Philip has more than 25 years of experience in the telecommunications sector and during that time has seen over $100 million in funding awarded to his clients. He has participated in litigation and policy resolution at both the state and federal level, including in front of the FCC. He has experience working with RDOF, BEAD, NTIA's Middle Mile, USDA's ReConnect, Community Connect, Telecommunications Infrastructure Loan, and ARPA's SLFRF and CPF programs.
Elizabeth guides the strategic direction and vision of Aristotle's ISP division, Digital Product Development Lab division, and Digital Marketing Agency division. She plays an integral role in the development of Aristotle’s business relationships, including partnerships, investment strategies, and joint ventures. Elizabeth is currently serving a two-year term on the FCC’s newly established Broadband Deployment Advisory Committee.
Pierce has been with LiveOak Bank since 2015, and has overseen over $100 million in spall business transactions. He and his team are primarily responsible providing senior debt solutions to companies in the broadband, internet service and data infrastructure industries.
Gary Bolton: And we're live. Well, good morning everyone, and welcome to Where's the Funding? Hosted by the Fiber Broadband Association and sponsored by Broadband.money. I'm Gary Bolton, president and CEO of the Fiber Broadband Association, and this is our fifth episode of 2023. This is a 12-part series designed to help you understand and navigate and obtain matching funds for broadband grants. The NTIAB program requires a broadband grant applicant to come to the table with a minimum of 25% matching funds, and a letter of credit upfront with the application. For many smaller providers and non-traditional providers and communities, this may sound daunting, but it doesn't have to be. This 12-part series designed to help you understand how and why meeting these requirements can be straightforward.
Gary: Last month we had a great session where we discussed partnerships, alternative sources, and pathways with Brian Vo, the Chief Investment Officer from Connect Humanity. Brian shared with us many different sources of private capital that can be used to expand your business. And if you missed it you can go over to the FBernie website under events or go to Broadband.money.io and watch the replay. Today on Where's the funding? We're going to focus on navigating the NTIAB letter of credit requirement with our guests, Philip Macres of Klein Law Group, Elizabeth Bowles of Aristotle, and Pierce Verchick of Live Oak Bank. And during this session we'll explore the issues with the MTI letter of credit requirements from a legal ISP and banking perspective. If you're concerned about this requirement, this is the session for you.
Gary: Philip Macres is the principal at Klein Law Group and has been for more than 25 years of experience in the telecom industry. Philip counsels companies on increasing profitability, reducing risk, and furthering their corporate objectives to effective and efficient regulatory litigation and transactional business strategies. Elizabeth Bowles is the CEO and Chair of the Board of Aristotle, Inc and ISP Digital Product Development Lab and digital marketing agency with corporate offices in Little Rock, Arkansas. Elizabeth guides her strategic direction and vision for the company, including partnerships, investment strategies, and joint ventures. Elizabeth is licensed to practice law in Washington, DC and Arkansas, as well before the Supreme Court of the United States, on a number of US courts of appeals. And prior to joining Aristotle's leadership team, Elizabeth was an attorney in when Washington DC law firm of Arnold and Porter, where she practiced in the field of intellectual property and commercial litigation with emphasis on international and technology law.
Gary: And Pierce Verchick is the head of broadband lending at Live Oak Bank, and holds roles in its servicing division, credit underwriting departments, and small business lending division. He's been responsible for more than $100 million in small business transaction. He's responsible for providing senior debt solutions to companies with the broadband internet service and data infrastructure industries. It's a focus specifically on senior debt facilities such as conventional term debt, as well as SBernie 7a loans. And the team also provides a letter of credit support for operators participating in federal government grant programs. The bank have actively participated in the Connect to America Fund II and the Rural Digital Opportunity Fund Auction Program. So welcome Philip, Elizabeth and Pierce. And for audience, please type in your questions in the chat, as we go, and we'll work those into discussion. So this whole NTIA letter of credit requirement is a thorny issue and has the potential to undermine the opportunities for the very communities and ISPs, yet the administration is targeting to be potential recipients of the BEAD funding. So given that our expert panelists today represent a law firm, an ISP and a bank, let's get started with some brief opening statements from each of our distinguished guests. So with that, we'll start with Phillip.
