Debanking: The Newest Threat to Free Speech and Religious Liberty?

Caroline Bryant: Well, hello everyone and welcome to this Federalist Society Virtual Event. I'm Caroline Bryant and I'm Associate Director of Practice Groups with the Federalist Society. Today we're excited to host this webinar on debanking. Our moderator today is JC Boggs. He's a partner with King & Spalding's Government Advocacy and Public Policy Group, and co-leads the firm's state attorney's general practice. He helps multinational companies navigate the political and regulatory issues often associated with doing business in the United States and abroad. If you'd like to learn more about today's moderator, his full bio can be viewed on our website, fedsoc.org. After our speakers give their presentations, we will turn to you, the audience, for questions. If you have a question, please enter it into the Q&A function at the bottom of your zoom window, and we will do our best to answer as many as we can. Finally, I'll note that as always, all expressions of opinion today are those of our guest speakers, not the Federalist Society. With that, thank you all so much for joining us and JC, the floor is yours.

 

JC Boggs: Caroline, thanks so much. Glad to be here and thank you all for joining. As Caroline mentioned today, we're examining the subject of debanking. What is it? Does it represent a threat to free speech and religious liberty? Should we be worried and what should we do about it from a policy and law enforcement perspective? We've got a great lineup of speakers today, beginning with US Senator Kevin Kramer of North Dakota. Senator Kramer was elected to the US Senate in 2018 after serving three terms as North Dakota's at-large member of the US House of Representatives. He's on four different committees in the Senate, the Armed Services Committee, Veterans Affairs and Environment, and Public Works. And importantly for the discussion today, the Senate Banking and Housing and Urban Affairs Committee where I served early on in my career as council. Last year, Senator Kramer introduced the Fair Access to Banking Act, which now has 36 sponsors in the US Senate, including 10 members of the Senate Banking Committee, which has jurisdiction over the measure. Senator Kramer, thanks for joining us today. We very much appreciate you taking the time to kick off this important discussion. So debanking, what is it and what's your legislation proposed to do about it?

 

Senator Kevin Cramer: No, thank you for the opportunity and good to be with you and everybody on the webinar. Well, debanking is simply - the way I describe it is pretty basic- it's' when banks decide to categorically discriminate against entire industries who they view as being unfavored. And maybe the bank doesn't even view 'em as unfavored, but somebody does, somebody putting enough pressure on them, whether it it's investors or young employees - in many cases, I've heard that one from some pretty big bank presidents - but they get a lot of noise in their left ear and you have activist investors and whatnot that are saying, hey, you know what? We don't like coal. We don't like oil, we don't like natural gas. We don't like private prisons, or we don't like ammunition shops or gun manufacturers or whatever the case might be, the entire category or industry and says, "Well, so we're not going to bank them. We're going to debank them. We're not going to bank them. You're disqualified from getting money from us.”,  and they're starving these industries out. And all this really is, in my view, you guys is this is a political agenda where they're utilizing the leverage of the financial services sector to accomplish policy goals that they can't accomplish any other way. And of course this applies to lots of things, but in this case, it has to do with access to capital. And it's not just the traditional banks either. I mean, it's the investment firms and we could name 'em. It'd be pretty easy to do that. But anyway, during the second Trump term, which is when I came into the Senate, and yes, I did get on the Banking Committee, but as I remind a lot of people, Sonny Bono was on Judiciary, anything's possible. I don't have any particular credential other than the chairman really wanted me on the committee, and maybe this is why he did, because I see the things that maybe other people don't quite see.

 

I introduced it then, even back then, the Fair Access to Banking Act. But at the same time, I had the great honor of working with the Comptroller of the Currency at the same time on the rulemaking, Brian Brooks. And we came up with a pretty good solution. I think it's pretty basic, but the rule never got quite across the finish line. In fact, I think it's still under consideration, interestingly, not serious consideration, but prior to getting into the federal register. But basically what it does and what my bill, the Fair Access to Banking Act, which has been reintroduced, it was my first bill, this Congress, it was easy to get the 36 friends to get on the bill because after a couple of efforts and seeing that there wasn't really progress being made and that we were seeing categorical discrimination continue, it was important to keep it alive.

And what it really does is says you can't do that. And if you do do that, if you pick unfavored Industries categorically, regardless of how good a loan might be, regardless of the financial standing, the opportunity might be the best investment your bank could make except for the type of industry it was, if you do that, we're going to cut you off from certain aspects, obviously from the central bank. The discount window, for example, is one of the things, one of the carrot sticks, if you will, that we throw out there as a possibility. The Automated Clearing House Network, I mean there are tools that they benefit from that are under federal jurisdiction, not to mention FDIC insurance, which they pay for, but at the same time, pretty big federal backstop there when the taxpayers of the country are backing up your assets. So what the bill does, it applies this prohibition of categorical exclusion or categorical discrimination on banks that have $10 billion or more in consolidated assets.

 

We did create a threshold that, having said that, however small banks are getting the same types of pressure. I might just tell a little story about the first time I introduced it. The first year of the Biden administration, when I introduced it that year, and it got a whole bunch of signatures or a whole bunch of co-sponsors really fast, you guys. Again, they were more reluctant when we had a Republican in the White House, but not reluctant at all once we did not. And they saw the onslaught of these very high profile banks discriminating against categories of industry, the five largest bank presidents called - all within a week - and all were in to see me within another week or two. And I'll never forget the first one was Jamie Dimon, I think the next one was David Solomon, and they just kept - Brian Moynihan - we probably don't have time today, but it was interesting to hear from them directly.

 

And on one hand they were sort of asking for help and the discussion went something like, "Well, I've got all these 25 to 35-year-old employees in there, about half of my employees are young and they just don't understand guns or they don't like fossil fuels. And so they're really pressuring us and we've got these investors, these activist investors, and they're putting a lot of pressure on and yap, yap, yap all this noise." And I said, well, to all of 'em, I said, "Look, you're getting a lot of noise in your left ear and our problem as conservatives, and you all know this probably better than I do, we're not very good at noise." We just sort of adjust, if you will. And I said, "I will promise you I'll make as much noise in your right ear as all those 25 to 35 year olds are making in your left ear."

 

If you need cover, I'll even provide that for you if you do the right thing by providing you, if you have certain climate goals or you have certain GHG goals or whatever your weird goals are, ESG, I'll try to help you by showing you projects and whatnot that clean up fossil fuels or whatever your goals might be. But you can't just categorically exclude entire industries - or in the case of energy, fuels. I mean, Citi had the worst ESG statement I can imagine, and Jane, she was the last one to come see me, but she was also the least responsive, but where they just literally say, "We won't do coal. Anybody that generates their electricity from coal, we won't bank." So that was the premise of this for me, although the guns and manufacturing industry as well was really, really important to me, when I went after this.

