GE’s Global Investigations Chief Counsel Katy Choo Discusses the Art of Investigations

Co-hosts Zach Coseglia and Hui Chen speak with Katy Choo, VP and chief counsel of global investigations at General Electric. Katy is one of the most highly respected figures in corporate internal investigations, and has led a multitude of investigations both as a prosecutor and in-house at GE. On this episode of There Has to Be a Better Way?, Katy shares her “humanizing” approach to investigations and compliance, and the many questions she asks in her search for answers.

Transcript:

Zach Coseglia: Welcome back to the Better Way? podcast, brought to you by R&G Insights Lab. This is a curiosity-driven podcast where we ask, “There has to be a Better Way, right?” There just has to be. I’m Zach Coseglia, the co-founder of R&G Insights Lab, and I’m joined today, as always, by my friend and partner in crime, Hui Chen. Hi, Hui.

Hui Chen: Hello, everyone—it’s wonderful to be here again. I’m very excited that we have a guest here today who’s someone for whom I have a tremendous amount of respect and admiration. We’re very happy to have Katy Choo, the vice president and chief counsel of global investigations at GE, joining us today. Welcome, Katy.

Katy Choo: It’s nice to be here—thank you.

Hui Chen: Katy, we’re going to start off by asking you to tell us about yourself. Tell us who you are and about your professional journey.

Katy Choo: Let me start with my professional career, and then we can take it from there. After college, I went to law school, and after law school, I worked in a large law firm, Davis Polk & Wardwell in New York, for a couple of years. Then, a friend of mine at the U.S. Attorney’s Office in the Southern District of New York called me up, who was someone I had worked with a great deal while at the firm, and said, “What are you doing there?” I said, “You know what I’m doing here. I’m reviewing documents. It’s discovery time.” He said, “You should apply to the U.S. Attorney’s Office.” And I said, “What’s that?” He went on to tell me that it was the federal prosecutor’s office in the district of Manhattan and Westchester, and off I went. I applied, and I was lucky enough to get the job, and stayed there for over a decade.

Zach Coseglia: What was it that drew you from law firm life to being a prosecutor?

Katy Choo: It was just a leap of faith. I hate to say that, in the sense that you think there’s a charted path, or that I would have a charted path. I literally just adored this lawyer and trusted his judgment so much. In fact, he is someone I consider a big mentor. I didn’t really know anything about it. I didn’t have any lawyers in my family, and I certainly didn’t know any former prosecutors or current prosecutors, but he was having a lot of fun, and so I thought, “Why not?” So, I applied really out of a position of ignorance.

Zach Coseglia: That’s great. And you stayed for over a decade?

Katy Choo: I did. I did the traditional general crimes, and then moved onto higher units, ultimately focusing on white collar types of crimes, but initially doing drugs, guns, and smaller cases too. After that, I became a supervisor and a deputy chief in the Criminal Division, and then moved on to GE after that. I’ve been at GE now for almost 20 years. So, three jobs altogether, only.

Hui Chen: At GE, have you focused on investigation from the beginning?

Katy Choo: Yes, I was hired into the litigation department, and have worked on investigations the entirety of my tenure. In the beginning, the litigation department had two former prosecutors. I was one—I was back-filling, if you will, someone who’d left recently. Since then, I have grown my career there and done more. I’m very tied to the compliance organization, given that what I work on is typically going to lead to potential compliance improvements and the like, and certainly discussions about whether there are broader issues to tackle, or at least consider and evaluate. I’ve spent 20 years doing that.

Zach Coseglia: I think one of the things that a lot of our listeners are probably interested in, especially the in-house folks, is how the organization at GE is set up. So, are legal and compliance part of the same organization, or are they actually part of two separate organizations with their own respective leaders?

Katy Choo: They are separate, but that’s been an evolution over time. They both report into the legal organization and up to our general counsel, but back in the day, when I first started, one individual did both investigations and compliance. Then, that led to the hiring of a compliance leader, so that role and that function started to develop within GE. The businesses themselves also started to hire their own compliance leaders, and over time, it has really become very distinct organizations, but working closely together in tandem, and reporting in to a general counsel.

