Commercial Credit (1840 – 1890)
Prior to the introduction of any formal commercial credit system across the US, credit was extended primarily on the basis of character, while capacity and capital made up the “three Cs”. Every moral quantification of a merchant increased his credit: reputation for honesty, work ethic, perseverance, industry expertise, marital status, religion etc. This trust was a function of familiarity, creditworthiness and reputation. This was a stark contrast to the system of credit in Europe which hinged on collateral, land and inherited fortunes.
The speed of the capitalist transformation of America in the early nineteenth, the shortages of circulating currency, and the increasingly far-flung and complex credit relationships that supported it meant the liberality of the American credit system was a practical necessity.
By the 1830’s, as migration bought growing numbers to the cities and populations spread inland, traditional forms of credit assessment were breaking down. This was a major problem for city merchants, especially importers, manufacturers, wholesalers, and other middlemen who sold to country retailers and tradespeople each spring and fall. With so much business at stake there was considerable pressure to trust people of unknown and unverifiable reputation.
The panic of 1837 underscored the risks. A cascade of defaulting debts wiped out investments, wrecked businesses and crippled the American economy. Lewis Tappan who ran a silk wholesaling firm in New York was bankrupted by uncollectable debts. He also saw an opportunity to transform the credit system and launched the Mercantile Agency in 1841 with a goal of compiling detailed information about business owners across the country. The Mercantile Agency quickly became synonymous with commercial credit and served as model for future competitors.
Tappan’s innovation was to transform the business community’s collective knowledge into a centralised, subscription-based reporting service. Key to the agency’s success was the use of unpaid correspondents instead of expensive lone travelling reporters. Most members of this vast network were attorneys who filed reports in exchange for referrals to prosecute debt collections in their communities. The agency had 300 correspondents by 1844, 700 by 1846 and more than 10,000 by the early 1870s across nearly 30 offices, including several in Canada and one in London.
While usual correspondence between reporters, branches and the main office was completed by mail to limit costs, news of “serious embarrassments, assignments and failures” were immediately telegraphed. Until coded reference books appeared in the late 1850s, subscribers – wholesalers, merchants, banks, and insurance companies – received credit information only in the offices of the Mercantile Agency. Seeking a competitive edge, at least one major wholesaler strung its own telegraph line to one of the mercantile agencies, establishing the first system of real-time credit authorisation.
By the late nineteenth century specialised reporting firms were also formed to serve a variety of industries that included manufacturers of iron and steel, jewellery, furniture, shoe and leather, and construction materials. A Chicago journalist in 1896 wrote about “Barry’s Book” which listed 35,000 retail lumbermen and 2,000 wholesale dealers, “it’s so thorough and comprehensive that a retail lumberman out in a Dakota village can’t stand the milkman off for half a dollar’s worth of tickets without every wholesale lumberman in the country being appraised of the fact before night”.
There were major problems with these early systems though. The quality of the intelligence was often an issue when much amounted to little more than hearsay, could be corrupted by young lawyers seeking to gain favour with the mercantile agency to win work, and often went back more than 18 years. Converting qualitative reports into quantitative fact could be difficult as comments were open to interpretation and lacked context. While it was easy to identify the extremes of the business community it was the vast middle range that proved troublesome. Importantly, if you were subject to less than favourable character reports there was very little you could do about it. There were no laws to protect you, no way to view or appeal your own report, and libel suits at the time were lengthy endeavours that were all ultimately decided in favour of the agencies. The introduction of full-time credit reporters in the 1860s went some way to solving these issues. Efforts to compel business owners to share signed financial statements were resisted or ignored well into the 1890s.
Tappan sold out of the agency to several associates in 1854 and the firm was renamed R. G. Dun and Company. In 1868 Dun’s chief rival was the Bradstreet Company. The two companies competed aggressively until 1933 when they merged to become Dun & Bradstreet (now Illion).
The credit bureaus and reporting firms together formed an elaborate system of mass surveillance. No government agency in America had anything like the intelligence gathering reach of the mercantile agencies at the time. To compound this further, the information wasn’t being collected for internal administration but to sell to anyone that had a need to use it.