 

I will say this, that we've seen some change in some behavior. You've seen a little change in comments from some of these bank presidents, a little bit of toning down of some of the language in their annual reports and in their ESG statements, things that - partly because you guys, I think what they're finding out is while I'm not only a loud noise in their right ear, some of the investments they're making versus the investments they're prohibiting aren't as good as the ones they're prohibiting, that it doesn't do any good to debank a company that generates its electricity from natural gas or buys electricity from a utility that generates natural gas. I mean, that's a dumber idea than having a manufacturer that doesn't have reliable electricity because they can only buy it from a wind farm. Really a nonsensical approach to reasonable banking in my view. The other problem, and I know you guys are going to get into this of course, is that with the lack of a federal response to this, states are coming up with their own debanking prohibitions and laws, and some of 'em are pretty big states, as you guys know, and I know that's part of the agenda, but that's got a lot of interstate commerce ramifications to it.

 

It's obviously got a lot of the larger bank organizations that are concerned obviously about how that's going to play state to state. This is clearly an interstate commerce issue and it's clearly with the FDIC and the Federal Reserve and the obvious connection to regulation and a federal nexus really calls out and I think demands a federal response. And so that's what I continue to work on. We'll see where it goes ultimately, but it does gain a little momentum each congress because you're just not seeing an appropriate response. And until they sense that there's a downside to their behavior, the noise in the left ear is always going to be louder than what we can provide. So that's kind of where I am. We're always looking for support wherever I can get it, but I don't see anything happening as long as Democrats have the majority.

 

JC Boggs: Well, I know you got to go. And on that point though, there's 36 Republican sponsors in the Senate, 88 in the house, all Republican, both chambers, anybody on the other side of the aisle interested in doing this to make it a bipartisan bill?

 

Senator Kevin Cramer:

Yeah, there hasn't been to this point. And Joe Manchin's leaving, he's one that probably, he'd be somebody I could probably get at this point. And Senator Sinema, she's on the Banking Committee with me and she's resisted it as well. And probably that's her sincere position. I think a little less so with Joe. Beyond that, I've just never gotten any traction from Democrats and maybe if we got a little more prescriptive in some areas, but oil and gas is one thing, guns are quite another for them. They have a really hard time in that space, at least in the Senate. So I don't know, but I just think what I'll tell you, what I really hope for is I hope for a Republican president and a Comptroller who on day one, he and I can start working on - he or she - and I can start working on a rulemaking that actually is doable and durable and given Chevron, given the Chevron case, given the New York Financial Services Agency or whatever they're called, the case - Vullo, NRA v. Vullo, I mean there's real opportunity here I think. I do think there are all kinds of opportunities that we - if I started going off on Chevron,the  major questions doctrine, I think they're some of the greatest things that have happened to America since the founding, at least certainly since this decade and this century, really.

 

JC Boggs: We'd love to have you come back and talk about that another time in another session.

 

Senator Kevin Cramer: Believe me, those are the things - there are probably two of us in the Senate that think about Chevron every day up here - and the other one's Mitch McConnell. But anyway, I wrote a piece for Harvard a couple of years ago on all these cases before they were settled and the opportunity that it presents for restoring authority, and that's really what we're talking about, restoring authority back where authority belongs, with the elected officials, states, individuals with their own private property rights, things like that. How profound, right? But anyway, I do think Chevron and NRA v. Vullo do present some pretty good opportunities to clean this mess up.

 

JC Boggs: Yeah. Well, Senator, thank you so much for joining us today. I know there's a vote on the floor you got to get down to, you don't want to miss that, but you've been generous with your time On behalf of all of us here at the Federalist Society, thank you very much

 

Senator Kevin Cramer: Oh, it's my pleasure. And thanks for all the work you guys do. I mean really you're the go-to on so many of these things and we appreciate your interest in the issue.

 

JC Boggs: Thanks again. So I'm also delighted to welcome former Senator, Governor, Ambassador Sam Brownback. Ambassador Brownback served in the US Senate about 15 years before deciding to run for governor of Kansas. He won and served two very successful terms as governor of the state. As a brief aside, I actually had an opportunity to go down to Topeka for the first inauguration. I think it was January, 2011. Great event. I think there was some interest in hosting the event outside on the lawn and with the capitol in the background, but we had a big blizzard, so that didn't happen. The Lord had other ideas that we were inside, and if you haven't been there, the capitol at Topeka is one of the more beautiful - I think of the ones I've seen - and ornate capitals in the country, great history to it, so I was pleased to be there and it turned out to be despite the snow, a picture perfect day, but following two terms as governor, Senator Brownback served as Ambassador At-Large for International Religious Freedom, and he continues to work with coalitions around the globe to promote and protect the fundamental human right to religious liberty.

 

And in that context, he founded the National Committee for Religious Freedom, a 501C(4) nonprofit organization that exists to proactively defend the constitutional rights of religious freedom. And today, Ambassador Brownback chairs that organization, though I know everyone listening today is saying, "What a great American, what a stellar career, member of the House of Representatives, US Senate, governor and ambassador", and yet you were debanked. We're not talking about guns and fossil fuels, but religious freedom. So one of the largest banks in the United States where the National Committee of Religious Freedom kept a modest checking account to pay for its employees and some other things suddenly closed that account with little or no reason. So Ambassador, what happened?

 

Sam Brownback: I wish I knew. I still wish I knew what took place with that. And thank you JC for the very generous introduction and thank you Federalist Society for all that you guys do. You are fantastic. I've seen you during my political career really mature into just a fantastic organization that's helped so much the cause liberty in the United States, JC and others - like I said, I wish I knew, we formed the National Committee for Religious Freedom, as you say, a 501C(4) organization to fight for religious freedom in the United States. I had just come off of a stint fighting for it internationally and was seeing us losing ground here at home. And any ground you lose in the United States on religious freedom gets magnified overseas. It's just that this is the bellwether. You got to get this one right and solid or else you're going to continue to have growing problems around the world, which we have.

 

So we formed it, opened an account with Chase Bank on April 15th, 2022, and I want to be real precise on my dates. I know it's a lawyer group and you're interested in the facts. Three weeks later, Chase Bank sent a letter which we didn't get for some time, dated May 6th - so we got it three weeks later - notifying us that they had decided to end the relationship with the NCRF effective May 9th. I only found out about this on May 19th. Okay, May 19th, I go into the bank to make a deposit. We're trying to get this organization set up and they said, I'm sorry, we've closed your account. It's been done at corporate, it's non revocable and we're not supposed to talk about it.