Hui Chen: You’ve spent 20 years doing investigations at GE, and I will tell you, I have heard at least one prosecutor in the DOJ tell me that if they could work under you to learn how to do investigations, they would. They would do it without pay, they said, so you’re like the master of investigations. I have also found that an investigation is one of those things that’s very difficult to teach in a classroom or workshop type of setting because it’s so fact-specific and nuance-driven. So, how do you train investigators?

Katy Choo: I love to do this, so thank you for the question. I use a hypothetical—I don’t train per se—I just say, “Imagine you’re in a big meeting, and someone comes up to you and says, ‘I need to talk to you. I know something really has happened that is non-compliant,’ or some such intro, so you know there’s a compliance concern. What do you do?” I will be training people who are not only lawyers, but also non-lawyers, perhaps members of the audit staff, and the first question out of the gate is, “What do you do? Do you sit down with that person immediately? Do you try to get someone to come with you? Do you call outside counsel? What do you do?” When we start iterating off that hypothetical, we get to some interesting places. I’ll then point out along the way things to consider. I think there’s a tendency with investigations to think for something significant that you immediately call outside counsel, so I’ll ask the question, “What if there’s nothing there? What if it’s a frivolous concern? How do you evaluate whether it’s frivolous or potentially has legs underneath it? Even then, when is the right time to call an outside counsel? Who are you notifying in the company before you do that? Do you have the authority to do that? When do you escalate? When do you set off an alarm bell? When do you not?” Because in the end, to your point, Hui (and I completely agree with it), each matter is different, and a fact can tip it in a different direction, in a different tangent.

Think of the boy who cried wolf too many times. You can’t just react that way, but if you also just journey on and treat it like your many other matters, and/or you just take it on yourself, then perhaps you’re not doing the company justice either. Perhaps you should be telling other people—and if so, whom? And what about the attorney/client privilege? That is so critical to understand in evaluating at the outset what might be coming your way, how to look at it, how to examine it, how to resource it, and who to elevate to, if you’re going to elevate it. Is it your boss? Is it the business’s general counsel? Is it the corporate HQ? Is it senior management? Is it up to the audit committee? When do you make those decisions, and why? It is so critical to understand “why.” And then, teaching those who are not lawyers, or even if you’re a lawyer, you may not be that familiar with the attorney/client privilege—we’re very global, so our concept of the attorney/client privilege is going to be very different from those abroad. In many countries, as you know, the privilege does not apply to in-house counsel, so being able to educate people during the process of teasing out a hypothetical is the way I do it. It is also great fun because there’s such energy in the room and it causes people to think as we’re talking—because if you just train, at least in my mind, there’s a tendency to tune out if you’re just listening—and so, this is a way to draw people into what I call the “classroom experience.” Then, get to a place that when someone makes a comment, being able to ask further questions or make other observations that either lead to even fuller discussion of the topic or ultimately get back to where I want to go, but we’ll try to cover many things in the course of teasing out a hypo. For example, “How do you evaluate whether that person has something or not?” I start it with that. “How detailed are they in what they say? Is it firsthand? Is it hearsay that they convey information to you? Do they have documents? Do they not? Does it raise a safety concern? Immediately, if it’s a safety concern, what do you do with that versus something else? There may be something very major, but it’s not going to raise a safety concern. What do you do with that?” All of that causes the juices in your mind to think and to move, and what I want to see is people taking those inputs and running with them, and getting the light bulb, “Aha, that’s a good point. What would I do with that, and why would I do that?” And by the end, we have a great time—it’s such a fun thing to do.

Zach Coseglia: Can you give us a couple examples of how data is being used, and the kinds of data that you find to be most valuable from an investigative perspective?

Katy Choo: Yes, I’ll just give one example that comes to mind. Let’s say that we have a concern about a trade controls violation, and we’re wondering, “How could this be something we’re just learning about now?” Let’s say it happened back five years ago: “Have there been more instances of it?” And even more importantly, let’s say that the concern comes to your attention because someone has come in to say, “You have got to address this.” Then, I’m going to look at all our ombuds data and figure out how many times, if ever, has it been raised before? By whom? When? Who addressed it? What were the conclusions? Were remediations put in place? That history is critical to understanding why we are where we are today. We get thousands of ombuds concerns every year. We’re proud of that because that shows we have what we call an “open reporting system,” where people believe in the system and raise concerns, but of course, you have to address those concerns. So, what happened to those concerns?