Philip J. Macres: So, yes, good morning. My name's Philip Macres I'm with the Klein Law Group and I'm a principal here, I have 25 years experience in the telecom industry, I've been assisting clients in broadband construction, funding applications and addressing other obligations under federal and state programs, including the FCC's RDOF, NTIA's BEAD, Middle Mile USDA's, ReConnect, Community Connect and, Telecommunications Infrastructure Loans, along with ARPA's State And Local Federal Recovery Funds and Capital Project Fund programs. In addition, I work on and I assist clients relative to efforts on the Hill in front of state and federal and state agencies on broadband deployment and broadband funding opportunities and issues. So over the past few years of assisted clients in obtaining over $100 million in broadband funding awards, and so I've been focusing on various issues relative to the BEAD program, and here I look forward to talking about a little bit more about the letter of credit and the issues there, and what we need to do to resolve those problems.
Gary: Thanks, Philip. Turn over to Elizabeth.
Elizabeth Bowles: Hi. So as Gary said, I'm Elizabeth Bowles. I'm the CEO of Aristotle Unified Communications. We are headquartered in Little Rock, Arkansas. We're a hybrid fiber, WISP provider of broadband services. We were the recipient of CAF-II Funds, Cares Act money, and RDOF funds. We have direct and firsthand experience with the letter of credit, both to the good and to the bad, and have been, we're actively looking at whether we're going to participate indeed. In addition to that, I was the chair of the FCC's Broadband Deployment Advisory Committee, which was a advisory committee designed to make recommendations for alleviating the digital divide, so I've had a lot of activity in advocacy both on the Hill and before the FCC.
Gary: Thanks Elizabeth, and Pierce.
Pierce Verchick: Thanks Gary, I'd like to thank Broadband, the Fiber Broadband Association and broadband.money, for hosting the event. My name's Pierce, I work for Live Oak Bank, we are a FDIC-insured bank located out of Wilmington, North Carolina. I head up our broadband lending group, which focuses traditionally on senior debt financing across the country, and we also have some direct experience with letters of credit in specific federal grant program. So excited to talk a little bit more about the banking perspective on these letters of credit and the requirements for the BEAD program.
Gary: Well, thanks Pierce. So just to kick things off, let's start with...
Gary: Maybe Philip you can start with explaining the letter of credit requirement under the BEAD NOFO.
Philip: Okay, I'd be happy to, Gary. So in a BEAD application under the BEAD NOFO, an applicant or could be an ISP or a municipality, would provide a letter from a bank. This is in the application, alright, that the bank meets the eligibility requirement from our bank. And it's a fairly straightforward process that the bank states that it will issue a letter of credit to an applicant ISP of 25% of the award, assuming the ISP has met all the bank's obligations to get the letter of credit. Then if the ISP or the municipality gets the... Awarded the grant, the ISP needs to, or the municipality needs to get the actual letter of credit from the bank. Now, to get the letter of credit from the bank, the broadband provider of the ISP municipality typically needs to have the full letter of credit amount in a liquid cash account with the bank throughout the construction period or until project completion, which could be subject to possible reduction upon meetings optional or service milestones based upon the state broadband offices and what's permitted by NTIA.
Philip: Now this letter of credit requirement applies on top of NTIA's 25% match requirement. So just say for example, you have a $20 million construction project, broadband construction project, that would require a $5 million match and a $3.75 million letter of credit, that's 25% of the $15 million grant that you're seeking. Which would mean that the winning company would have to have about $8.75 million in a cash account less than any in-kind reductions to the match or if allowed program income at the time the grant is awarded. So NTIA intends to strictly impose this requirement with limited exceptions. Now Evan Feinman, he had expressed this, that he intends to implement this pretty rigidly, and he mentioned this on a fiber broadband session just a few months ago, that there's going to be limited exceptions. So I just wanna emphasize that. So I hope that answered your question, Gary.
Gary: Well, thanks, Phil. So, Elizabeth as an ISP, what's the big deal? Just go to the bank, get a letter of credit. How hard could that be? [laughter]
Elizabeth: I'm going to start out by saying, "I get what the government's trying to accomplish here." This is public money, this is taxpayer money, they're trying to make sure that they're giving it to good actors, that they're giving it to financially solvent companies. But the letter of credit is a singularly bad way to go about this because the major problem, and Phil touched on this, is that the banks require cash. So I have to ask you, "If I have a $10 million grant that I get from NTIA, I've got to come up with, what is it, $2.5 million in a match and $2.5 million in a letter of credit, and so there's $5 million off the top. Why am I getting a $10 million grant that's going to cost me $5 million, if the project costs $10 million?" At the end of the day, I call it my sad math, after you take off everything, including taxes, ISPs are being asked to do a $10 million project for less than $4 million at the end of the day. It takes money out of one pocket, which is the pocket for deploying broadband, and puts it into another pocket, which is being held at a bank.