 

That was the note on the computer screen that the employee gave to me and I go, what did we do? And they said, I just read you what I can tell you. It was made st corporate, it’s non revocable. We're not supposed to tell the customer anything about it. Checking account was closed, and we received the funds from it May 25th. So this is very shortly after we opened the account. When contacted, Chase described the decision to close the account as one coming from the corporate office as I mentioned. Finally, we just kept peppering Chase about it. We had our executive director at the time had worked for Chase at one time in his young career, and so he kind of knew the places to push on and kept peppering, Chase, why'd you do this? And finally, a member of the executive office at Chase, New York on June 8th, Chase said they would reconsider providing the NCRF disclose all our donors, provide a list of the intended fund recipients for the next election cycle and the full details of the NCRF, how they would select our pro religious freedom candidates to support. And we said, "You don't require that of other people. We're not disclosing that kind of information."

 

They said, "Okay, well then we're not going any further" and Chase then - we kept pushing it - Chase then contacted me through a former staff member of mine that worked for Chase Bank and assured us, we always ask for donor lists, and I'm sorry we did bad customer service with you guys, but they kept going on. On October 21, Chase sent a letter stating that something that I and the executive director had said at the opening had triggered them looking into the account for money laundering and domestic terrorism. And we said, well, what was it? And they didn't disclose anything. They just said we were investigating it and they didn't give us the standard 60 days to get the account cleared up, they just closed it. We on multiple occasions asked to talk to key people on it. Then eventually Chase came up with a final answer.

Well, they said, I'm a politically exposed person and therefore that's why this was closed. Well, "politically exposed person" is actually a term of art that means a foreign elected official. And at the time I was neither foreign nor elected, and so we just kept on going, ADF and others took a shareholder resolution forward that Jamie Dimon had to answer finally at one meeting and he said, no apology needed, even though they had apologized earlier for bad customer service, and we didn't do anything wrong. And so it just stopped at that point. My point in saying all of this, I wanted to get the details in front of you. There was a couple. Number one, we need to stand up to these things because once we did and we were public about it, I was contacted from anywhere from 12 to 20 different groups saying the same thing had happened to them and they just went away quietly.

 

They said, "This could hurt our fundraising, this could hurt the organization if it got out, so we'll just kind of shovel off somewhere else." And that's the exact wrong answer because then the activity just keeps taking place. But it's happening a lot. And it's not just banking, it's deinsurance, it's deplatforming. It's a whole series of things that you can't get into the economic activity of the day if you're not tied into it. And then secondly, we've since formed a National Council for Religious Freedom, which is a 501C(3) organization, and we do monthly activist meetings to communicate with each other about what's taking place in various sectors of the society, whether that's banking or healthcare or schools or government or businesses generally to try to push back against this cultural push to really suffocate people of faith in the society. And just my final point on this, you can join that group if you'd like to let us know at ncrf.us if you want to join that monthly call, it's free. And we'll have an annual meeting on February 5th about religious freedom in America. But when you saw last week at the opening ceremonies, this mockery of the last supper done in the opening ceremonies - the taxpayer funded mockery, I might point out - the Olympics are a very expensive activity that governments are heavily involved in. You're just really sliding a long ways down the road towards this effort to really stymie and suffocate people that want to overtly live their faith. Our group is a multi-faith, bipartisan group. This isn't a one agenda size and we've got to stand up to protect our ability to get into the public marketplace. Thanks everybody. Thanks JC.

 

JC Boggs: Governor Ambassador, thank you. I mean, you've made such a difference over your long career in so many ways and respects. I got to say this last role is maybe the most significant to me and so many Americans and people around the world of all faiths - to protect religious liberty. It's so important. So thank you for doing that and thanks for sharing your story and how we might be able to get involved on a monthly call or otherwise with the organization. Appreciate that. You're welcome to stay with us for a while or the whole thing and we'll take some Q&A later on. But right now I'm delighted to introduce Attorney General from Iowa Brenna Bird. General Bird was elected AG in November, 2022, and after more than 40 years of Democratic control of that office, so you're a giant killer and a rising star in the party in Iowa and across the country. 

 

Before becoming AG, General Bird served as a prosecutor for six years, and was also engaged in private practice law, worked with the Iowa Governor's office and the US House of Representatives and also taught as an adjunct professor at the University of Iowa College of Law. Born and raised on an Iowa farm where she was homeschooled, General Bird received her JD from the University of Chicago Law School and where in addition to her law studies, she helped entrepreneurs on Chicago's south side start their own businesses. I think that's great. So thanks for joining us today. Senator Kramer earlier talked about the federal response, what the US Congress is proposing, and from what I can tell the states and particularly state AGs, and you have been very active in this space, and perhaps you can take a few minutes to explain what you and maybe some of your state AG colleagues have been up to.

 

Attorney General Bird: Well, thanks and thanks JC for inviting me to be part of this discussion. We know things have gotten really bad when somebody who is as respected and well-known as Sam Brownback is considered somebody whose organization might be debanked. And I was particularly interested in that phrase he used, "politically exposed individual." Well, that to me sounds like anybody who does something, any leader could possibly fit that definition, anyone exercising their rights. And so that's why myself, along with other AGs from around the country, we are working on this issue and we're keeping an eye on it. AG offices have a lot of responsibilities under our laws and constitution, not only to go to court - often federal courts - when the federal government has gotten out of control, that's often what people know about, about us fighting overreach - but we also have significant investigatory powers. Each state is different where we can get to the bottom of things that are going on in our states and hurting our citizens, particularly under our consumer protection powers.

 

And that is something that we can do to make sure we get the facts and hold people accountable when they're taking advantage of Iowans or citizens of other states. And we've been working together with other AGs from around the country, not just looking into debanking, but I'd say the ESG issue more broadly as well because it really is a threat to our way of life and to the soundness of our economy that we have here in this country where it's supposed to be based on things like fiduciary duty and sound principles, and instead when they bring political considerations into it and not only make investments based on political considerations rather than fiduciary ones, but also discriminate against people who might hold different political beliefs, whether it's religious liberties, the life issue or second amendment rights, energy sector, agriculture I would add to that as well, which is very important to us here in Iowa.

