Episode 5: The Shutdown Episode

In this episode of Asset Management Corner, Andrew Dean and Chris Mulligan discuss how the federal government shutdown impacts the SEC, even if it is short lived, and how we did not see the SEC bring the typical flurry of enforcement actions at the end of its fiscal year. Later, Tana Ryan, a partner in Weil’s Private Equity practice and the Managing Partner of Weil’s Los Angeles office, joins them to talk M&A dealmaking trends and give her perspectives on the regulatory environment.

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Transcript

Andrew Dean: Hello and welcome back to Asset Management Corner. We are your hosts. I'm Andrew Dean. He's Chris Mulligan. We are partners at the Law Firm Weil. This is the podcast where we bring our experiences as former SEC officials in the Division of Exams and Enforcement and talk all things SEC and asset management. On today's podcast, we're joined by a special guest, Tana Ryan, a partner in Weil's private equity practice, who will talk to us about some of the trends in M&A dealmaking and her thoughts on the regulatory environment. But first, Chris. They shut it down. We are recording this a couple of days after the government shutdown. Maybe it'll be up and running by the time this drops. That means the SEC is also shut down. We've experienced, Chris, a couple of shutdowns during our time. How many shutdowns did we live through?

Chris Mulligan: I think I was part of three. One really long one. The last one was definitely the longest at the SEC in, I think, early 2019.

Andrew Dean: Started 18 into 19, 35 days. Chris, what did you do with your 35 days?

Chris Mulligan: It was pretty busy because my wife was in the final trimester of our third child. So I was very busy with the other two. And right as the shutdown ended, actually, we were fortunate to have our third child. So I don't have memories of like taking vacations or doing anything fun. It was a pretty busy time for me during the last shutdown.

Andrew Dean: You had a shutdown baby. Nice. So I was busy as well. My kids were a little bit older and my wife was gracious enough to let me take a road trip to Vegas for a couple of days. So that's how I spent a couple of days of my 2018 shutdown. So look, we'll hit that as the first topic because it is sort of interesting and people ask us about it sometimes. So we'll just give you some of the color. During an actual shutdown, the SEC only keeps a few 100 staff active, focusing on urgent enforcement matters, halting most IPO reviews and corporate filing sign-offs. It's actually illegal, Chris, for the SEC to work unless they are deemed to be essential employees. Personally, I was never deemed essential until I was a senior officer. My last couple of years at the SEC, I always felt like it was essential, but apparently I was not nearly as important most of the time as I thought I might have been because the standard to be essential is to protect life and liberty, a higher standard than one might expect what that means. That meant that most enforcement investigations and examinations stop. And once the shutdown happens, some staff may have up to a business day to kind of get things in order before they can no longer work. Shutdowns, impacts at the SEC, even if they are short-lived, or even if they're averted at the last minute, do have an impact packed in the weeks before shutdowns. Management has to identify who's going to be essential. On the enforcement side, that means going through all the litigation dockets, making sure court filings won't be missed, trying to predict how long the shutdown may go. People could be added and removed from the essential list, but you're not allowed to check your emails if you are not on the essential list, so it creates some complication. Trial counsel are oftentimes deemed essential for that reason. For investigations, the staff have to comb through cases to see if there's any upcoming deadlines like statute limitations issues, or whether there are deadlines in WELS notifications, and really try and address any of those issues early. Chris, on the exams and investment management side, what happens during a shutdown?