Elizabeth: And the only people who actually benefit from that, if you can call it a benefit, are the banks who are holding the money, and the federal government if there's a default. But at the end of the day, it's depriving companies of working capital, and this impacts specifically smaller companies, which are more likely to be all... Well, let me put it another way, there are a lot of small companies that are impacted by this, but most women-owned and minority-owned businesses are smaller companies. And so this disproportionately impacts minority-owned and women-owned businesses, small businesses, and these are the very providers that have been going out in rural America and deploying. And while there are some providers that have other options like co-ops, sometimes they have means to get letters of credit that don't require collateralization. For those of us who are not phone companies or co-ops, we have to actually come up with the cash. And so for a company that might be asset rich, but cash poor, this is a pretty hefty lift and an expensive one, because those fees that we pay on letters of credit, 1% to 5% annually, that is annually. So every single year of the five-year build, you're paying 1% to 5% of the 25% of the grand amount.
Gary: So Pierce as a bank that issues these letters of credit, what are your clients telling you? And tell us exactly how this works.
Pierce: Yeah, so just from the basics what a standby, irrevocable letter of credit is, it's just simply a document that the bank provides on behalf of an operator to whatever the beneficiary party is, whether that's NTIA, whether it's to the USAC or the FCC or any governing body that's administering the program to say that, "In an event of default that letter can be called at any time under the default provisions that the program allows and the bank wires the funding." So with the letter of credit it is a product that is very straightforward, very rigid, and the bank is required to send that money that it's holding. So it really is truly a very cumbersome product that the bank can allow for. Typically you hear about them in construction projects or in foreign trade, because there needs to be a guarantee that the performance is there or that the good and service is delivered.
Pierce: So with that being said, operators for that, in working with banks for these letters of credit, that are required by these programs, having a difficult time, because the banks typically only have one or two options of administering that. There can be certain circumstances where it's more of a relationship-based lending program that can be a little bit more flexible. But most banks are going to be requiring cash in the deposit account in the event of a default to cover the full obligation of the build because again, there are no restrictions for the size of company to build on the size of a project. So the bank, in order to mitigate that risk, is going to want cash in the account to fund that event of default amount, whether that's the face value of one year's worth in certain grant programs or in the NTIAB program, 25% of the project.
Gary: So... Go ahead.
Elizabeth: Can I... Sorry, there's, there are a couple of questions in the chat that are relevant to... That are sort of baseline, if I could jump on them? Craig Corbin asked if the letter of credit, "Do I consider... Do we consider it a user risk requirement for small providers?" That's, yes, I think it's horrible. And I could tell you the history of them and why they need to go and where they came from and why they're a bad idea. And I'm hoping we get into alternatives later. Convertible debt would be an option to raise funds, it's harder to get than you think. Hopefully we can get into that later. And then Kevin Collins asked, "Is the ISP or the grant applicant responsible for providing the letter of credit?" It is the grant applicant, not the ISP. So with the ISP it's the grant applicant, then it provides a letter of credit. But if it's the municipality that's the applicant, then there are some... That's one of the very limited exceptions that Phil was referring to.
Philip: Right, right. And so...
Gary: Yes, so Pierce, I can understand. So you have to have cash in the account, because if you get a call on that letter of credit, you have to like wire the money immediately, so that really kind of completely hamstrings the ISP or the applicant on having any cashflow, right? Whatever money is in that bank that is untouchable.
Pierce: Yeah. So the way to think about a letter of credit is it's really with three parties. The bank is issuing the letter of credit directly to the beneficiary, which is the grant program administrator. It is on behalf of the operator, so the operator cannot step in between that relationship which is why in the event of default, banks really are worried about the ability to recoup those funds or the ability to pay, because there is a time requirement. It is basically within business days, the funds have to be received based on the way the letter of credit works. And to the earlier point, and what we're eventually getting to here is that it is very stressful and it is very onerous on the operator, especially smaller operators to meet those requirements. Which is why down the line here of this conversation, hopefully as well we can talk about optionality, because banks really recognize that it's not a great product for a bank to partner. Banks would much rather focus on the senior debt construction financing piece, it allow for a third party to hopefully provide that sort of guarantee that the program's looking for to protect those taxpayer dollars.
Gary: Right. Let me add...
Philip: Oh, go ahead.
Gary: Just help me understand the... So the build time is about four years, right? And so NTIA is not going to be able to call on this until default is after four years. So you have the time you put in the application to the time you get the award, to the time you finish the build, all that money's tied up for all those years.