 

There's a lot that we can do as AGs. So we work together to investigate. And I want to say this because I know we have a very key group of people involved on this webinar who are leading on this issue. If you see something that is happening, please tell us because we know that debanking and other related activities are happening across the country. And there are some people, well, like Sam Brownback, who because of his vast exposure in public life as Ambassador Governor, Senator, you name it, he isn't afraid to stand up for what is right, but many other people are afraid to have their name in the paper, afraid of that attention that it would bring to them or their group. So it's really important that if someone is aware of debanking or other nefarious activities, that they would reach out to a state AG's office like ours and let us know.

 

Certainly we can protect all Iowans, but we can also work with other states to help protect people in other states. We've also really been focused on holding proxy advisors accountable. I'd say, and it's not their fault because people don't have to know about all of this, but most people don't know what a proxy advisor is unless they really work deeply within the financial sector. But it's being used, the proxy advisors are being used to try to force a political agenda on our country through corporations and through these shareholder votes. And there are only two proxy advisors that exist. So there's a big monopoly there as well. That's been another area that we have been very active on as state AGs and just basically letting them know, we see what they are doing, we're keeping an eye on them, and we will step in to protect the citizens of our state because it is not right for them to be trying to pursue a woke Wall Street policy when in fact what they should be looking at is fiduciary duty and protecting shareholder value, the basic things that make sure that when someone has a pension, it's there for them when they retire. So we've been very active on that front as well. And I have to say this, I'm not the only attorney general. I'm just here representing a much, much larger group of AGs from around the country that are very engaged in this issue. So thanks JC.

 

JC Boggs: Well, I'm glad you've raised the proxy advising firm issue. And I know you mentioned other AGs. I think you led that letter to the two advisory firms related to their advice concerning debanking efforts. More recently, I think it was just in the last couple of days or weeks there's as a lot of reporting about a letter that the Department of Treasury sent to some congressional representatives about state laws seeking to stop banks from replacing, I'd say your common sense banking practices with ideological ESG and DEI ones, if you could try to say a little bit more about that and how states are pushing back.

 

Attorney General Bird: Yeah, well, you've just raised a really important one, and that also shows the intersection between Congress and the executive branch AGs, so it's a good example for us to use, but basically the Treasury Department issued a letter that - I had to read it twice to even understand what they were really trying to say in that letter - because their assertion was so bold and so unsupported by both logic and law. And Florida has a state law that's intended to combat some of these debanking practices. I think one that is sound and was well thought by their legislature and governor there, and basically, I'm going to put it in a nutshell here, but Treasury said that if a Florida's law were followed, it would allow, I would call terrorist banking, drug cartel banking because you couldn't discriminate against a customer at all. And that's not even close to a true characterization of what Florida and other states have done with their laws.

 

And in fact, it even goes counter to Treasury's own regulations that they have and that they have made that basically say you can't deny somebody financial services unless it's justified by quantified and documented failure to meet quantitative, impartial, and risk-based standards. That makes sense. You could certainly deny banking services to a drug cartel or to a terrorist under that standard, but treasury has conflated those things, and in fact, it's a pretty new change in their policy that now they are interpreting their policy to prohibit laws like Florida's. It just shows that unfortunately the Treasury Department has really been changed into more of a political agency, I think than it ever has been before. The banking regulations, I think in the past would stick to banking and not social policy and other types of policies to get into, and it's very dangerous that they're doing that. So we're pushing back against that letter. It's obviously an incorrect reading of what the law says - of both what Florida's law actually does and of what Treasury's own regulations require as well.

 

JC Boggs: Thanks again, great to have you here. Please stay if you can, but appreciate your time. So it's my pleasure now to introduce Professor Peter Conti-Brown. Professor Conti-Brown is the class of 1965 Associate Professor of Financial Regulation at the University of Pennsylvania's Wharton School and a non-resident fellow in economic studies at the Brookings Institution. Professor Conti-Brown studies central banking, financial regulation and public finance with a particular focus on the history and policies of the US Federal Reserve System. He is author of the book, "The Power and Independence of the Federal Reserve" and Co-author of "The Law of Financial Institutions", which is a leading textbook on financial regulation, and author and editor of several other books and articles on central banking, financial regulation, and bank corporate governance. He received a law degree from Stanford Law School and a PhD in history from Princeton. So professor, thank you so much for joining us today. We now have heard from Senator Kramer, Ambassador Brownback and Attorney General Bird so I'm looking forward to hearing some of your concerns or share some of your concerns that we've heard and I wonder if you come at this with a similar perspective or maybe a little different.

 

Peter Conti-Brown: I think the answer to that is yes, both a little similar, a little different, and I want to just thank the Federalist Society for having me and including me in such an illustrious panel. I was reminded of the Sesame Street rhyme, "One of these things is not like the other." So I'm very grateful to be in the presence of such great public servants who've committed themselves and their careers in this way where I get to just sit at my desk and read and write about these things where you all are in the trenches and living them. I also want to apologize and explain my attire. I am dressed for the lake, and that's not a coincidence. I'm a senior church leader in my church in Philadelphia, and I'm here in upstate New York volunteering. We take all the young men from the city, put 'em in the woods and at the lake and talk to them about various things throughout the week.

 

So that's where I am. I'm getting away from some kayak wars I think are happening right now. I mentioned that explicitly because the concerns raised by Ambassador Brownback hit close to home. I've been the victim of religious discrimination myself. I've seen it many times in other places, and it's something that I think is one of the most important issues to which we can commit ourselves. And the entire question of when private sector participants like shareholders or banks or bank executives can make decisions relative to their own reflection of risk profiles as they've appreciated them, I think is a much harder question than perhaps my predecessors on this panel do. I see it with less clarity? And I say that not because I don't have the same values or similar values that they have with respect to fairness and certainly religious liberty, but because this question of understanding "With whom shall we do business and to what end?" I think is harder to resolve, certainly through using the big blunt force of government to impose clarity on what can be hard questions.

 

What I would say when I was, as all of you probably did, as I heard Ambassador Brownback's story, I literally felt my temperature behind my ears go up. It made me mad to hear about this, the way that Senator Brownback and his - Ambassador Brownback - and his organization was treated. But what I didn't hear in response either implied from Senator Kramer or from General Byrd or from Ambassador Brownback, is the most potent tool that we have in our country to respond is not politicians, it's not law enforcement, it's not government. It's for others to come and eat Jamie Dimon's lunch and outcompete him by providing these services that are perfectly legal to provide, but in a less discriminatory fashion. Now, the question - I do share Treasury's perspective on the Florida bill and not because I think that it's some great thing for banks to privilege their 28 year old's concerns about ESG or what have you, I'm agnostic to skeptical on those issues. But the reason I share the treasury's concerns here is because drug dealers don't walk up to a bank and say, "Hi, I'm El Chapo and I have a bank account?" They set up organizations that look just cheeky, sweet and pure in their intentions and are infiltrated. Now, the idea that Sam Brownback is a drug dealer or terrorist is an insult and a joke. And so that's why I would love to see Jamie Dimon and Chase have to answer for this in the marketplace if they start to see, oh, they are making bad banking decisions that should be made better by better banks.