Consumer Credit (1890 – 1950)
When the norms of commercial credit were transferred to consumer credit during the late nineteenth century, the cocoon of privacy surrounding personal finance was similarly punctured. Retail credit reporting was almost entirely based upon an assessment of the borrower’s character and financial behaviour. A lot of these firms didn’t last for long though as the costs of collecting information was high and a gargantuan effort was involved to update reference books to ensure their accuracy. They also couldn’t control the books being shared and were reliant on small businesses whose record keeping was often very poor.
The financial crisis of 1893 provided the impetus for professionalised credit management which in turn had an enormous influence on the institutionalisation of consumer credit surveillance. Large retailers introduced credit managers who codified principles and standards for supervising customer accounts. They increasingly leveraged telephones for credit checks and the telautograph (early fax machine) and teletext technologies that came after to improve the speed, accuracy and efficiency of credit departments and credit bureaus. The National Association of Credit Men was founded in 1896 but never numbered more than 200 members primarily because of the natural distrust amongst competitive retailers. It did spawn another grouping organised around the profession, The Retail Credit Men’s National Association, that grew to more than 10,000 members across 40 states and 230 cities by 1921. By the mid 1920s there were credit files on tens of millions of Americans.
As judge and jury in lending decisions, credit managers wielded enormous power over the lives and fortunes of consumers as they balanced the expectations of salesman with keeping losses at or below 1 percent of sales. Credit professionals were expected to have a grasp of all spheres of activity with even the slightest bearing on the future financial conditions of his customers, from local weather conditions to national monetary policy. Fear was the primary motivator but they also had to keep the customer’s goodwill and even make themselves their confidant and advisor, so they would voluntarily keep them informed of their “condition”.
A retail credit department wouldn’t extend credit until the customer had an interview with their credit manager. These interviews became a referendum on a customer’s morality and social standing. A national association’s educational director observed “I know of no single thing, save the churches, which has so splendid a moral influence in the community as does a properly organised and effectively operated credit bureau”. To be refused credit implied they were undeserving, deficient or suspect. When credit was granted, a credit limit was assigned without the customer’s knowledge and could be adjusted over time to control credit risk and reduce the need for constant credit approvals.
Unlike highly secretive 21st century credit reporting, early credit bureaus and associations went to great lengths to publicise their work. The message of credit morality, delivered via mass media and in countless private consultations throughout the country, equated credit and character in explicit terms. Credit managers used World War 1 to join their message of credit responsibility and national allegiance to introduce thirty-day billing cycles. “Prompt Pay” and “Pay Up” campaigns were run in cities and towns across America to amplify these messages. The messaging over the next decade then shifted to one of “credit consciousness”.
In addition to their regular customer credit files, many credit departments and bureaus kept “watchdog” cabinets. These files included compromising information about divorces, bankruptcies, lawsuits, and accounts of irresponsible behaviour sourced from newspapers, court records and public notices. This information might not have an immediate impact on a customer’s credit standing but it could be used against them in the future.
By the 1920s, credit managers were no longer simply tracking customers and making authorisations, they were also mining their rich repositories of customer data for the purpose of targeted sales promotions. In this way systematic credit management began to develop into an instrument of social classification and control with broader implications.
The fact that credit reporting up until this point had generated so little public reaction was surprising. Occupation, with its connection to income both in terms of amount and regularity biased salaried professionals with an established credit history and good references. Geography and buying patterns were other metrics used to make generalisations and race and ethnic prejudice were codified as standard operating metrics to discriminate amongst applicants. All these early efforts were blunt punitive tools used to identify the best and worst cohorts in the community. They also created, supported and sustained social prejudice in many of its forms across America.
By the 1930s, credit managers began to realise the value of “customer control”. Their most profitable credit risks were already on their books, and it was far more difficult and expensive to acquire new customers. Customer control developed in credit departments rather than marketing departments because they controlled all the insights. Personalised letter campaigns enjoyed high conversion rates and were just as effective to reengage inactive customers as they were to capture a higher share of wallet from their best customers across more departments. As customer control became more sophisticated, retailers attempted to further differentiate their credit customers by price line, taste and average expenditures to regain the personal touch that had been lost in the development of impersonal mass retailing.
Despite the prevalence of a national credit reporting system, many retailers in the 1940s continued to grant credit on the basis of an honest face or a personal reference. Many retailers didn’t have their own credit departments or full-time credit managers. Barron’s reported in 1938 that only 10% of small business owners employed a credit manager, though 91% offered credit terms to their customers. By the start of World War 2 credit bureaus had files on 60 million people.