Pierce: Yeah. So the money would be tied up in a letter of credit situation for however long of period the milestone checks are. So in any program, they're going to establish certain criteria to check to do their own due diligence around completion of the project, making sure that money's being spent in a prudent way or the project is finished. And the bank, whether it's with this program or any others, are going to be restricted to altering that or revising that letter of credit requirement based on however often the due diligence can be performed to check that the work is being completed.
Philip: Right. And just to add to that, that's the NTIA and whoever the state broadband, they may agree to reducing letter of credit over a few years, depending upon if those milestones are met, so it could be reduced but that NTIA would have to approve that. And one thing I want to add to this is that filing the application, and it's like, I can consider this like running a marathon. When you file the application, you put all your engineering together, you put your financials, your environmental, you're meeting all the requirements, you get the letter from the bank saying, "Hey, I will issue a letter of credit to the ISP or the applicant so long as you meet all these obligations." And so you do all that and you submit the application, it goes to the broadband office.
Philip: The broadband office says, "Hey, I want to use you. You're going to get awarded the grant." And then when it once goes to perfect that grant, it comes to you and says, "Okay, I need the letter of credit." And you have to have that money in the bank and be ready to go with that letter of credit. So you don't want to be running this whole marathon, you're at mile 25 and say, "Hey, listen, I need the letter of credit. Where's the money in the bank?" And you just aren't able to satisfy that obligation, so you're never able to finish the marathon. You'll see the finish line right in front of you, but you won't be able to finish it.
Gary: So a lot of people in the chat are saying performance bond, why can't we just use performance bond? What?
Elizabeth: Oh, please let me take it. [laughter]
Elizabeth: So okay. So I'm going to give you a very brief history of where these letters of credit came from, but I'm going to start by saying this should be a performance bond. These are construction projects. Construction projects in every single other context are secured by performance bonds, not letters of credit. The letters of credit came out of the FCC and the FCC admits this. They had used them in the context of spectrum auctions, they make sense in a spectrum auction context. If you're bidding on something, you should be able to prove you have the money to buy it if you win the auction. So it makes sense to post a letter of credit in that context, because if you win the bid, you got to write the check. So, okay, makes sense.
Elizabeth: When CAF II came around for the first time in the universal service program, they looked at these new kind of applicants and they said, "Well, they're smaller, they're weird, they're cable companies, they're WISPs, we don't know them. They're not traditional phone providers. So we're going to come in and we're going to try to protect ourselves. What do we know?" And the guy who managed this spectrum auction said, "We know letters of credit, let's do that." And that's really how this started, was we're going to do a letter of credit because we understand it. Later they came up with justifications, they can be called immediately bonds and assurance policy, blah, blah, blah. But the bottom line is they just didn't know anything else other than that. If this program had been managed out of, let's say USDA, we would've never been in this letter of credit situation. So now you have NTIA looking at it and saying, "Oh, well it worked in CAF and they used it in ARPA, so now we're going to import it into the BEAD program."
Elizabeth: The problem is that the letters of credit are so burdensome, they're treated as debt, the banks are not flexible in what collateral they can take. And while I will rail against the banks, in fact, it's not really their fault because particularly smaller banks or community banks, these things get called, they've got to come up with the cash, and they may not have it on hand, if they don't have your money in the bank to do it. So I find some banks to be less flexible and more usury than other banks but at the end of the day, the banks are not the problem here, the problem is that this should never have been a letter of credit in the first place. So bonds are what we have floated to NTIA. We think that companies should be given an option, there are some providers for whom a letter of credit is actually a better deal than a bond, believe it or not, because they have lending institutions that qualify like CoBank, that will make it out as a loan instead of a bond, they don't require collateral. So my argument is that there should be flexibility. There are a number of ways to protect the American taxpayer in these programs and the letter of credit is the most burdensome on small businesses. So there should be other options that are not simply, "Okay, we're going to write this letter of credit."
Philip: Yeah, it's surprising that they don't have other options available. NTIA's mantra has been about digital equity and inclusion, but NTIA's letter of credit requirements, it's a huge obstacle for DEI when it comes to small, women-owned, and minority-owned ISPs that wanna apply for BEAD grants. And this is really particularly surprising when the NOFO itself passed that grant sub-recipients include a broad cross-sectional of sub-grantees that include among others, small, minority and women-owned businesses. These companies simply just don't have this spare cash hanging around to fund this letter of credit. But at the end of the day, the letter of credit is even problematic to the big companies. You'd look at a big company who wins maybe in 30 states and $2 billion in award, they're going to have to come up with $500 million match and $500 million letter of credit. And good luck to the guy that has to go and request that those funds from the CFO of that entity, he's going to be laughed out of the room maybe.