 

Now with respect to Florida, this is the same kind of practice that in fact - and here I'll put my historians hat on - there's nothing new about the government wanting to impose on banks a stricter lens and avenue for risk and intermediation. This goes back an awful long way, even back to big debates between Hamilton and Jefferson. One of the big debates there in favor of building out the strength of the United States from the conservative Alexander Hamilton was precisely this blend of both public and private policy and finance risk on both sides of that divide. What happens here though with the Florida bill that makes me uncomfortable and a reason that I would also not be - if I were a member of the Senate or House of Representatives - Heaven help us all - I would not co-sponsor Senator Kramer's bill is because I see that as big government shrinking the range of motion and optionality of private sector participants and especially entrepreneurs from solving this problem.

 

Maybe slowly, maybe inefficiently, but in the best traditions of our free enterprise system. In Florida in particular, the danger that I see here are twofold. The first is, national banks should indeed be exempt from these laws. These laws get to the heart of risk underwriting and banking services. The National Bank Acts as they've been amended, are federal laws, federal preemption through a line of Supreme Court cases going back to 1868, makes clear that states can't engage in bank regulation, especially risk regulation for national banks. States can't do that. That's the job of Congress, and the Florida statute does that. It doesn't intend to do it. And so when General Bird said that is a total mischaracterization of what the Florida act does, I disagree there. I don't disagree that that's a total misrepresentation of what the Florida legislators intended. I don't see that at all, that they're intending to facilitate money laundering or whatever else. But again, that's why we have a dual banking system. Now, Florida can make any kinds of decisions that it wants for its state chartered institutions, and indeed it should.

 

That's the laboratory of democracy. It shouldn't and can't do the same for national banks. That's not yet been litigated. I expect if Florida persists with this, that it will be, and I would expect that would be an easy case for the national banks to win. The other reason though is the problem that I see on both left and right of trying to shrink the freedom of movement, of risk assessments for the private sector. Now, again, I say left and right because this is something again that goes back many, many decades. "We must lend to people who can identify according to these identitarian characteristics." say people on the left going back 60 years, "We must make sure that coal or private prisons or guns always have banking access no matter what." more recently, say people like Senator Kramer, and my answer to that is, but what if they shouldn't because it's not a good banking bet? What if it's a bad financial risk? Well, the answer might be, well, coal is way too important for us as a country to risk underwriting coming to that contrary conclusion, in which case it should be subsidized. And we've been doing that for in all kinds of sectors.

 

General Bird knows about this better than I do in the state of Iowa, where federal subsidies for industry are a very large part of the economy, and maybe we should do that and the same for public subsidies for minority owned businesses or community reinvestment. But those should be separate conversations from shrinking the risk profile and risk assessments that banks can make. And if they get it wrong and they engage in illegal discrimination, we should sue the pants off of them under the Civil Rights Act. It's richly available for exactly that purpose. And if they get it right and it 's just an outcome where people we love, or institutions we love, or industries we love are not good risks, then we've got to think about other kinds of policy solutions. So that's how I see the issue. And let me just end with the same note where I began. I'm so grateful for the debate and grateful to all of you for the work you're doing in tackling these complex questions.

 

JC Boggs: Peter, thank you. And we do like a discussion and debate, not everybody has the same view so thanks for joining us. Before you go back out to the lake and kayaking, I'm hoping you can stay with us a little bit longer, takes some Q&A at the tail end of this, I think General Bird may have to jump around one o'clock. So before I turn to Jeremy, I don't know General Bird, there's any other remarks or comments that you wanted to offer and we might get back to you, but I wanted to be sure.

 

Attorney General Bird: No, that's all right. No, just keep going JC, I just wanted to let you know that when I sign off, I'm not trying to avoid any discussion. I just have another meeting I have to get to. So I thought your remarks, Peter, are very thought-provoking and I'm glad you're participating today. Thank you.

 

Peter Conti-Brown: Yep, thank you.

 

JC Boggs: Yeah. So last but certainly not least, I have the pleasure of introducing Jeremy Tedesco who serves as Senior Counsel and Senior Vice President of Corporate Engagement for Alliance Defending Freedom. In this role, Jeremy has led ADF's efforts to combat corporate cancel culture and build a business ethic that respects free speech, religious freedom, and human dignity. Jeremy, I was going to list some of your cases you've been involved with, it's going to take me five minutes, but a lot of litigation, Supreme Court, two or three cases, appeals courts, state Supreme Courts, et cetera. So thanks for all you do. So we've heard a lot. What do you think about all this? I know you've been very engaged with this issue for some time with the ADF, and I'd love to hear your comments.

 

Jeremy Tedesco: Yeah, thanks very much for the invitation, JC, thank you to the Federalist Society for focusing on this issue. We think it's a really critical issue and it really helps a lot to have the Federalist Society focusing a light on this with such great guests and speakers. So I wanted to lean in on a couple of things. It's kind of fun to bat clean up, because I get to hear everything else. One thing that Ambassador Brownback said about this being an under-reported issue, I think is really critical. I think we don't actually know the scope of this problem, but we do know that it's a lot bigger than what's out there in the public square. We've been tracking this for at least the last two years, and there's a couple other really key stories I at least want to start off with, just a couple of the key stories of debanking that I think the listeners should be aware of.

 

One of our clients, Indigenous Advanced Ministries was debanked by Bank of America back in April of 2023. They had been a client there for eight or nine years, had changed nothing about their business practices or anything, and received a letter out of the blue - five letters actually - saying they were closing their accounts. They no longer wanted to do business with their business type. And then shortly thereafter, another letter that said that their risk profile had exceeded the bank's risk tolerance. Now understand, this is an international relief Christian ministry. They support and provide relief for widows and orphans in Uganda. They build them wells, they build them schools, they pull people out of sex trafficking. I mean, this is like the bread and butter of Christian ministry. And so Bank of America debanked that ministry, plus also a local church in Memphis, Tennessee that also supports that ministry.