Spy’s and Social Warriors
Credit bureaus were essential to the banks and oil companies launching aggressive credit card programs in the 1950s that meant the credit departments of the large retailers no longer had a monopoly on the insights of their customer’s buying habits.
By the early twentieth century two basic types of credit reports dominated. Trade clearances were the least expensive and most time sensitive reports and included only basic identifying information like name, spouse’s name, current address, and ledger data consisting of a list of open accounts, the maximum balances and the customer’s history of repaying. Antecedent reports were comprehensive summaries of an individual’s personal, financial and employment history. Typical information included race, age, marital status, number of dependents, current and former employees and positions held, salary and other sources of income, bank account information, any bankruptcy or legal actions and whether they owned or rented. They also included terse commentary on home life, personality, reputation etc.
There were also two styles used for data collection. The Retail Credit Company (RCC) was a national reporting agency who employed local investigators, primarily in the insurance business and would later in 1976 be renamed Equifax. Their approach relied on a direct investigation via interviews rather than shared ledger data and extended to the family members, former employers, references, club members, neighbours and former neighbours, financial and professional people. By 1968 the RCC had more than 30 branches and employed more than 6,300 “inspectors”.
In contrast the Association of Credit Bureaus of America (ACB of A) was a network of independent affiliated members and relied on customer account information and payment histories submitted to the bureaus by local creditors. They also conducted direct investigations to flesh out new or old files and spoke to employers, banks and landlords. Landlords were especially prized because they often included comments on personal habits and manners as well as rent payment records, number of dependents and history at the address. They would also speak with neighbours, the local grocer or drug store to fill in any gaps.
Bureau investigators were advised to cultivate trusted informants, to meet privately to ensure confidentiality and to conceal notebooks or pre-printed forms that might arouse suspicion. They also created derogatory reports that included any information that could be used to discredit an applicant from press clippings, public records or member feedback. These reports were used to fill the gaps in real time information and were cheaper than ordering a full report. They included news clippings on accidents and calamities and even stillborn or premature births on the logic that such events usually involve new debts to doctors, hospitals and morticians. Bureau clerks would also descend on courthouses and municipal offices daily to copy all records pertaining to real estate, civil and criminal lawsuits, tax assessments and liens, bankruptcies, indictments and arrests. This air of espionage would come under harsh criticism during the late 1960s.
Many bureaus systematically repackaged and resold their information to third parties – insurance companies, employers, car dealers, landlords and law enforcement. Employer reports could be sold for more than three times the price of a credit report. Some bureaus began branching into new promotional services, including pre-screening programs and the sale of customer lists.
Many post war bureaus also ran promotional business by offering “newcomer” services based on the Welcome Wagon business promotion model thinly disguised as a charitable civic association. Hostesses would greet a new family when they moved into town to offer them helpful information on schools, shopping, churches and other community amenities. The primary purpose was to convince them to sign up for credit services in their local town. With either a completed application or a former address in hand, investigations could be made to determine whether complimentary charge accounts would be offered. In some places these services were integrated into local credit card programs often run by the credit bureaus.
Dallas’ Chilton bureau was unique in its aggressive effort to marry credit surveillance with credit promotion. It issued its own credit card in 1958 and sold pre-screened lists of top-rated customers that could be sorted by mailing zones, then by income, age, profession, renter or property owner. This type of targeted marketing and consumer analytics was far ahead of its time and is now a core service offered by all three major credit bureaus. The Dallas bureau’s rapid expansion in the 1960s with the purchase of more than 40 bureaus and the computerisation of its credit reporting network and list marketing business, eventually led to the creation of Experian.
Both credit reporting agencies and credit managers were motivated to maintain confidentiality. It protected their competitive positions and helped them to avoid libel suits. Applicants would never be given a specific reason why they were rejected, and only told their credit report was incomplete or insufficient. They were also never able to see their own credit record, and in any interview a credit manager had with those who wanted an explanation, it was used as another opportunity to enhance the applicant’s credit file.
