Business Elevated Podcast (Episode 4)

This podcast is the fourth in a series featuring business and government leaders discussing what it’s like to live and work in the great state of Utah.

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Audio

Transcript

Introduction

Welcome to the Business Elevated Podcast, where we discuss what it’s like to live and work in the great state of Utah. Did you know Utah is frequently ranked the best state for business by Forbes? This podcast is a production of the Utah Governor’s Office of Economic Development. Thanks for joining the conversation.

Conversation

Clark Cahoon (0:20): Hi, my name is Clark Cahoon. I’m with the Utah Governor’s Office of Economic Development and you’re listening to the Business Elevated Podcast put together by our office. Today, we’re going to be having a conversation with Patrick Mullen. He’s with the Utah Association of Counties and we’re going to be specifically talking about Opportunity Zones and what that means here in the state.

A little bit of background to kind of lead up to it. This came about from the tax cuts and jobs act that was passed in the last couple of years and we’re going to be finding out a little bit more about what the implications are for Utah, what an Opportunity Zone is, and a whole lot more information. So I’m going to turn the time over to Patrick, and have him tell us a little bit about what the Utah Association of Counties is and the work he’s doing with Opportunity Zones.

Patrick Mullen (1:08): Great. Well, thanks Clark. It’s a pleasure to be on the podcast and maybe before I tell you about the association and the work that we’re doing, I’ll give you a little context on the opportunities and legislation and how it came to be, and as you mentioned, this was part of the tax cuts and jobs act that happened at the very beginning of 2018, end of 2017. But it was really the culmination of an effort that has been going on for the last four or five years and it was a group in Washington, D.C. called the Economic Innovation Group, which was actually founded by, of all people, Sean Parker of Facebook and Napster fame.

Clark Cahoon (1:42): Interesting.

Patrick Mullen (1:42): What they were working on was this concept of looking at all of America post-2008, right? We had this great recession. We saw huge economic uptick, obviously here in Utah, we saw a lot of it, right? It’s been a very prosperous decade-plus since. But what they were specifically curious about was, well, what’s the rest of the country like? What are the places that are not San Francisco, Boston, New York, Austin, Texas. What do they look like? What they expected was probably to see slower growth, and what they found was actually negative growth. People were leaving these cities, they were losing jobs, businesses were shutting down and part of the reasons behind that was a lot of folks said we just can’t get access to investor capital. Every investor we go to talk to, whether it’s a real estate investor or a business investor or whoever it was, say, “I don’t want to take the added risk of going to a place that, you know, maybe needs the help but isn’t growing as fast as some of these bigger markets.”

So the idea came to be that, well, what if you could create an incentive to bring investor capital back into these communities and so the idea of Opportunity Zones actually happened long before the tax cuts and jobs act. I know there were several tries to get this done in previous administrations and obviously congress is a very tough body to move legislation through. So it kind of started and stopped multiple times. But low and behold, with strong bipartisan support, this passed at the end of 2017 and what it did was it allowed the governors to select 25 percent of the low income census tracts in their state to be eligible as an Opportunity Zone.

So, in Utah, that meant we had 181 eligible Zones. So that means 181 eligible census tracts, which were federally defined as low-income and Governor Herbert could select 46, or 25 percent. The way the governor ran the process here is he worked with the Associations of Government or their regional bodies of counties to basically say, “Run your own localized nomination process, take all of your eligible tracks, select the 25 percent you think make the most sense, and send them to my office.”

Clark Cahoon (3:40): So, from what I understand, this wasn’t a top-down decision. This was kind of putting the power in these different regions all around the state and saying, “Hey, you know these areas better than maybe we do here up to the Capitol, but can you give us some feedback on where these Zones should be focused on?”

Patrick Mullen (3:55): Yep. Yeah, no, that’s a good point. I think unlike some other states that ran very top-heavy approaches, some even just did straight kind of research analysis and set a formula [that said] “We should pick these Zones, so we’ll do it.” I give the governor’s office a lot of credit for running a very localized process and at the end of the day, I think everybody wishes we had more. I mean, we did what we could within the federal regulations, but I think they ran a very good process to select them.

Clark Cahoon (4:20): Yeah, I think a collaborative approach is always going to be beneficial, especially as you look back and try to figure out the questions, okay, why this zone over this zone and being able to answer some of those questions that are coming up as a process is moving forward. But, yeah, that’s good to know that the governor kind of put the power into these different regions all around the state to come together to kind of pick those specific regions.