 

And so while our clients asked over and over again for an explanation, Bank of America just brushed them off the whole time. There's plenty of other examples. Timothy Two International is a Christian ministry debanked by Bank of America, JP Morgan Chase debanked Arkansas Family Council, a pro-life and pro-family organization in Arkansas because they considered them high-risk. JP Morgan Chase also denied payment processing to Defense of Liberty for an event that they said promoted intolerance and hate. This was an RNC event back in 2019 that featured Donald Trump Jr. amongst a couple other guests. And so this is just a few of the examples, including Ambassador Brownback's experience that shows that these things are on the rise. And we tried to figure out why is that, and there's a lot of explanations for it, but I want to go through some of those right now.

 

One is that the vague, subjective policies that are causing these cancellations really pervade the financial industry. We know that terms like reputation, risk, hate, intolerance, misinformation and things like that are all throughout terms of service. ADF has an index called the Viewpoint Diversity Score Business Index that measures corporate respect for free speech and religious freedom in the tech and financial industries. And what our 2024 index found is that of the 85 companies we scored, 76% had these kind of policies in their terms of service, and that also included about 70% of the financial institutions that we studied. So these kinds of terms are the very terms that the companies usually rely on when they're depriving people of services. They're incredibly vague. They tell the customer nothing about the real reason that they're being debanked, and the company's allowed to hide behind these vague standards, just like the government would do if they were regulating speech through these kind of vague standards.

 

The next problem is government regulation and overreach. The government has pervasive regulatory authority over banks, both at the federal level, and even in some states like New York, and they have historically abused that power from time to time to discriminate against organizations whose views or activities they don't like, even if those are constitutionally-protected views and legally-protected activities. You also have to note that under reputation risk on the federal level, reputational risk includes under the federal regulations, negative publicity related to a customer. So clearly you're really inviting a heckler's veto or the use of these third parties to discriminate against views that the government disagrees with. Couple historical examples, one very recent and one back in the 2010s. The 2010s was Operation Choke Point under President Obama, his DOJ used reputational risk as a tool to push out legal industries like payday lending and gun manufacturers from banking services.

 

They knew they couldn't do it legally, so they used reputational risk and the supervisory control they had over banks to push those companies out. NRA v. Vullo, which was discussed a little bit, is the most recent example, just decided by the Supreme Court. The Department of Financial Services in New York put a lot of pressure on banks and insurance companies - so this implicates insurance as well - to stop doing any kind of business with the NRA. One of the insurance companies acted on that pressure and deprived the NRA of services in response to all this pressure. And the message was very clear to the banks and the insurance companies, if you have a relationship, a business relationship with the NRA life is going to be very miserable for you from a regulatory perspective. And this is the way - it's like they regulate by suggestion, it's never a demand. It's "If you don't do this, your life's going to be very miserable from a regulatory perspective."

 

So the decision in Vullo was very good, great decision. The court even went on in that decision to say that "Government officials cannot wield their power selectively to punish or suppress speech directly or through private intermediaries." And that's really what we're trying to stop here, is the government using private or third party intermediaries to do their censorship dirty work for them and to coerce them to do that. Another problem that is posed by the banking industry and banking regulations is that they're really shrouded in secrecy. Banking supervision is something that is hidden behind a veil and is very difficult to get transparency around what's going on, why the decisions are being made, even what kind of suggestions and regulatory pressure is being put on bank officials by regulators. Operation Choke Point and the Vullo case, give us a very small peak into something that's almost completely shrouded from our view.

 

So that's another thing that contributes to the problem. We also have seen very recently an increase in collusion between big banks and big government. So this is kind of the same as the government regulation and overreach, but I think it's a distinct problem. It came about and saw the light of day because of the very good work of the House Judiciary's Select Subcommittee on the Weaponization of the Federal Government earlier this year, and two different kinds of data dumps and reports. They talked about how the US Department of Treasury now has been telling banks that in order to identify domestic violent terrorists, or at least people who could be suspect for domestic violent terrorism, they wanted those banks to surveil the private financial data of their customers for terms like "Dick's Sporting Goods", Bass Pro Shop", "MAGA", and religious texts that they thought were potentially alarming to them. 

They also shared a list of hate groups, so-called hate groups, that was put out by a very partisan, far-left group that included my organization, Alliance Defending Freedom and numerous other mainstream Christian conservative nonprofits in that effort to identify domestic violent extremists. So that's very alarming. I mean, Operation Choke Point really pales in comparison to what we're seeing from this kind of collusion between big government and big banks to surveil their customer's private data in a way that implicates their speech and constitutionally protected activities. I think another thing we really need to be concerned about is AI-powered censorship. We see this in the social media and digital context all the time, but the thing is, the kind of censorship industrial complex is coming for the banks too. The federal government is even issuing grants for the development of AI tools to help financial institutions reduce risks posed by misinformation and reputational concerns.

 

So this is going to even be more hidden when the AI tools that are incredibly - lack transparency at an incredible level - start being used by big banks to determine whether you pose a reputational risk through some kind of algorithm that we'll never see or understand. I want to talk a little bit more about just a couple other things. One was the mention that was made about the rise in ESG. I think we really need to focus on that. The weaponization of the financial markets is purposely occurring because it's an end run around democratic accountability. It's an end run around our civil liberties. It's an attempt to regulate in a way that you can't get done at the voting box or because there's an impediment in courts to try and get the agenda across the finish line. So ESG, the proxy advisory services that General Bird was talking about, are used to drive an agenda to essentially co-opt the banking institutions and financial industries to try to achieve regulatory and policy ends that are not achievable through Congress or other means.

 

But I also want to talk about solutions before I end. One is debanking legislation. We've talked about the Florida legislation, but there's also Tennessee that passed legislation earlier this year. We were involved in that. We worked with legislators there and other policy groups in the state and nationally to help get past a piece of debanking legislation that stops banks from being able to debank people for their political or religious expression or because of their involvement in ESG-disfavored industries like energy or fossil fuels and things like that. In the law it gives customers the right for a detailed explanation if they are debanked and it gives enforcement authority to the Attorney General and in states where there's a private right of action, it adds a private right of action as well. And the other thing I wanted to focus on is Ambassador Brownback had talked about the efforts with Chase, the shareholder resolution that we were involved in.

 

This is an interesting part of our work and I think it may go to the good professor's concerns. We're helping shareholders and investors in these companies raise these concerns through the proxy process much like our colleagues on the left do. And so we helped an investor named David Bonson file and submit a shareholder resolution on debanking at JP Morgan Chase about the ambassador's debanking and the broader issue at JP Morgan Chase that was heard at the May, 2023 shareholder meeting for Chase Bank. And eventually because of the amount of pressure that Chase received over that and letters from State AGs and other things, Chase actually changed one of their policies that had been causing debanking in this space. One of those vague and objective policies that we were really concerned about at Chase was a social risk policy on their payment processing side of their business.