Chris Mulligan: Yeah, I went through a shutdown when I was in the Division of Investment Management and also when I was in the Division of Examinations. Like I said, the Division of Examinations, if you're in the middle of an examination, it will basically stop. I think enforcement's a little more complicated, but in exams, you'll receive a letter probably the day after the shutdown. You've probably already received it saying, you know, until you hear otherwise, pens are down on this examination. If you try to communicate with the exam staff, you're likely to get this sort of very official response, auto e-mail back saying the government has shut down and they can't respond to you. I would say, however, to still try to go ahead and meet the deadlines unless you are specifically told not to. So sometimes exam staff will say, we know there's a deadline coming up. If the government is still shut down, don't send those documents. No one will be looking at them. Other times they won't say anything at all, or they'll say, please try and meet the deadlines. So unless you hear to stop on a current production, my advice is to go ahead and to continue to try to meet those deadlines as best you can until you hear otherwise. It obviously is a big disruption to an examination, right? And while it can seem to be a good thing, you know, oftentimes registrants are just trying to get exams over with as quickly as possible. And to your earlier point, Andrew, you know, a one or two week delay, a shutdown can often lead to a much longer delay in the exam because when they come back, they kind of have to restart a lot of things. And so it can cause a pretty significant delay in the exam. On the investment management side, I think this is really not a well-timed shutdown because investment management has so much to do. Very ambitious rulemaking agenda. Now, it's deregulatory, but we've talked about this before. Taking away a rule is just about as difficult as creating a new rule, right? But still the same process of rulemaking on the deregulatory side. And there's a very, very ambitious rulemaking agenda that IM has that will just all basically stop during the shutdown. So this is not great timing considering the ambitions of the Division of Investment Management.

Andrew Dean: Yeah, and I agree, Chris. Once the shutdown ends, it does take a while for the staff to kind of ramp back up. And I think for exams and enforcement, I think that can also be frustrating because it's going to cause delay. Like, if your case should be off-ramp, the investigation should be ended, that's just kind of delay that from happening. And it may take longer for the staff to kind of get around to dealing with you again, as e-mails and other things may have piled up while they were out. We're also, Chris, days now past the end of the fiscal year, and the shutdown may, in some ways, have overshadowed the fact that we just passed the end of that fiscal year. And in the recent past, regardless of the commission, we see a flurry of enforcement actions announced at the end of the fiscal year. Not so this year. In the weeks leading up to September 30, we did see some litigated complaints filed by the SEC alleging violations like Ponzi schemes, offering frauds, but nothing like the aggregate number of cases that we've seen in years past. Of note, since our last podcast, we did see this commission's first negligence-based 20648 charge in a matter. Chris, some said it couldn't be done. Some questioned whether or not this commission would do a negligence-based 20648, given some of Commissioner Atkins' prior views on whether scientia is required, knowledge or recklessness for that charge. And now, while it seems like for this case at least, there was -- negligence was sufficient. We will keep an eye on it. Sometimes it takes a while for trends to be clear. But, so far, the first 20648 case is -- negligence is out there. But I will say, Chris, and I think you and I have seen this a lot in the past weeks, even with the dearth of enforcement actions that have been put out by this commission in the last weeks, enforcement is very, very active right now. We have seen a number of significant investigations open in the asset management space. We're hearing a lot from the market on this topic. And so I think even though the cases may not be out there, we are seeing and hearing a lot of investigations that are going on. And I know, Chris, that you're also seeing a ton on the exam side.

