
Teresa Frick
2020-07-07 16:08
Thank you very much. I appreciate the question.
I know that we do have some information on international comparisons. Unfortunately, I don't have that with me right now. I'd be happy to share it with you at a later date, if that's all right.
Gary Sands
View Gary Sands Profile
Gary Sands
2020-06-18 17:25
Good afternoon. Thank you, Mr. Chair.
I'm the senior vice-president of the Canadian Federation of Independent Grocers. I would like to thank the committee for the invitation to participate in your hearings this afternoon.
Independent grocers across Canada serve a myriad of communities in this country, particularly rural, remote and indigenous communities in which we are the only source of food for people in those areas. As such, independent grocers are a critical linchpin in ensuring food security for much of the country. Independents account for about $18 billion in sales and there are approximately 6,900 independent grocery stores across Canada.
We compete on a landscape that is overly consolidated at the retail, wholesale and supplier levels in a number of categories. At the same time, our members operate on overall margins of an average 1.5%, and that is much lower than other retail sectors. To stay on that uneven playing field, independents must differentiate themselves, and they do so by buy buying local, hiring local, supporting local initiatives and living in the communities they serve.
There is no playbook or manual that exists that could have helped guide the industry through this crisis. In the context of panic buying, labour shortages, the closing of most of the food service business, plus the increases in costs through the entire supply chain, this industry, for the most part, has responded very well by supplying groceries and supplies to Canadians.
That being said, there have been issues around the issue of supply that our members have encountered over the last few months that need to be addressed within industry and government. Independent grocers and independent wholesalers have encountered problems getting access to some products.
We understand that for some products there has been a huge spike in demand, particularly when customers want to buy enough toilet paper to last them for the next two years. However, when our members cannot access poultry, flour, eggs or other essential products, including fair access to PPE, such as hand sanitizers and face masks, then that not only impacts the ability of that independent grocer to continue to stay in business but the ability of those people, especially in more rural and remote communities, to access those essential products. The situation we've experienced has put that at risk and that is unacceptable to us. We hope it would be unacceptable to this committee as well.
Too often, over the past few months, we've had conversations with associations representing supply-managed sectors or companies in the consumer packaged goods areas, and with governments, that were taken aback when we would explain that what they were saying, in terms of supply, was not what our members were seeing. There were two different realities.
There are issues around distribution that need to be addressed and fixed. While panic buying has subsided, we could see a second wave, or at some point, some other pandemic or crisis could again arise. This means we all need to ask what we can learn from the past few months.
This industry, producers, processors and retailers, all responded with dedication and an exemplary commitment to ensuring Canadians had food and essential products. However, there is learning and things we can all do better in the event of another crisis. That includes consumers refraining from panic buying, but it also means wholesalers and suppliers have to ensure there is fair access to products for all retailers.
It also means governments have to ensure there are going to be mechanisms in place that allow our independents to access PPE supplies, both for the protection of their customers and employees. As well, all agriculture and food ministries, federal and provincial, must end their entrenched and systemic preoccupation with on-farm to the exclusion of off-farm. They are fond of slogans such as “gate to plate” or “farm to fork”, but the reality is, and it doesn't matter what party is in power, scant attention is paid to this end of the supply chain.
I would like to conclude by pointing out how the reality for all small and medium-sized businesses has changed and will change as a result of COVID-19. We know this because our members have been open as an essential service. We know what lies ahead for everybody, because we're on that road right now.
Increased costs to enhance consumer and team member safety through rigorous and stringent in-store cleaning, enhanced safety protocols, additional supplies of PPE, including installation of plexiglass barriers, are just some of our new realities. For independent grocers, because we're not part of the on-farm sector, we have received no government financial support unlike other parts of the supply chain.
As well, this committee in particular should be cognizant of the significant migration away from cash on the part of consumers to credit and contactless payments. This has meant, and will mean, a correspondingly significant erosion of the bottom line of most businesses because of the increased percentage they must now pay in interchange fees. Since large chains pay much less in interchange fees as a percentage than small and medium-sized businesses do, this erosion has a disproportionately deeper impact on those without the leverage of a Walmart to negotiate more favourable rates.
It is naive to believe that these billions of dollars siphoned out of the pockets of those SMEs do not have a huge impact on what Canadians pay for goods and services. Of course they do, but with the percentage of credit transactions now so much higher, this will make it a much more difficult journey for many businesses on their road to recovery in the next couple of years.
In the context of COVID-19, we would urge this committee to recommend that the government revisit the current agreement with the credit card companies, yet to go into effect, to reduce fees to an overall average of 1.4%. The payment landscape is much different now. All of us need to work together to put this country back on its feet, and credit card companies need to be part of that solution.
Thank you again, Mr. Chair and members of the committee, for the opportunity to speak with you today. We very much appreciate it.
View Peter Julian Profile
NDP (BC)
Thank you.
My final question is for you, Mr. Sands.
You raised the issue of interchange fees. Other countries basically have put handcuffs on the banks' gouging of people. I know of many small businesses that are impacted by the high cost of access through interchange. How important is it that the government, given that they've provided about $750 billion in supports to the banks, actually require the banks not to gouge small businesses on interchange fees?
Gary Sands
View Gary Sands Profile
Gary Sands
2020-06-18 18:31
We feel very strongly about it. I don't think there's an issue that's more important for all small and medium-sized businesses in Canada.
I do want to start off by saying that the government has brought about a new agreement, which was to go into place in April and has been delayed. That was definitely an improvement over the agreement that was in place with the previous government, but there's still much more to be done. The gap that exists between what the main street small businesses in this country pay and what a company such as Walmart pays is indefensible. It's inexcusable.
I want to go back to the grocery sector and have members understand the context of this. These independent grocers—I'm going to have to pick my sector, but I know that I'm speaking for all small and medium-sized businesses—are at margins of 1.5%. The new agreement that is supposed to come into effect is to provide an overall rate of 1.5%. That's an overall rate, and that's disingenuous, because the rates for premium cards actually drive that higher.
How do you make money? How does a small and medium-sized business in this country make any money when your margins are so tight? On the interchange fees, if Walmart can get 0.89%, why can't other small and medium-sized businesses in this country get the same? We've never had a clear, concise answer given. It's almost a deafening silence.
The amount of money we're talking about is billions of dollars, and I'm saying to this committee that we need to take another look at this, because in the post-COVID landscape there are going to be a lot of potholes on that road to recovery, and we don't need the credit card companies putting up any more roadblocks. That's what exists now. They have to be part of the solution. If they're not, they're part of the problem.
View Alexis Brunelle-Duceppe Profile
BQ (QC)
They are probably quite similar.
What I want to emphasize is that this is almost a monopoly. Many merchants have called me about interchange fees. I don't know if you know what those fees are. Right now, I don't think they're regulated. These merchants today pay 2% to 3% interchange fees. You may have different numbers. In Europe and Australia, it's 0.3%.
Do you think that would be a good way to—
View Wayne Easter Profile
Lib. (PE)
Alexis and Mr. Rudin, some of this area is really the government's decision to make.
I don't want to put Mr. Rudin in a spot of having to.... He has to abide by what the established government policy is. I think your question related to exchange rates is more for the finance minister's perspective rather than Mr. Rudin's.
Mr. Rudin, if you want to add anything to that, go ahead.
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