Patrick Mullen (4:41): Yep, and you might be asking, and I’m sure your listeners are probably saying, “Wait, what about this whole investment incentive? Isn’t that what this is? We’re just talking about how they were selected.” I think what’s really interesting about the excitement around what Opportunities Zones are, is they are essentially are an incentive to private investors to take their capital gains dollars and defer taxes on them by investing into qualified projects in these newly designated zones. So across the United States, there’s over 8,700 Zones. So if you think about Utah’s 46, we’re just a fraction of that, but we’re actually ranked pretty highly from an investability and attractiveness standpoint. There’s some rankings out there that puts cities like Salt Lake and Ogden in the top five, top 15. The state of Utah overall, I know it was ranked three or four compared to all the other states.

So a lot of people are looking to us to figure out what they can do and what they get as the benefit for investing in Opportunity Zones is kind of three things. The first one is you defer any taxes you would have on a capital gain. So think, you’re selling a building or selling a portfolio of stocks, something that creates a capital gain. By putting it into a fund and if that fund goes and invests in a project that’s in one of these Zones, that meets a criteria that we’ll get into a little bit later, you don’t pay any taxes upfront. If you stay in that fund for five years, that initial tax bill you had gets a 10 point step-up in basis or essentially a 10 percent discount. If you stay for seven, that 10 points moves to 15 but if you stay for 10 years, if you’re truly a patient investor, spending a decade in this fund, you not only just pay your original tax less the 15 point step-up, but any new tax you have, let’s say you invested $1 million on day one, 10 years from now it’s worth $10 million, you pay no tax whatsoever.

So if you think about the investment community across the country, real estate investors, business investors, kind of hard asset investors and things like solar and wind are looking at projects and saying, “Wow, if I can go to one of these Zones, you’re telling me that 10 years from now whatever that new gain is, I pay no tax? Sign me up!”

Clark Cahoon (6:45): So this isn’t a short-term solution. This is really trying to figure out what we can do to have investment stay in these Zones and really kind of move things in the right direction for a long-term kind of focus for economic development?

Patrick Mullen (6:57): Yeah, it’s bring new money into the Zones and bring patient money into the Zones. Actually the majority of what we’re seeing in the early days of this is a lot of real estate investing, but how it was sold to Congress in the first place was actually as a job creator and as a new business driver. So we’re hopeful that we see a lot more business investing going, but kind of walking through the very high level regulatory framework because this gets very complicated very quick. The way they keep the capital patient and the way they drive it towards creating new initiatives is it’s a self-certification on the taxpayer’s part to the IRS. So if I sell something that creates a gain, it’s a pretty simple form that I say, “Hey, I’m forming a fund or I’m putting my money into another fund that’s going to go do these investments.”

But it’s actually the United States Treasury that then oversees this and the first test that they look to do is it’s a 90 percent deployment test. So they regulate you semi-annually for the life of the fund. So every six months you’re being regulated by Treasury and the first thing they come and do and look at is they say, “Are you 90 percent deployed?” What that means is, has 90 percent of the cash you put into the fund actually been invested because they want to avoid people using this as just a tax deferment where you hold onto the money and you’re supposedly looking for investments but you just can’t find the right one.

Clark Cahoon (8:11): So this tool is regulated, but the regulation isn’t stifling the opportunity for the people that are making the investments but it kind of goes along the lifetime of the investment long-term, so five, seven or 10 years?

Patrick Mullen (8:24): Yeah, to make sure that the investments are going into the right types of things. So that, moving further down the regulatory kind of chain, if you’re going to invest into owning what is called qualified Opportunity Zones business property, which is the real estate piece, you either have to be passing a test called the original use test, which is the original use of your fund coincides with constructing a building. So you basically have to build something brand new or there was nothing or if you’re buying an existing structure you have to pass the substantial improvement test, which means investing an amount equal to the building’s value in the first 30 months. So, if you buy a building for let’s say $2 million, you can subtract the land cost, but then you have to reinvest the building’s value in the first two-and-a-half years ‘cause they want to see you improve it and do something with it. Not just go buy, let’s say a parking garage that’s never going to leave the community, and you’re really just doing it to shelter your taxes. You have to be adding value to these communities.