Chris Mulligan: Yeah, I think, maybe this shouldn't be surprising. I know we talked about earlier this summer on a podcast about how exam activity in the spring and early summer was about as busy as we've seen it. And now we're seeing sort of the consequences of some of that. And we're seeing a very busy division of enforcement. So I can't say I'm terribly surprised, but I think some of the issues that we're seeing raised are the types of issues we saw under the previous administration. And some of the announced actions that we're seeing are some of the similar issues that we've seen under a prior administration. So it's a little surprising in that sense, but it sort of matches the pattern we saw initially on exams, and now we're seeing that in enforcement. There's three other issues I wanted to add with respect to recent activity from the Division of Investment Management and the Division of Exams. First of all, very recently, Form PF amendments. This is a set of amendments that was very challenging, requires you to disaggregate all of your private funds, a lot of questions about trading vehicles, a lot of complaints about this round of revisions to Form PF. Those were delayed again. They're about to kick in this October. They were delayed another year now until October 1st, 2026. In addition, very challenging remarks from a couple of the commissioners about this round of amendments indicating that they are going to look at these amendments, maybe the entire form. And so the delay effectively buys them another year to look at those amendments and perhaps make changes. Regulation SP, we've talked about this at length. Our last podcast, we spent a lot of time on Regulation SP. I think we got the clearest signal that the Division of Investment Management and Division of Exams could send. They held a training on Reg SP in preparation of the December deadline. It was a really great training on SEC's website. Joe Murphy, one of my old colleagues, led it. was a really, really great training going over Regulation SP. But I think that's a pretty strong signal that they are not looking at any sort of significant delay. to the December deadline for the amendments to Regulation SP. And in the last podcast, we spent a lot of time talking about the substance of what SP requires. We also saw a new no action letter on crypto assets in custody. What originally came out, there was a lot of excitement that this would deal with self-custody and of crypto assets, really kind of deal with the real challenges that private fund advisors, the trade and crypto deal with. It wasn't exactly that. It was a pretty narrow, no action letter. It was helpful. What it effectively did was clarify that a state trust company, many of which have options to custody to hold crypto assets, is considered a bank under the custody rule, under the definition of qualified custodian. That means that a lot of these state trust companies that have created the opportunity to maintain crypto assets with them, if you do that, you are in compliance with the custody rule with respect to whether or not they are qualified custodians. So helpful, pretty narrow, but I suspect this is sort of the first move in terms of a longer term project of dealing with the custody rule kind of wholesale, but particularly with respect to crypto assets. And now that we know that state trust companies are banks under the custody rule and are qualified custodians, that might help make the other moves a little bit easier. And finally, on exams, we are beginning to see inquiries from the Division of Examinations into interval funds. Interval funds have become very, very popular as part of the retailization of private fund and alternative assets that we've talked about. So this is not surprising to see the Division of Examinations take a lot of interest in interval funds. funds, but we are beginning to see that line of inquiry underway. And as we learn more about what they're looking for and what issues they're looking for, of course, we'll be happy to share those.

Andrew Dean: Yeah, Chris, I was recently in Chicago for something and Bruce Carton's securities enforcement docket and a lot of chatter about interval funds and those exams and inquiries going around. So it's something we've predicted will be more resources focused in that space. So sure enough.

Chris Mulligan: All right. I shouldn't say this, but next up is my favorite partner at Weil, Tana Ryan is a partner in Weil's private equity practice and is managing partner of our Los Angeles office. She advises private equity funds and public and private portfolio companies. on a variety of corporate transactions. She's been recognized by basically everyone, Chambers, everyone else as one of the best private equity lawyers in the country. She is described as super sharp and great to have as a partner in negotiation. She was named as one of the top 100 lawyers in Los Angeles by the Los Angeles Business Journal. And she is just an absolute joy to work with. We've been fortunate to partner together on a lot of clients on the regulatory issues and the private equity execution issues. So we're just delighted to have her with us. Welcome, Janet.

Tana Ryan: Thanks so much for having me, Chris and Andrew. It's always great to talk to you guys about all things private equity and especially the world of deals and regulatory intersection with them. So I'm thrilled to be here.

Chris Mulligan: Perfect. All right, Tana, what's going on out there? It seems like we're getting a lot of mixed messages, but what's happening in the private equity M&A space?