However, in their perpetual quest to vanquish deadbeats and to safeguard the nation’s credit economy, bureau operators saw themselves as patriotic agents of social change. Bureau files were completely opened to government officials in the spirit of public service. This started shortly after World War 1 and turned into a paid relationship in 1937 when the US Department of Justice contracted with the National Consumer Credit Reporting Corporation for the FBI. A symbiotic relationship developed because bureaus were dependent on government agencies for access to courthouses and municipal offices and public agencies relied on detailed investigative reports to run loan programs like those of the Federal Housing Authority and Veteran Affairs. Non-credit granting agencies, like the FBI and IRS, can still get access to bureau files today with a court order.
The industry faced lawmakers and popular condemnation in the late 1960s. Surprisingly, the appropriateness of fundamental metrics of credit reporting weren’t bought into question. It was the lack of rules around the collection, sharing and correction of credit information that was the focus. The Fair Reporting Credit Act (FRCA) of 1970 and the Consumer Protection Act of 1968 placed restrictions on these activities but the underlying logic that a credit record was relevant to employment and insurance risks didn’t change. These included:
- Credit reports could only be purchased for a “legitimate business need”.
- Bureaus had to disclose the “nature and substance” of an individual’s file as well as the sources if requested by the customer.
- Adverse items were to be deleted after 7 years (14 years for bankruptcies).
- If you were denied credit, insurance or employment, or your insurance premiums were raised on the basis of an adverse credit report, you had to notified and given the contact information of the credit bureau.
- Individuals for whom an investigative report was ordered had to be notified.
- For employment reports, applicants had to be notified if the report included an adverse public record.
Serious problems quickly emerged around the interpretation of the FRCA laws that left a lot open to the discretion and abuse of credit bureaus. The laws did even less to protect privacy because government agencies could still obtain basic information without a court order and the content of the bureau files was unrestricted. Since credit bureau violations were very difficult to prove, and long-standing privileged communication laws protected them from defamation, they had little fear of being sued and therefore no incentive to rein in their information collection practices.
Relevance was another problem for credit evaluation because it wasn’t clear where financial information ended and non-financial information began, and they informed each other. This was only partially addressed by the Equal Credit Opportunity Act (ECOA) in 1974 that made it illegal to deny credit on the basis of gender or marital status. Race, religion and age could still be used to discriminate against applicants even though many lenders had already removed these from their scoring models. This was complicated by an ECOA requirement to give each declined credit application a specific reason for their rejection. Lenders argued it was impossible, but they were more concerned about defending some of the metrics they were relying on. If more metrics were excluded from their models it could have an impact on their profits. Even when gender or marital status was removed from models there were so many “secondary” variables that offered reliable proxies for these variables.
Lenders were relying on information collected from the credit application alone until the late 1980s primarily because it reduced their spending with the credit bureaus, despite providing an opportunity to reduce some of the discriminatory nature of credit decisions. The practice of not including an applicant’s past payment history in a credit decision came in for heavy criticism which eventually led to their inclusion.
Computerisation (1950s & 60s)
The automation of banking and accounting during the late 1950s caused many to predict that a paperless office was on the horizon and a single identification card would replace checks and cash and link a person’s bank, credit and personal information. Although a checkless society was technically possible, the problem of personal identification was insurmountable. Mistaken identity and fraud had already become a major problem after World War 2. It also required a new high speed surveillance infrastructure to identify and monitor the nation’s population.
To combat these fraud issues, verification services started to proliferate:
- Validator was adopted by Macys in 1966 and allowed sales clerks to authorise credit purchases by entering a customer’s account number, into an electronic desktop device.
- Telecredit was used by Carson, Pirie, Scott and was a combination touch tone phone and audio response unit connected to a computer.
- Veri-Check was created by the Dallas Chilton bureau and combined a database of names, physical descriptions and up to date check cashing histories for local individuals.
The first mover in the computerisation of credit records was Credit Data Corporation (CDC), a private firm based in California. It was led by Harry Jordan, a graduate in biophysics that returned home to run the family business, The Michigan Merchants Credit Association, after his father’s death in 1956. Rather than working to gain the cooperation of local bureaus across the country he focused on the wealth and mobility of three regionals zones that accounted for 43% of the US population: LA to San Francisco, Boston to Washington and Chicago to Buffalo.
CDC digitised it’s LA bureau at a cost of $3 million in 1965 using IBM 1401 computers leased at a cost of $20,000 per month. The bureau provided reports in 90 seconds at a cost of 63 cents per enquiry (33 cents if no record could be produced). The next year the cost of an enquiry fell to 22 cents. By 1967 CDC boasted state-wide coverage with more than 11 million records. The first step to achieving their goal to permit rapid access to credit information from anywhere in the US occurred in 1969 when the New York office could remotely access credit data from LA.