Clark Cahoon (9:20): So with that, you mentioned that real estate is one of the aspects. What are some of the other things that we’re seeing people, investors, utilizing this tool with?

Patrick Mullen (9:28): Well, there’s certainly a lot of investors who are anxious to use this as a tool to invest in businesses themselves. So businesses in the Zone can qualify. Again, there’s a lot of regulatory framework around this, but the high-level piece of how it’s written now is there’s a gross income test. So greater than 50 percent of the business’s gross income has to come from activity within the Zones across the country. That’s plural, it doesn’t have to be just in the one that they’re operating in and substantially all of their assets or 70 percent have to be located in the Zones.

Patrick Mullen (10:01): Now, this is actually a point that may be addressed by Treasury. So we’re at the point right now where there’s enough rules that there are certainly deals happening across the United States. There’s even deals happening here in Utah, but there’s a large number of investors, particularly on the business investing side who are still waiting for Treasury to come out with the next round of regulations. I think a common theme throughout this entire legislation is that, because people had been working on this for so long and so hard that when it passed, it actually kind of was very sudden. People didn’t really expect that it would be thrown into the bill. So even the governors only had 90 days to select these Zones when it first happened.

Clark Cahoon (10:42): It’s pretty quick turnaround to put this all together.

Patrick Mullen (10:45): Yeah, and the regulators, particularly Treasury and the IRS and everyone who has been involved. I think very quickly realized this is going to be very complex because you’re going to be dealing with very specific, very custom investments and on one hand, the reason you have these 50 percent income tests, these 70 percent asset tests is they explicitly don’t want to see large corporations use this, right? This isn’t necessarily designed to bring in the Walmarts, the Amazons. This is designed to bring in the truly local businesses that are hiring local individuals and making a community impact. But the feedback they’re hearing is, “Well, you know what if I’m an entrepreneur who operates a 21st century business model selling online around the world, I’m hiring local people. But those tests seem to kind of make me ineligible because I’m making income from all over the world.”

So those are the types of things that Treasury is still trying to work through. So, we’re still very much in, I guess some portion of what you could call the Wild West on the regulatory piece. But there’s enough out there that many people are forming funds, deals are happening and we’re seeing stuff come online.

Clark Cahoon (11:44): So there’s a framework that’s engaged right now with the knowledge that there’s still more to come with exactly how this is going to fully play out over the next 10 years or so and that’s, so there are some question marks as to where exactly this is going to go?

Patrick Mullen (11:59): There’s more question marks on what type of investing would be allowable. So if I have a great entrepreneur who has this business that is set up in a zone and they’re making [a] meaningful difference, they’re hiring locals, they seem like I want to invest in them, that’s going to be a great investment for the community and for me from a financial perspective, if I have a question about their sales receipts and where they’re making their revenue from, is it maybe not in one of these 8,700 Zones or is half of it not coming from there, I may be less likely to make that investment. Because the problem is with Treasury regulating you twice a year for the life of your fund, that’s ongoing the whole time. So if they start growing and let’s say they’re selling outside of the Zones, then I could be found to be not in-line with this incentive and I could lose the tax exempt status.

So those types of questions are the ones that I think investors are still trying to make sure that they get a little bit of safe harbor from so that they don’t go into any investments that potentially could be viewed as not being qualified.

Clark Cahoon (12:56): Interesting. Bringing it back to Utah, what’s one of the more exciting aspects about this for the state of Utah with Opportunity Zones?

Patrick Mullen (13:06): I think for Utah, kind of as I mentioned, we’ve got a really unique blend of different types of communities. On one hand, we kind of have Salt Lake on the Wasatch Front, that’s just been growing like crazy the last 10 years, [and] is a very stable kind of labor market. But we certainly still have issues around things like housing and where stuff like this can plug-in. And one of the first deals that was announced in the state actually was a housing deal. It’s called the Paper Box Lofts done by the Vivint Smart Home Arena and it’s a group called PEG that is funding that one down out of Provo. But, certainly there’s a lot of people looking for multifamily, looking for things like that in large operating markets. On the other hand, we have 14 non-Wasatch Front counties that have a Zone and some of those Zones take up 80 to 90 percent of the county’s entire geography.