Tana Ryan: Oh, it's so simple. We'll easily sum it up in one podcast, guys. We'll save the private equity M&A world here today between the three of us, I'm sure of it. No, it's obviously a bit of an understatement to say that this has been a very interesting year for private equity generally, and in particular in the M&A space. I feel like for the last couple of years, every year, Q4, private equity M&A attorneys, maybe we're just eternal optimists, but we often expect deal volume to rise going into the next year. End of 2024 was no different. I think there was a lot of talk in the market about how what had been a slightly bearish market was going to become a bull market, and we were all chomping at the bit. And I think, as everybody knows, when the Trump administration came in, it just had more of an impact on uncertainty than I think people had anticipated. As a result, I think most private equity M&A practitioners and market trackers would tell you that deal volume in the first part of this year was surprisingly low. I believe some folks have said that it may have been the lowest in a decade. So it was a pretty choppy market in the beginning of the year. Deals were still absolutely getting done. If there was a compelling reason for a seller to be to market, they were to market. If there was a particular industry element or other transaction that had a bespoke nature that was driving something to get done, it was getting done. And so interestingly, even though deal volume was down. Most stats show that deal size was actually up because I think the deals that needed to get done were getting done. But it was overall a pretty choppy, challenging market. That is really starting to kind of break through now that we're getting into end of Q3, Q4. We are just getting stats. Obviously, it's only been a few days since the quarter closed, but already major deal trackers are releasing the stats for Q3, and we are already seeing a very significant uptick in volume. And we also saw that here at Weil. And I think people are thinking that trend is going to continue into Q4. So it's pretty interesting. There is definitely now a momentum and a trajectory in the market that we weren't seeing in the first half of the year, probably due in part to people kind of understanding the new administration and the market a little bit better and some other, I think, interesting trends that are worth discussing.

Chris Mulligan: Yeah, so that's really interesting. So we've gone from sort of a bespoke, very limited deal market to one that sounds like it's becoming more normal, more robust. towards the end of the year? Is it an economic factor? Is it a psychological factor? What do you think is explaining the uptick in the deoctivity?

Tana Ryan: Yeah, certainly if I knew for certain, I'd quit this job and I'd go take my magic prognosticating tools on the road and just do that for a living. So I can't be certain. But I do think that those of us that have been doing this for a number of years and have kind of watched the trends, would say that there's a number of factors. A lot of times when we see deal volume changes, it's often driven both by market uncertainty, which we already discussed a little bit, and also by interest rates, inflation, the typical measures that we use for a healthy market and a healthy economy. I think this year, it really does feel like it might be driven by something a little more novel. My best guess, and I think I've seen this in other press as well, is that we might be seeing an increase in volume through the fact that funds are out there to market trying to raise capital right now. That happens, of course, year over year. You know, when a fund runs out of cash and it needs more capital, that's not something you can really totally control. And so you go to market on your fundraise when you go to market on your fundraise. And this year's fundraising market has been, I think, particularly challenging. There's a new metric that, it's not really a new metric, but it's a metric that's got a new emphasis, I feel like on the fundraising side, which is DPI. Distributed to paid in capital is really getting a lot more attention than it used to. A lot of fundraise focus was on TVPI, IRR, you know, general kind of like portfolio health. And I think DPI taking a front seat has meant that liquidity is the name of the game for a lot of these fund sponsors. They really do need to show cash in, cash out sort of models now.

Chris Mulligan: And as someone who partially who spends a lot of his day reviewing marketing materials, I can confirm that DPI is definitely a very, very hot metric in marketing materials.

Tana Ryan: Yeah, exactly, I feel like it was something where if I was talking to people two, three years ago on the fundraise, was it in there somewhere? Sure, but was it as prominent and as focused on by LPs as it is now? I don't think it was. And part of that may also be, that's a bigger discussion for another day. I'm sure you guys will talk to some of our funds folks about that more, about how the fund market has gotten more competitive and interesting and people really kind of holding sponsors a little more to task on kind of hitting liquidity goals and timelines. But look, I think that could be a major factor in why we are seeing deal volume pick up. Plain and simple, sponsors need to show that they've generated some kind of liquidity. And so that could mean traditional acquisition sale activity, but that could also mean things like dividend recaps, that could mean things like division sales, carve-outs, other bespoke transactions. So I think that was probably a little bit of the activity in the early part of the year, but really, I think that's probably driving a lot of people just getting back out to market in a more traditional way and generating transactions. So I think this liquidity focus is going to continue to be a theme that carries us into 2026. And I think it's going to mean that people can't really sit by the sidelines anymore and they actually need to transact one way or another. And so we're going to see more realistic expectations from sellers, a little bit more of a hopefully buyer-friendly market that gets transactions done that we've all been waiting to see happen.