While centralised reporting spelled the end for the local credit bureau, it was widely assumed in the mid-1960s that banks, retailers and credit card companies would be better positioned to dominate credit reporting. Retailers gradually joined banks as heavy computer users but were not at the forefront of the adoption of new technologies. Banks were far ahead of all other major stakeholders in the market for consumer credit information and had already revolutionised check clearing. What held bankers back though was their conservatism and a long history of strict client confidentiality. In contrast, credit bureaus’ only privacy concerns came from not sharing their best customers. From the beginning many banks declined to participate in local reporting ventures and even when they did they shared only basic identifying information and ballpark figures. Instead, banks relied on their own in-house records and intrabank relationships for customer information.
The problem for the banks at the time though was the sheer volume of consumer credit that their customers were accumulating across charge accounts and credit cards. It was difficult to know a loan applicant’s true financial position without engaging with a credit bureau. In 1965, ACB of A members received about 10% of their income from banks. The mysterious ascent of CDC can be explained by its main subscribers: banks as well as credit card issuing oil companies and national credit card issuers like American Express and Bank of America. CDCs decision to exclude any information about a person’s race, religion, psychological profile or personality, medical records or gossip culled from neighbours was a crucial point of differentiation. The banking industry’s defence of consumer privacy was quite forward looking. This unfortunately didn’t prevent a race to bring American consumers under an increasingly totalising system of private sector surveillance.
There was a furious response across the credit bureau industry as they could see the potential to be cut out of the credit reporting loop altogether. In 1966, a new consortium, Computer Reporting Systems Inc., was formed in LA to help Southern California bureaus compete with CDC and a few years later was computerizing and linking more than 40 bureaus in Arizona, Nevada and Southern California. By 1967, Credit Bureaus Inc. was computerising records across 40 bureaus in Oregon, California, Washington and Idaho. ACB of A’s challenge was that computerisation meant centralisation. Regardless, the Dallas Chilton bureau had IBM 360 computers set up in 1966. The Dallas bureau alone reduced 1 million records stored in 300m2 of office space to a data cell the size of an office waste basket.
Computerisation importantly led to a new alphanumeric “common language” to describe creditworthiness that would address the inconsistencies of historical credit reporting. The most important of these was COBOL (Common Business Orientated Language) that used a reduced character set and naturalistic English language commands. There was still a common problem to be solved though: how to identify an individual. The use of the Social Security number by federal agencies was already expanding in the 1960s and no rules prevented its use outside of government. It’s adoption more broadly was legitimised by the American Bankers Association when in 1968 it recommended it be used for a nationwide personal identification system.
Statistical credit scoring developed in the late 1950s as business consultants and researchers began using computers to create sophisticated scoring systems for major banks and retailers. Computer-assisted credit scoring caused a fundamental shift in the concept and language of creditworthiness, even more so than computerised reporting. Interaction between credit managers and applicants ceased and risk management shifted from a focus on the individual to being a function of abstract statistical risk.
Fair, Isaac and Company succeeded in bringing credit scoring into mainstream commercial practice using the same discriminant analysis used by David Durand in his 1941 study on consumer finance. Founded by two former analysts from the Stanford Research Institute, William Fair was an electrical engineer and Earl Isaac a mathematician. They received a break when one of the nation’s leading consumer finance companies, American Investment Company (AIC) hired them to analyse their credit files.
General Electric Credit Corporation (GECC) had invested $125 million developing credit scoring by 1965 and by 1968, a third of the top 200 banks were using credit scoring and another third considering it. The promise of credit scoring though took time to develop as the determinants of creditworthiness needed to be identified. Credit applications of 40 or more questions became fishing expeditions for worthy metrics. A second problem faced by early adopters was maintaining the validity of scoring systems across different populations. No two businesses were the same because no two businesses dealt with exactly the same borrowers. Even small behavioural or socioeconomic differences could skew results at the risk of disastrous miscalculations. Over time, small changes in a statistical pool of customers caused a model to lose its predictive power. Continual resampling was necessary to adjust the models.