Clark Cahoon (13:57): Right. When you look at a map of the Zones, rural Utah, you can see, is playing a really big role in what Opportunity Zones is going to be able to do in those different counties. Can you talk a little bit about what that might look like in a rural community?

Patrick Mullen (14:08): Yeah, and that brings it back nicely to kind of what I’m doing with the Association of Counties and why we’re involved in this. But, one of the pieces of tension that I think exists across the country is that, in theory, this act was designed to bring capital back to the forgotten places in all of our states and all of our regions, and what we’re seeing, at least in the early days, is very much a predominant market shift towards investing in Zones that are adjacent to large urban areas, and that’s a great thing. We’re always happy to see development and see things that help communities. But the true intent of this was to help the areas that have, for lack of a better term, been left behind. So the Utah Association of Counties recognized this pretty early on, they were getting phone calls left and right from our county commissioners and their economic development staff asking, “What is an Opportunity Zone? How do we use it?”

What we ended up putting together was a partnership with my old firm, Sorenson Impact, where I was the executive director for about three-and-a-half years and worked in previous organizations that led-up to that for the better part of seven, who kind of had the inverse problem. They’re a nationwide leader in this, their founder and chairman, Jim Sorenson, actually played a very prominent role in getting Opportunity Zones past. He worked with then-Senator Hatch’s office, to help get this bill done and is seen at the nationwide level as certainly one of the top two or three leaders in the sector.

So people were coming to him and to the center and saying, “You know, we’re a fund out of New York or out of somewhere else. What should we be doing in Utah and the association, and I know your office here, the Governor’s Office of Economic Development, we’re saying how do we make sure capital flows to rural areas?” So in partnership with Sorenson, what I’m leading at the Utah Association of Counties is our rural engagement where we’re specifically going into every single one of these counties doing one-on-one level kind of education, presentations to both the public, the taxing entities, the elected officials, and moving towards what we’re referring to as marketplace creation, right?

Let’s create things like investment prospectuses or marketing materials that go into these types of deals. Let’s highlight the counties and what their needs are, right? Is it counties like Carbon County that maybe have prime industrial land that could be developed and that they really want to get up to all of the industrial investors who are trying to build manufacturing facilities and other things like that? Or is it places like Washington County down in [the] south where they’re the fastest-growing city in the country and they dramatically have a need to have high density housing, have different types of residential come in and how do we filter them up to kind of put them on a platform and allow these investors to go into. So that’s the project we’re working on.

Clark Cahoon (16:51): I didn’t realize there was that connection with the Sorenson Impact Center. So it sounds like you’ve been kind of at least abreast of the situation with Opportunity Zones for quite some time and it’s unique knowing that Jim Sorenson has had a pretty big role in that with the conversation kind of leading up to what we’re seeing right now. Is that right?

Patrick Mullen (17:08): Yeah. Jim is definitely one of the nationwide leaders in this. He’s been back to the Oval Office several times already to talk about the legislation and how it’s working. He’s giving orientations to new members of Congress and the Senate about what is going into this and by being privileged enough to work for him and work in his impact investing world. I was part of the earlier conversations that they were having in Washington around this. So when the legislation passed and there was kind of a mad panic to understand what it is, I certainly was not as well versed in it as I am now, but I could stand up and work with your office and with our other jurisdictions to say, “I think I know a little bit about it. I’ve been around from the time they discussed it in the beginning, and it’s worked out.” So, we’re lucky to have someone like Jim and Sorenson Impact here in Utah because it does lend itself to both getting us kind of a great nationwide insight and people kind of looking to Utah asking what’s happening. But it also gives us resources like the Sorenson Impact Center and the Utah Association of Counties to go out and leverage that to make sure that we help our communities stand out.

Clark Cahoon (18:18): That makes me feel really encouraged knowing that there’s that federal connection and kind of the genesis of the conversation starting kind of with a really important group here in Utah and then just knowing that we kind of have that direct access on a federal level with those conversations. Then also having someone like you that understands this and moving forward with it, really working in those rural communities here on the Wasatch Front and kind of furthering those efforts to making sure these communities really recognize the opportunity. No pun intended, it’s…

Patrick Mullen (18:48): It’s kind of hard not to say that when we’re talking about this. Yeah.