Chris Mulligan: So what kind of deals are getting done? I know we, Weil has this really cool tool, Deal Vision 360, that, it's proprietary to Weil, has some really cool information on it, gives us kind of a sense of the marketplace. But using that in your own personal experience, what types of deals are getting done in this market that's sort of returning to normal, but not completely?

Tana Ryan: It's a great question, right? Like not all deals are created equal, and certainly some industries and some types of transactions are getting more trajectory than others. I did spend some time with DealVision 360 that you mentioned, Chris, before this. DealVision, just to talk about that for a moment, super amazing, wild-specific tool that we've been rolling out over the last several months. It actually was a finalist for the best use of legal technology by the American lawyer. Really kind of a cutting edge item. We're basically taking here at Weil our deal data as well as all the deal data that is publicly available and able to be collected through market studies and surveys. And we're using that through an AI enhanced analytics program to synthesize that. So you're really talking about thousands upon thousands of deals. and we're able to very easily look for trends and kind of slice and dice what we're seeing in terms of the deal market and understand both what we're seeing currently and what that speaks to what might be to come. So I took a look at our latest information from DealVision and also thought a little bit about what I've been seeing. And there are certainly, I think, some industries that just continue to maintain volume and activity even when other industries are a little quieter. A big one that always ends up being there is, I think, healthcare. What we're seeing interestingly now in the healthcare space is a little more of a focus on the technological aspects of healthcare, app-based work, things that are bringing fintech and healthcare together. I feel like a couple years ago, maybe the more traditional healthcare deals, physician businesses and the like were a little more popular. Now I think it might be in part because the software market still remains a little flat and soft, that some of our software folks are kind of taking that and taking a spin towards a healthcare angle, but we are definitely seeing a continued trend in healthcare and healthcare tech deals. So I think that one is one that just, it continues to produce despite other market metrics. There's some other areas where I think they are being driven by current trends in a more interesting way. A big one with no surprise, I mean, AI is the theme of the year, right? Whether you're talking about legal, whether you're talking about making your grocery list, whether you're talking about, you know, whether or not robots are going to be folding your laundry in the next few years, AI is on everybody's mind. And the deal market's no different. So AI-based technology companies are being looked at and the right ones are being snapped up. Also, interestingly, AI infrastructure, meaning power and supply chain for power areas are really been really strong in the past year. There's a lot of work being done to, I think everybody knows this at this point, but like an AI search takes 6 times as much energy as a normal search engine just Googling something, right? All that power's got to come from somewhere. The U.S. government's projections now on our needs on our power grid for the first time in, I think, more than a decade have actually shown that we're going to need an increase in power despite more power efficiencies being generated through technological increases in power efficiency. So given that, you're seeing a lot of both what we call in front of the meter, which is power projects involving utilities, but also behind the meter, which is power projects paid for by major software and technology companies that are developing AI tools that want their own self-serving power sources. being a very popular space for folks to invest in. And it's an industry that a year ago was there, but is now growing in a really behemoth fashion in the new market. So I think that's a hot one as well.

Chris Mulligan: I can attest to that. As someone who lives in Northern Virginia, Northern Virginia has basically been taken over by data centers and AI facilities. So that certainly seems like a hot area from my perspective.

Andrew Dean: Also the number of podcasts that talk about AI, as we did last time.