By converting credit decisions into uniform, quantitative rules, scoring systems also allowed managers to quickly generate reports that displayed patterns of profit or loss and the risk of its various portfolios. The comprehensive managerial information system created from credit scoring almost rivalled its main function in importance. While risk-based interest rate pricing was explored and was standard practice in the insurance industry, the real power of credit scoring came from its ability to allow creditors to push credit risk to the furthest limit at the lowest margin and the development of “subprime” lending.
The CDC was acquired by TRW in 1968, a defence industry giant that engineered nuclear missiles and satellites, because they saw an opportunity to acquire a big proprietary database and a dominant position. Over the next two decades, TRW and other large computerised bureaus would develop a dizzying array of credit screening and marketing programs. The FCRA, with it modest requirements and loose definitions, did nothing to address the larger forces that were shaping the future of consumer surveillance.
The rise of data brokers (1970s – 1990s)
During the 1970s databases proliferated and became integral to everyday life in America. By 1974 the government was operating more than 800 databases with more than a 1 billion records on their citizens. Without a legal framework to limit data sharing in any way, consumer information became a gold rush commodity that circulated rapidly between a dizzying array of commercial interests. RCCs name change in 1976 to Equifax signalled this shift to very big consumer data. Each new venture of the big 3 data brokers (incl. TransUnion and Experian) fed data back to their parent entities that boosted customer insights. By 1980, 70% of all consumer credit reports were provided by 5 bureaus. By the end of the 1980s, Equifax earned more 10-20% of its revenue from pre-screening programs designed to convince merchants to accept them and customers to use them.
The integration of credit bureau data into credit scoring models in the mid-1980s allowed the take-up of generic credit models because risk models based on this data were generalisable. Prior to this each bank, retailer or business had to build its own credit scoring models at a cost of $50,000 – $100,000 that then needed to be constantly resampled. In 1989, Fair Isaac introduced a new credit model that would become the industry standard that translated risk rankings into a FICO score between 300 and 900, with higher numbers representing the least risk of default. The adoption of these models by the large listed mortgage lenders, Freddie Mac and Fannie Mae, in 1995 institutionalised the approach.
As credit risk became passe the new focus became customer profitability. It was no longer enough to clear the credit hurdles, you had to clear the “lifetime value” hurdle as well. By the late 1990s all 3 major data brokers had their own risk modelling units and there were literally dozens of generic models that predicted risk and profitability. Delinquency alert models allowed lenders to continuously track the risk and performance of an individual across all their accounts. New scoring models were developed for utility companies, telephone carriers, car dealers, property insurers and healthcare providers.
Credit bureaus finally turned to consumers themselves to sell services that helped them monitor their credit reputations. TRW (Experian) was the first in 1986 with a $35 per year subscription that offered access to your own credit reports, automatic notifications when your credit records were queried, and a special service for cancelling lost or stolen credit cards. The program was heavily advertised and quickly enrolled 250,000 subscribers in California alone. Critics of the program noted you could already buy a copy of your credit report for a nominal fee, and bureaus were simple shifting their costs to consumers, because its necessity was driven by their own inability to protect their data. They also used the service to gather yet more information from subscribers they could then repackage and sell.
The release of the Lotus Marketplace CD that sold for $700 in 1990 and contained profiles for 120 million adults and 80 million households that combined census data, postal service data, consumer surveys and Equifax’s own credit files, led to the first example of a privacy protest in America. Equifax decided to scuttle the product because of the uproar it caused but didn’t understand what all the fuss was about when all of this information on consumers was readily available. Credit bureaus had to abandon their marketing list businesses in the 1990s as they were slapped with multiple government lawsuits, but a key concession allowed them to continue to sell personal information (name, phone, zip code, birth date, social security number etc.). By then this kind of information was even being sold by the banks. The boundaries between credit bureaus and financial institutions had collapsed. In 1999, the CEO of Sun Microsystems, Scott McNealy, summed it up bluntly: “You have zero privacy anyway – get over it”.
If the issue of privacy has been such a low priority for so long in the US then it does make you wonder why it took until 2016 for the European Union to create it’s General Data Protection Regulations. The 3 dominant data brokers have been exploiting a lack of coordination and development on global privacy laws for decades.
Australia has a great opportunity after the recent review of our privacy laws to make amends for the slow pace of development of our privacy rights. It will also present a huge commercial opportunity for the forward thinking amongst us if we do.