Clark Cahoon (18:51): I know right? But looking at this on a larger scale, what does the average Utahan who’s maybe not tied to making investments, maybe they’re not even in an Opportunity Zone? What’s the core thing that they should be able to understand about the Opportunity Zones, whether it’s adjacent to their community or in their community? What does  the average citizen need to know?

Patrick Mullen (19:15): Yeah, it’s a really good question. I would say the first thing I start with when I talk about this is you need to understand this is simply an incentive to the private sector to make investments. Just because there is a Zone, it doesn’t mean anything’s going to happen, right? There’s at least, initially, there’s no federal money tied to this. I know the president actually put a line item in his 2020 budget where there might be some money made available to groups like HUD or the SBA to do some adjacent things that would help the Zones. But, if you live in a Zone or if you’re around one, I would encourage you to really reach out to your elected officials and understand what their level of understanding around this is. Because one of the things that I haven’t mentioned, but it’s what we’re doing in these communities, is the communities can really play a significant role in driving the type of investment that either does or does not happen in their community. So a couple of concerns that we hear across the nation, the first one always is, how is this going to gentrify my community? Right?

Clark Cahoon (20:11): Right.

Patrick Mullen (20:11): If you’re providing this incentive, what’s going to prevent these developers from just coming in and building high end condos, right? They’re in the Zone, so they qualify and we don’t need that, and that’s where you need to be talking to your officials and saying, “Look, what are we doing to either incentivize the right type of investors, or, in some cases, maybe disincentivize the ones that are coming?” Is it maybe changing the zoning so that you can’t have something that would gentrify your community? Or if it’s something that’s needed, could you, as a county or as a city or even potentially as a state, put together something like a tax incremental financing deal that says, “We will give you a great incentive to come develop here, but if you’re going to do it in our Zone, here’s the three things we need,” right? “It’s workforce housing, it’s job training, it’s businesses that fit these sectors, and if you’re willing to do that, we as a county, as a city, as a taxing entity will step up and help you.” And we’re seeing that happen across the country. The state of Maryland announced a statewide TIF fund kind of doing exactly that and we’re advocating for that at the county level, both to incentivize the right type of investors to come and keep the wrong types out.

Clark Cahoon (21:12): I’m glad you brought that up ‘cause I think people getting politically active, especially in the communities, is something that’s really important. I think local politics should always be more focused than something on the national level and so this sounds like a really worthwhile thing to pay attention to. Talk to your elected officials, whether that’s legislators or maybe even just your community council. But it sounds like there’s a really great opportunity to kind of guide that, the message or guide what we’re working on with Opportunity Zones across the state.

Patrick Mullen (21:46): Yup. Yeah, and I’ve had people come to me, there was a citizen I met in Washington County at one of the meetings who came up to me and her first question was, “How do we opt out?” I kind of was taken aback and I said, “Opt out? The Zones are set.” And she said, “Well, I’m concerned. I’ve lived here for 30 years. St. George was very different 30 years ago. We’re growing like crazy and I feel like this is just going to be the floodgates opening to people coming in and building all sorts of things that take the character away from St. George.”

And my response to that was, “I think that — I mean, far be it from me, I’m not a resident of St. George — but I think that’s a great concern. I would encourage you to go talk to every single person in your elected official’s office and say, “What’s your policy on Opportunity Zones? What are you thinking about in terms of the development?”

I know housing is a big issue, but how do we grow in a way that keeps our community cohesive and working together and keeps people happy while also addressing the fact that you got a lot of new people showing up, and to give Washington County and the city of St. George credit, we’ve met with their officials extensively and they very much are thinking about this. I think they’re doing a great job trying to put that policy together and we’re working closely with all of them, but I want to bring that up as an example to say that, this is how it happens in real-time, right? This is a kind of ambiguous and sometimes hard to understand incentive, but it’s one that I think is creating a lot of really good conversations between the public and private sector.

Clark Cahoon (23:09): That’s what I was thinking, that just the conversation and getting people involved this way and caring about what’s happening in the future of their community sounds like a really unique opportunity for people to have a say in what’s going on in their local communities. So, Patrick, what are you seeing on a daily basis with your work at the Utah Association of Counties and what do you think the end goal is for these Opportunity Zones?