Tana Ryan: This podcast itself probably generate more deals for all of us with its energy usage. So there you go. So there are things like that I think are kind of just social trends that are translating into the deal market. And then I think the last area that's worth touching on is, of course, again, going back to administration and government-led trends. I think we're seeing an uptick in certain spaces around aerospace and defense. I think that there's a thought that tariffs and other focuses on international involvement in our markets is going to create certain supply chain elements within the aerospace and defense industries that are more domestic. I think it's going to drive up some volume for those businesses. And so I think people are thinking that's a great spot to invest. right now. And similarly, outside of kind of, general government trends, we just see that there's been in the world of sports and entertainment and the hospitality industries, there's been rule changes. There's been behavior changes following the pandemic where everything from new rules for investing in the NFL, right, to new interest in women's sports, to new interest in people wanting to go back to kind of a mega complex entertainment experience, all of these trends in the entertainment, sports, and media space, which is something that Weil's leaning into heavily right now for the same reasons, we're really seeing a deal uptick there. And we're starting to see really interesting transactions there. Again, going back to that theme of where if there's not a market yet, sometimes we see people making markets to maintain and sustain liquidity. In that space, Arctos just announced, right, the Arctos Capital Markets Platform, where they're going to be doing transactions where they're pairing sports teams with high net worth individuals and capitalizing on those kinds of transactions. So... The innovation you're seeing in response to government changes, societal changes, that's always going to feed into our M&A markets. And I think those are the main areas where I'm seeing a lot of interesting growth and activity that's keeping the deal space alive and is starting to bring back volume.

Chris Mulligan: That's really interesting. A lot of exciting things going on in the deal market. You know, where Andrew and I often get involved is SEC examinations, SEC enforcement actions, interpretation of limited partnership agreements. sort of like SEC regulatory issues. And so much of this activity is driven by registered investment advisors to private equity fund advisors. So our worlds intersect an increasing amount. And that's really interesting. I think it benefits both of our practices and it's sort of an exciting time on the regulatory side and on the deal execution side. But it's also important to remember that by regulatory lowercase R, that's a lot of stuff, right? It's more than just the SEC, a lot more than just the SEC. It's more than securities law. laws. It's more than SEC investigations. There's so many regulations that come from so many government agencies at the federal level and the state level that impact transactions. It's a very complicated process. I'm in our DC office and our floor is just with people who are CFIUS experts and environmental law experts and whatever sort of like niche government regulation there is, like we have an expert like on this floor. And could you talk about how you interact with all of us and how this all comes together on these transactions?

Tana Ryan: Yeah, no, that's, it's a really great point. And it's one of the reasons why I love working with you guys, because I think that there was a time where in the private equity space, doing the transaction versus doing the fundraise versus dealing with the regulatory framework and the kind of scrutiny that was faced all kind of operated, I think, somewhat in a siloed way. We weren't really as integrated as we need to be now. But you're absolutely right, Chris, that one of the reasons I feel like I'm talking to you guys every week is because there is more regulatory activity every day that's feeding into the M&A aspects of private equity. And for fund managers, that's now really getting integrated, I think, if you're doing it the right way, into how you approach your fundraise and your regulatory planning with the SEC, because these things are all interrelated. You need to be able to have your LPs ready to comply with what I'm going to need to get an M&A deal done sometimes. There's greater scrutiny on ownership. Certainly this current administration has shown that they care about foreign citizenship, investing in U.S. assets and what information's available and what kind of, you know, there's a lot of things here that really kind of intertwine. And it's no longer, I think, is viable to think about the fund side of the regulations and not also think about how the M&A transactions that those funds are doing are going to get regulated and how that's going to impact the fund side of the house. So it really is important we work together. To your exact point, we are seeing more regulation generally on transactions. I think at the highest level, when we think about kind of at a federal type level, you really still have, I think, two big drivers that haven't changed in terms of being the most important elements, but how they are working has changed. And that is antitrust and CFIUS. So antitrust, as I think a lot of folks know, the new rules that were created by the Biden administration went into effect early February of this year. And it's a whole new ballgame, a new level of disclosure that needs to be given to the DOJ to get a transaction done. And it's something that we're all navigating and learning about together, both, frankly, the agency that's been given this mandate and those of us that are providing the data. And so that has been a A really interesting aspect to deal with in the day-to-day transactions that require HSR review is just how the HSR process has evolved and changed. And people are starting to get their arms around it, but it definitely has taken some time to understand the new format of a typical HSR filing that was otherwise, I think, pretty much static for decades. On the CFIA side of the house, I think the first Trump administration made it very clear that not all foreign investment is going to be treated equally. There was a big focus on Chinese investment in the first Trump administration. This administration announced in February that there certainly would be greater scrutiny from a CFIUS and, quote-unquote, general agency perspective. So it's unclear what that means in terms of who's going to be involved, but that there would be greater insight into foreign investment by certain countries. And there would be, I don't want to call it a favoritism, but certainly some different standard applied to allies and other countries that had stronger relationships with the United States. So that is something on a deal-by-deal basis, people are navigating, and there is certainly a sensitivity to that. So certainly the federal level, these are not new words, antitrust, HSR, CFIUS, you know, but I think what they mean in this current state of the world is evolving and changing. And that definitely feeds directly into what we need from our sponsors and our LPs as we do transactions. On a similar basis, and probably a more novel basis, we're really seeing an uptick in state-based regulation. And that's one that I think, if you asked me about a handful of years ago, I wouldn't have been nearly as focused on, but I do think we are seeing that states are becoming more bullish about kind of making their own structures that you have to comply with for transactions, which really kind of makes it pretty complicated to do some of the larger deals we do, which can touch on so many states at once when you're doing a multi-billion dollar transaction. What they're looking at varies. AI privacy, once again, those are hotbeds. So lots of states are creating their own regulations in those spaces. Healthcare, as I mentioned, is a popular deal space. The practice of medicine is regulated often at a state. or sometimes even county level, and so you have activity there. Possibly the most interesting is we weren't really expecting a lot of state activity in antitrust. Historically, you know, the states have left that more to the federal level, but we are seeing states getting more involved with their own antitrust regulations. And the flip side to that is anti-competition concerns generally at the state level. We are seeing a skyrocketing number of states who are creating very state-specific regimes around what is acceptable from a non-competition, non-solicitation kind of drawing of the lines of your industry kind of framework. And if you are buying a business and you're expecting that business to be able to grow and change and expand into markets, those can obviously be very, very relevant to your investment thesis. And so we're having to get ahead of those and do a little bit of predicting on what the future is going to hold because it does impact industry growth and company growth. So it's really an interesting time from a regulatory perspective overall, and it's not surprising that You may occasionally see somebody running by your office with their hair literally on fire because there's probably some new regulation that they're worrying about.

