I'd say when you think of payments, most people are just thinking of I have a platform, that platform has clients, and those clients have cardholders and I just need to get money. That is easy as it is. Simplistically were just taking payments from a cardholder and funneling it back to the person accepting those payments but there comes a lot of oversight in that.

So when you think of oversight from a card brand perspective, and the brands all have ever changing guidelines that govern the way credit cards should even be taken from an authorization and settlement perspective, they also have guidelines when it comes to PCI compliance-- how are you building your environment? How are you engineering your software to protect that cardholders personal information and cardholder data? These items change constantly. And having a business model where in your payments facilitation journey accepting the fact that you're going to take on all of that yourself, you're going to hire that KYC officer, you're going to hire that PCI compliance manager, you're having to do it all. You're having to understand that and can constantly keep in mind.

So I would say the biggest risk of that is simply doing it wrong, is not understanding the complexities that come with that and not keeping the lines I of the relationships that are required. And then on the back end outside of the brands I would say there's compliance regulations where there's money transmission. Overall just rules and regs the Fed pushes down or banks have to ensure that you are transmitting funds appropriately and correctly, so you're not violating any money laundering or KYC, you're abiding by all the regulations. So biggest risk is one not understanding the amount of effort it takes to know all of those items and keep yourself attuned to all of those items as the future goes but getting it wrong.

Road to becoming a payment facilitator is a journey. A lot of organizations have to assess many different components-- is it monetization? Is it controlling the user experience toward your brand as a software platform is front and center to your clients?

Or is it just simply understanding and supporting KYC, AML, and all the regulatory considerations? When you look at that, organizations really have to assess where they feel their core competencies lie and where they feel they need support. That helps organizations in the here and now and also helps organizations grow and build their payment platform in the future.

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