Gary: So it's my understanding the Middle Mile, NTIA's Middle Mile Program, that's kind of run into a little bit of letter of credit issue as well. What's going on with that?
Elizabeth: People didn't take it seriously. They thought, "Oh, we'll be able to get a letter of credit." Maybe they submitted a letter from a bank that said, "Oh, we'll do this letter of credit." But they didn't take it, they didn't understand that they actually had to produce this letter of credit. And so a lot of people, that's Phil's marathon example, they got right up to the, "Okay, you've been approved," only not to have their letter of credit in place, because they didn't realize some of these little catches that are involved, that it is a cash collateral, and they didn't have it when they got there. And at least some people at NTIA were saying, "Well, I guess they didn't take us seriously, but we really are serious about this."
Philip: So some ISPs, they didn't apply, number one, for the Middle Mile Program. I spoke with leadership at NTIA in the Middle Mile Program and some ISPs that did apply, they didn't sufficiently support the waiver or make a demonstration of extraordinary circumstances. Now, extraordinary circumstances, Evan Feinman has been clear, it's not stating that you're a small woman-owned or small business that doesn't have the spare cash, that's not going to cut it at the end of the day. He said those exemptions aren't going to apply. Maybe there'll be some application to exceptions for municipalities that just, it's contrary to law for them to issue a letter of credit, but those may be the limited circumstances. And there was no consistency across all the applications, when you have to show extraordinary circumstances, you have to make a real good demonstration why they're extraordinary. So at the end of the day, getting a letter of credit, it's not easy, and the Middle Mile has found that people were left... Caught up, flatfooted because they wanted to make the announcement in March, and then when they went to their companies, they said, "Oh, we need to perfect our letter of credit." And then realized that there's a lot more to do in order to get that or they have problems.
Elizabeth: It's also very important that when we went to speak with NTIA, what Phil and I did, there was, they had... We were the first people they heard from on this issue. And the industry as a whole, pretty much bar none feels that this is a bad idea. And you can ask Pierce about what the bank's opinion is, my understanding from the banks, I've talked to, is they don't like it. And the federal government does not understand how hard this is. The state governments start to get it, and we fought this fight in Arkansas, and we were able to get the letter of credit requirement removed from the last grant round under ARPA, and we were able to get a bond substituted for that at the state level, but the states are going to... Some states like Arkansas, they just follow on with what the federal government is telling them they have to do.
Elizabeth: So there needs to be more noise about this problem. It's sort of this sleeper agent that's sitting in there that people don't realize how absolutely critical it is until it jumps up and says, "Surprise, and I'm going to blow up your entire grant application and your entire project." So if you have the wherewithal to do it, getting your information on record that this is a bad thing for your company at the state broadband office or your municipality for that matter, it's just not a good thing. 'Cause you imagine if you took the letter of credit fees, that we've been paying under the CAF build, then we repurpose those into... That's in an entire network, an entire community that we have not built because we had to pay a bank letter of credit fees, it makes no sense at all. And bonds are better, too, because the subcontractors can bond, and then the subcontractor bonds protect the ISP, and the ISP can bond the bank and etcetera. There is a question in the chat specifically for you, Pierce, which is, "Will Live Oak accept a bond?"
Pierce: So I'd say that that kind of gets into the gray area where some banks are open to it, others are not. I'd say in Live Oak Bank's case, there is receptiveness to try and help the operator where we can. And where that means for the bond is we're going to be beholden to the program. So, of course, the bond can never replace a letter of credit, but a bond can act as collateral for what would be a letter of credit that the bank issues. The problem with that route, and some operators can maybe weigh this out with folks that they speak to as well is, it also kind of doubles the cost that you kind of have to pay, 'cause you have to pay for the bond. But then, of course, the letter of credit fee is still there, because the bank has to pay the letter. Now, of course, that fully secures the letter obligation from the bank's perspective, so that reduces the fee on that end. But again, the bond is securing what the bank is providing, which is the letter of credit, it cannot supersede and replace the letter of credit in itself until changes would be made to the program.
Gary: So, this whole thing, a lot of people in the chat and on the website have been saying that they're looking at grant, at anticipation notes and bonds to raise the cash to be used to get the letter of credit. But I think what you're saying is that's just going to crank up a whole ton of fees.