 

The very policy they had actually used to debank Defense of Liberty, one of the organizations I mentioned in the beginning, they dropped that policy and it doesn't exist anymore. They also put out in some of the reports that they're committed to providing their financial services without regard to the religious and political views of their customers. And so we see Chase starting to move slowly in the right direction because of market forces and the influence of their own shareholders. So there's a lot of different tools available to push back on these things, and I think shareholder work, legislative work, oversight, just shining the light on these practices is really critical. And the last thing I'll say is if you know, just like General Bird did, if anybody who's suffering from debanking, having been debanked by a bank, please feel free to send them to us as well. We are tracking those and getting engaged where we can to try to help resolve the situations.

 

JC Boggs: Jeremy, thanks so much. This has been a terrific conversation. We've got about 10 or 15 minutes remaining for Q&A. Let me open it up first to our speakers to see if there's any further comment on what we've heard today.

 

Sam Brownback: If I could JC, just briefly, this has been an excellent panel. I think that Senator Kramer's point about the noise from the left not being equal to the noise from the right is our fault. I think we should be getting noisier about these cases and these situations. A corporate shareholder, one person told me that if corporate shareholders voted their stock the way they vote going into the polling booth, most of these big companies would be Alabama. They're owned by conservative people. Why aren't we voting our ownership? Well, we don't get organized. We said this is a fiduciary duty company that they're supposed to maximize shareholder value. Well, they're not, and we should get engaged at the shareholder level much more like Jeremy was just saying, that's a use of the marketplace. There's groups - Alliance Defending Freedom does work in this area, Consumers Research and Will Hild. Robbie Starbuck was an activist who went after Tractor Supply and John Deere to change some policy. State Financial Officers Foundation is voting the stock of the state pension funds in red states, pushing for them to be voted conservative. I think we got to get noisier and more organized, particularly inside and with these big companies would be a key piece along with, I think more transparency legislation would be very helpful. These things are big black boxes. We still don't know what happened to us after all the push that we've put in. Thank you.

 

JC Boggs: Yeah. Senator, while I got you, I had a question from one of our concerned listeners and asked if your organization was able to - I know the answer - was able to open a deposit account at another bank and how hard was that to find another bank?

 

Sam Brownback: It wasn't. We found another bank, but for us, the point was, the very reason we formed the National Committee for Religious Freedom is to stand up for religious freedom in the United States and to not see these practices that are done often by governments overseas being done by private entities in the United States. But we were able to find another bank. I do not believe we should have been denied or shut down ourselves, and we still don't know why.

 

JC Boggs: Yeah. Well, I'm glad you found another bank,

 

Jeremy Tedesco: Let me just say on that, and something else that was I talked about earlier, I want to focus on the fact that the idea that the market can fix this problem, I think is a fool's errand for this reason, the banking sector is extremely heavily regulated. In fact, they exist in what's called, according to Brian Knight, a Mercatus scholar, “a regime of privilege”, and that regime includes subsidies and bailouts and numerous regulations that privilege the big national banks and makes competition nearly impossible. Prior to some of the regulations coming on the scene and around 2008 and 2009 in response to the financial crisis, then there were about a hundred national charters issued a year to banks. That has dropped to about seven per year after those regulations came into place. The result of all this is what everybody is kind of talking about, is this consolidation of banking into just a few big national banks.

 

And so if you look at it, 50% of the deposit accounts in the country are controlled by the big five biggest banks, somewhere around 75% of the top 15 banks. And that's not slowing down, that's increasing. So you add that to everything I was talking about, the fact that the government has this pervasive regulatory authority over them. There are no guardrails on those regulators to stop them from doing the next Operation Choke Point, the next NRA v. Vullo and things like that. We need regulatory reform and accountability and transparency to try to stop these things from happening. So the idea that Ambassador Brownback got another account, that's great, but I don't know how long that persists when we have this consolidation of power and this impetus to use the financial industry as a weapon to achieve policy outcomes and to punish people who aren't bending the knee to the preferred political outcomes of the day.

 

Peter Conti-Brown: So I found myself agreeing with everything that Ambassador Brownback said and then disagreeing with everything that Mr. Tedesco said. So let me emphasize that a little bit.

 

Jeremy Tedesco: Haha, I knew that would happen.

 

Peter Conti-Brown: Yeah. So I just finished with my co-author, a 600 page history of bank supervision in America - writing this history. And in many senses, I agree with you, Jeremy, that what you're talking about, we are definitely seeing a period of increased concentration. There's no doubt about it. There are 9,000 insured depository institutions in the United States. If you were to take that same market analysis that you just offered talking about concentration, apply it to nearly any other industry throughout the country, they would say, 'Oh my gosh, that sounds like the most competitive dynamic marketplace you could imagine." And you would be right about that. What Ambassador Brownback's organization needs is not the services of one of the big five global banks that has financial services that are simply not relevant to a 501C(4) organization. Any number of these thousands of others could do so and they could compete to win in exactly that space.

 

I'd go further than that. The political power that banks have are not at the big five. They're in the community banks. There is a bipartisan love affair for community banks at a level that is deep in American historical tradition. I don't see that going anywhere either. Now that said, where I do agree with you completely is that when we talk about the private sector here, the private marketplace, it doesn't quite apply to banking in that sense because of so many formal and informal subsidies. And the point that I agreed with so much with Ambassador Brownback is one place of our legislation that I would like to see is transparency. I don't like mandates. I don't like putting extra bazookas in the hands of law enforcement to go blasting at citizens who behave or not in certain ways. And the statutes we've been talking about put a lot of bazookas in the hands of law enforcement. I don't like that, but requiring the disinfectant of transparency and sunshine on these issues so that Ambassador Brownback never has to wonder, wait, but why? And they have to hide behind these goofy terminologies, the confidential supervisory information. That's the veil that Jeremy was talking about.

 

There are too many problems with that lead curtain. So transparency, I'm in profound support of, but your account, Jeremy, is a testimonial of why the marketplace works, the fact of proxy successes. And as a political independent, I'll say on the left and right, I think more noise is better. I'd also say by the way that liberals would say about conservatives, the same things you all said about liberals, "Oh, they are so good at raising the volume of their interests and we are so bad. Why is that?" And as an independent, I look back and I say, I think y'all make a lot of noise across the spectrum. And I'm also saying that's what democracy is. It's rowdy, it's noisy, and as it should be. So I think that getting involved in exactly the ways you're describing allows us to be as dynamic as we can be, not casting in amber today's disputes that will affect generations in the future and making a way so that they can't make their own prosperity in ways that make sense to them. That's what I'd be in favor of.