Chris Mulligan: All right. Well, thanks so much, Tana. And on a fun note, is there a TV show or a movie or a book that you're reading right now that you're really into? Like your whole life can't be deals, right? Is there something you're really into right now in pop culture?

Tana Ryan: That's a tough one. I don't know. I haven't been going out to the movies enough, so maybe I'm doing a bad job of beating those big mega complex seals. But I guess probably the thing that's got me the most excited is football's back. And so I'll be heading to the Rams game later today to watch a stomp out the 49ers, which is the only possible conclusion to that game. And now that I've said that in a recording, I know I'm going to regret that when this recording comes out.

Chris Mulligan: Are you going to the stadium tonight?

Tana Ryan: I am indeed. Yep. I will.

Chris Mulligan: I heard that's a beautiful stadium. I want to get out there. Maybe you can give me tickets. Maybe you can get Andrew and meet both tickets.

Tana Ryan: SoFi is, I think, the best stadium in the country. And I think it's pretty imperative that we do some PEM&A and regulatory deep discussions over, you know, a cold beverage and a good game. So I think you guys should come on out.

Chris Mulligan: Count me in. Thanks so much, Tana.

Andrew Dean: We've been dying 5 episodes in to talk sports on a podcast. This is... We finally did it. We finally did it. We could have done this for the full hour.

Tana Ryan: All you had to do was get a woman on, guys, and then we'll get the sports going. So it was really great talking with you guys.

Andrew Dean: This is great. Thanks so much. So I learned today that we have something very cool called DealVision 360. I realized that we may need to, Chris, rename the podcast Asset Management 360. Right now, we're only in a corner. So with that, thanks for joining us, and we'll catch you next time. The information contained in this podcast is provided for informational purposes only and does not constitute legal advice. Listening to this podcast does not create an attorney-client relationship. You should consult A qualified legal professional with any questions. This podcast may be considered attorney advertising under the law of certain jurisdictions.