Pierce: Well, I think what would have to be viewed as is the bond itself costs money. And so the operator is going to have to pay a fee to obtain that performance bond. Or some folks have thrown out the idea of surety bonds as well but again, that's going to cost a fee. It's completely unrelated to the bank, unless it's acting as collateral. Then, of course, the bank records that bond as collateral for the letter. But the letter of credit has some small fee as well. So it's not like the bond itself could be your ticket to a completely free letter of credit. Some banks are still going to charge, whether it's a document fee, some are still going to charge a fee to issue the letter. So, I would say it's a bank by bank discussion because some are going to be open to that and some are going to say, "No, we don't accept the bond, we need cash." So that's probably a specific question that every bank may answer similarly but slightly different. But that's where, Gary, I wanted to make a comment that there may be a doubling of fee, because you got to pay for the performance bond but also at the end of the day, you have to pay something for a bank to issue a letter of credit normally.
Philip: Let me add the requirements are what they are, we have the letter of credit requirement, there's no alternative yet at this point. And so if folks are upset about the letter of credit, raise these issues with your associations. 'Cause, I've spoken with a lot of associations and they've said their membership has not raised this as an issue and it needs to be raised with them so that they can go to NTIA, they can go to the Secretary of Commerce. I'm raising it myself. Come reach out to me, be part of our coalition. But folks need to be more energized and involved in this, so that they ensure that they can participate. Last thing you wanna be doing is getting involved and doing all the work and then finding out that you can't satisfy this letter of credit requirement. If you're going to be awarded and they say, "We can't award you, because your letter of credit requirement hasn't been satisfied, because the cash isn't in the bank."
Gary: So, just to wrap up here, Elizabeth, as the ISP here. What you're suggesting is, "Hey, we need NTIA to give us an option, performance bonds or letter of credit, whatever works best based, 'cause not every ISP is the same, not everybody that's going to be applying for this. We need to make sure that we don't disadvantage the exact people the administration's trying to get the money to. And be able to serve every member of the community." Or, I'm paraphrasing, but don't let me put words in your mouth.
Elizabeth: Yeah. No, you're right.
Gary: That's it.
Elizabeth: So, we're out of time unfortunately, because there is so much that could be said. There are ways to protect the American taxpayer that do not involve letters of credit. The letters of credit are a bad idea. The banks don't like them, they don't serve the purpose. They hurt the communities we're trying to bring broadband to, and they make it difficult for smaller providers or really any provider to participate. You imagine if you're a company that gets $100 million out of this, that's a huge, enormous letter of credit that I think even some larger players would have trouble doing. It creates a lot of pitfalls that people don't really recognize, and there are two ways to attack it. And I'm going to... I said it earlier, Phil repeated it, it's very important to get loud on the subject. It is very important. There are three ways to go about it. One, get rid of the thing entirely, which I think is not going to win, but needs to be said. Two, is to expand the things that can be used to protect the taxpayer, bonds insurance policies for Pete's sake, there are insurance companies that do this, and letters of credit.
Elizabeth: Let the provider or the grant recipient choose what they wanna use. And three, let's expand who can issue the letters of credit. Why is it just banks? There are a lot of very solvent, extremely wealthy entities that can issue standby letters of credit that aren't banks. But because they're not on the Weiss Rating or because that particular bank's not on the Weiss Rating, they need to be solvent. Obviously you don't wanna get into a, "Oh, look, I picked the savings and loan collapse" or whatever. You wanna make sure that whoever it is is solvent. But there are... We've had a number of very high-net-worth, venture funds say, "Look, well why can't we just issue the letter of credit?" This is done internationally all the time. This whole obsession with it having to be a Weiss Rated bank narrows the number of people who can issue it. So we have three ways to come at this to attack it. I think having options is the best road for us to take, options on who can issue it, and options for whether you even need a letter of credit or something else you can use.
Gary: Everyone, Philip, Elizabeth, Pierce, really appreciate you guys sharing this really important issue with our audience. And hopefully people can follow up with you to help rally to find a way forward, so that every community gets served, and we're able to do this efficiently, make good efficient use of our precious taxpayer dollars. So, thanks for everything that you guys are doing to help close our nation's digital equity gap. And thanks to our audience, great questions. Thanks for being so active on our chat and look forward to getting back together next month, June 14th for our next episode of 'Where's the Funding?' So you're not going to miss that. We'll see you guys in June, so thanks everyone.
Philip: Thank you.
Elizabeth: Thank you.
Pierce: Thank you.