Patrick Mullen (23:37): Yeah, so with our partners at Sorenson, we are just finishing what we would call kind of phase one of the project and phase one is initial community engagement. So, it’s kind of funny at my previous job I used to have to be on an airplane going to places like India and Indonesia and my wife was driven crazy by it because that’s where the Sorenson portfolio was. Now, I spend most of my time behind the wheel of a car going to all of our beautiful counties and she’s like, “I thought you said you were done traveling?” But it’s been great to be at every single one of these communities. We’ve been back to most of them two or three times by now and we still have a few that we’re just getting to, but the goal of that was to really aggregate all of the potential deals that are coming together now — some of the potential areas of land where there could be development.

So in some cases, the community says we want things like industrial manufacturing or workforce housing, or we want to have a vibrant main street with companies located in it. But we need help understanding who those businesses are or who the investors are that are out there. So we’re finding that and now we’re moving into more of the investment prospectus creation, which is essentially putting together investor briefs saying, “Hey, here’s a deal that’s happening right now. It’s in this sector. Here’s the amount that they need.” Or, “Hey, here’s potential,” right? “There’s land, if you’re an industrial developer or commercial developer and multifamily developer, take a look at this county in Utah.”

And the final piece of what we’re going to be working on here in the next couple months is putting that out to a statewide website that is both an Opportunity Zone one-on-one resource, but also a little bit of like a heat map where you can get on and say, “I want to see all of the deals that are happening right now in Utah. I want to see the prospectus about each county,” right? What are the levels of development that they care about?

I think housing will probably be across the board, but we have a very diverse economy across the state, right? It’ll be everything from manufacturing to Main Street, kind of high-tech businesses as well, and that’s kind of the culmination of where I think we see the project going.

And to answer your question, we’re in the early days of Opportunity Zones. What does success look like is a question that I think a lot of people ask. For me, it’s about, “Can we drive investments that otherwise wouldn’t have happened?” But that type of investment would have happened in a community that wasn’t as in need of it as the investment that is happening with the Zone, right? We want to bring investors who say, “Look, we do manufacturing, we do business investing, we do this all day, but historically we’ve only done it in urban areas or non-distressed communities. We’re going to take a look at all the areas we’ve never thought about before because we’ve got this incentive”. And, I think the key thing is, does it lead to better positive community outcomes that fit into making these communities stronger and more vibrant and prevent things like gentrification from happening?

That’s really, I think what we’re working on right now is to set the guardrails up so that that type of investing doesn’t happen and the right types of deals come together, but it still is in the early phases. So I hope four months from now I can come back and show you the website and show you all of these deals and show you the investors that we’re marketing to. I think we’ve certainly created a lot of buzz, but it’s not just simply building something and saying, “You know, if you build it, they will come.” You’ve got to definitely go out there and put in the time to try and both connect the communities to the investors.

Clark Cahoon (26:55): Well, I’m really looking forward to seeing what those tools look like and that kind of heat map or just being able to, as a citizen, see what those projects are kind of coming down the pipeline. So that’s really encouraging to know that those are being built right now. And it sounds like even though we’re in the early stages, there’s a lot more to come. There’s really some good progress that’s been made already with Opportunity Zones in Utah, and it also sounds like if anybody needs tips on road trips around the state of Utah, that you probably have some that you can give out. You get on the road that much.

Patrick Mullen (27:22): Oh yeah, yeah it’s a gorgeous state. I grew up here so it was not new to me, but it fascinates me more and more every time I drive. We’ve got a lovely place. So anyone looking for, especially food tips, I’m getting a pretty good list going.

Clark Cahoon (27:35): Awesome. Well, thanks so much for taking the time to meet with us, Patrick. It’s really exciting to know what these Opportunity Zones are, to kind of dig in a little bit deeper and understand what’s going on with them. I know that they’ve been in the news a lot lately, I think people are kind of trying to wrap their head around what it is. But, I think it probably makes sense to have maybe a followup podcast in the future where we can maybe take a look and see what some of the progress is [as] more of these tools kind of come about.

Patrick Mullen (28:03): Yep. I would love to, and I’ll just add that the latest round of regulations from Treasury of the update should come out in the next two- to three-weeks. So, keep that in mind when you’re listening to this. Some of these actually may have changed that I talked about, so maybe do a little bit of research and when they do come out, I’d be happy to come back and give some updates.

Clark Cahoon (28:20): Excellent. Appreciate that. Thanks again, Patrick.

Patrick Mullen (28:22): Thank you.

Conclusion

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