 

JC Boggs: Hey Peter, I'm glad you raised a transparency issue. As I read through a number of questions we've had from the audience, that's a common denominator. Look, I understand a bank can decide whether to open an account and maybe that should have happened first and you're kind of frustrated. You open it three weeks later and you're close down, but at least, okay, why did you close it down? And you're not getting an answer. So that's sort of the frustration I've seen in these questions, and I just wanted to reinforce that. I've had some conversations with Federalist Society members over the last couple of weeks as we were putting this together and they've said, "Well, debanking's one thing, but I'm on - " - a number of folks - "I'm on a nonprofit board, faith-based board, and we're losing our insurance." So this is a parallel issue, deinsuring, I guess. But they're extensively for business reasons based upon their faith related policies, procedures, and belief and non-renewable insurance. So I don't know if either of you have seen much of that or have comments on that as well.

 

Sam Brownback: I have, and I get contacted increasingly by people that say it's deinsurance or it's an accounting firm that says, "We just kind of don't want to do business with you guys anymore." And it's never this sort of, "You know what, you're kind of a faith-oriented Christian traditionalist viewpoint, and we don't like you guys." They don't say that. But you're left to wonder, well, why, you've done business with us for 10 years, 12 years, why now? What changed here? And the only thing that you can kind of cobble together is just that this is a group that stands for a traditional set of moral values, which like our group, the NCRF, where we have faiths of all faiths, I mean Christian, Jewish, Muslim, Hindu, but many of them have a similar set of kind of traditional set of values. And they're not favored in the culture today, particularly maybe by the 25 to 35-year-old that Senator Kramer was being told by these bank presidents about, and they're the ones that take it in the neck then.

 

And that's why again, the NCRF, we've gathered people from all these various groups monthly to talk about this and how do we push back against a culture that's trying to crowd these groups out? And professor, I appreciate you agreeing with me, although I'd rather you'd agree with Jeremy than me, but one of the things we had to go with another national bank because we're spread across the country and we had people working in various locations. So you are limited to some degree on who can then service you in that type of situation. Maybe if I was more electronically aware, I could do better, but that was one of our problems.

 

Peter Conti-Brown: Well, let's sit down together. I'll show you how to make great use of a regional bank on a national infrastructure. It's not as easy as doing Bank of America, but it's almost as easy, and I think that the national banks have an unfair advantage, which is they say, "Look how big we are." And for a lot of busy customers who are out there doing their business, protecting religious liberty, doing tractor supply, selling widgets, whatever, they say, "Well, great. Well, I'm hiring you to solve these problems for me. I trust you." And that's a trust that I don't think that the largest of the banks have necessarily earned. For 99% of all the financial services needs of anything other than global manufacturing corporations, good regional banks and even some credit unions can solve a national infrastructural problem. But I agree with you, it's not obvious how to do so, and it requires a little bit more customer sophistication than we can expect. And the big banks rely on that asymmetry.

 

Jeremy Tedesco: And I would just add on the insurance front, we filed an amicus brief in the Vullo case on behalf of pro-life groups who had been denied insurance explicitly, even though Ambassador Brownback is right that most of the time they don't tell you why. It's really vague. They said, "Look, it's because of your pro-life views on the abortion issue that we're not going to continue to provide you insurance." And so I think if you pull back from the specifics of some of these cancellations, I think the thing that we have to reckon with goes back to ESG proxy services and what those represent. What they represent is an attempt to do an end run around the way we regulate from a national policy perspective and put businesses in the position of government making national, setting national policy. And that's exactly what ESG is trying to do.

 

When you look at Climate Action 100 or the Insurance Alliance or the asset manager alliances related to climate change, I mean, their goal is to bypass what they can't get done with the government and impose national standards and rules on the entire country. And so when the effort is concentrated to try to make that end run around the institutions where we should have these debates, dialogues, and set national policy, we're dealing one, with a manipulated market, not really a totally free market. And two, that means that the free market isn't the complete solution to the problem because how are free market, free speech-loving religious freedom-loving oil and gas-loving Americans going to wrestle away control of the two proxy advisors and the three big asset managers when it comes to the way in which they're forcing corporations to take positions on and essentially regulate society without having to pass a law or win a court case? So I mean, I think that's the thing that faces us and that's what's such a struggle for free market conservative Americans, is the battle has changed to a setting where our knee-jerk free market and conservative principles make it difficult for us to wrestle down the problem, to figure out the solutions. And I think we're all trying to figure this out together.

 

JC Boggs: Well, I see Caroline is back, which probably means we need to wrap this up soon. I've got so many great questions I wanted to get to, but we ran out of time. This has been a wonderful, wonderful discussion. I enjoyed it. I always learn something with these events and webinars. We had terrific speakers. I'll pose one more question. We have three people left here, so we'll have the lightning round, just any final comment that you may want to offer to the group and then we'll wrap up, Senator, not to put you on the spot.

 

Sam Brownback:  I really hope people get engaged and not just kind of let it slide off to the side, whether it's with one of these groups or a specific narrow group - I listed several - or with the National Committee for Religious Freedom, as I mentioned, go to our websites, get engaged because this problem's growing bigger and it's morphing out into more areas. And as I said earlier, I want to repeat, any ground we lose in the United States gets magnified around the world. It gets worse in other places. You've got to protect religious freedom solidly and strongly in this country.

 

JC Boggs: Great. Peter, any thoughts? Final comment?

 

Peter Conti-Brown: Just my gratitude for what a great webinar this has been. Thanks so much.

 

JC Boggs: Well, and thank you too, and I hope you get out in the lake and do a little kayaking this afternoon with your friends. And Jeremy, you have the last word. How about that? Doesn't happen often.

 

Jeremy Tedesco: Just thank you so much for hosting this. It's been a great event. I think I would just say send us your debanked. We can't move the ball in shareholder meetings, in the legislatures, or in the public square unless we have compelling stories of people being debanked. It's scary sometimes to go and tell your story, but it really makes a difference in shedding light on what's going on and making sure we get to the solutions we need.

 

JC Boggs: Great. Well thank you everybody. Caroline, do I turn it back to you?

 

Caroline Bryant: Yep. Great. Well, on behalf of the Federalist Society, I want to thank our speakers for the benefit of their time and expertise today. Thank you also to our audience members who joined us. We greatly appreciate your participation. Check out our website fedsoc.org or follow us on all major social media platforms to stay up to date with announcements and upcoming webinars. Thank you once more for tuning in. And with that, we are adjourned.