Theoretically, hypothetically, let’s say you had a matter, and it turns out there were 50 concerns like that raised in the past. “Why? How could that be? Why is it now?” And let’s say the person coming in is very emotional because they feel like this concern has not been addressed when it should have been. Probably right. What happened to those concerns? Were they squelched? Were they mishandled? Did people not understand them? That’s my journey, to figure out not only what’s happened here in this fact pattern, but why did it happen, how could it have happened in a company like ours, and to see what we can do to better improve, to make sure those kinds of things are escalated? Being able to pull that data out, look at that historically vis-à-vis the one party you’re looking at, but also more systemically. What has gone on here with this particular business in the past? Are there gaps here we need to address? Likewise, being able to slice seniority levels of people who may or may not have had concerns before or have had issues before.

Culture surveys—things like that are a gold mine when it comes to doing an investigation, because you want to understand the behavior. To me, investigations is not trying to figure out the whodunnit aspect of it—it’s the “How did it happen?” More often than not, it humanizes it, because then you understand the broader, fuller context in which this particular circumstance arose. When you have the broader context, then you can put it in the proper context, and explain it, fix it, address it, whatever it may be. I think that is a way to more fully understand, rather than just the microscope going directly into the one and only fact that you have.

Zach Coseglia: I’m picking up on what I feel like must be one of your Better Ways, which is just having the humility to not just have all of the answers, because it’s about asking questions. You’re asking so many questions. Even as we’re having this discussion it’s, “Why didn’t this happen? What does this say? What did that say?” When you were explaining the way that you train, it’s just a series of questions—that has to be one of the characteristics of a really effective investigator, is, “We’re looking to get to an answer, but we’re going to ask a whole lot of questions to get there.”

Katy Choo: Yes, thank you. I’ve said this before, even in my trainings—in viewing investigations, what we find is a humanizing experience, which is to not be judgmental, but to find out what happened, why, and how. More often than not, by humanizing that way, because you always have to put yourself in that other person’s shoes, is fundamental to doing investigations. How did that person do that? Why did they do that? More often than not, you understand and see that it’s not because they were coming from a bad place in their heart or intentionally—it’s often because they didn’t know, they didn’t appreciate, or they were under enormous pressure and didn’t know which path to follow. We never say, “Because your manager told you to do this, it’s okay.” That’s never true if you’re really going to actually violate the law or violate a rule. On the other hand, if you’re in an environment where there are so many things to do, there’s so much time pressure, perhaps the people who usually handle that are not there at the time—they’re off on some other crisis—so you’re doing the best you can, juggling eight things. Of the eight, we are usually only at three—that means some are not going to get the attention they need, and maybe you don’t have the expertise to understand it. Once you appreciate that context, it has a humanizing effect—not to excuse the behavior, because there’s a miss, but to understand why. And it is so important for internal consumption purposes, for process improvement purposes, but also, if you were to go to the government, to be able to explain that, and explain that transparently, thoroughly, and accurately, because I think people need to understand that in order to make a proper evaluation.

Zach Coseglia: Indeed. We talk about the why and about the root cause analysis—I want to use that as a transition to talk a little bit more about your views of compliance, the remediation, and the fixing of it all that comes at the end of an investigation. We’ve talked before, and one of the things that we do a lot in our work is try to make sure that we’re not fixing the thing that’s right there at the surface that seems really obvious and easy, the contributory factor, but that we really are trying to fix the root cause—that we’re asking enough why questions about why this happened to make sure that whatever happens on the compliance side, forward-looking, proactive to try to fix this, is actually fixing the thing that needs fixing. So, talk to us a little bit about your process there.

Katy Choo: It’s absolutely critical to make sure that remedial measures, process improvements, and discipline, if needed, are carried out. My vision is always not only, “What happened?” and addressing this particular matter, but also, “How do we keep it from happening again?” So, that goes to root cause. That goes to strengthening or improving processes—it may mean more resources, it may be bringing more domain, it may be changing systems entirely. And then, the throughput is so critical, because if you don’t have that, to your point, Zach, you’re going to have the problem again. Most people tend to pay attention to that. I have not seen an instance myself of matters I’ve had, where they haven’t followed through on what needs to happen. What I always like to think about is, you can’t have commercial success without compliance—you might have short-term gain, but then you’re going to have long-term loss. That always has an audience at GE—we’re looking for sustained business success, not once in a while, and then way back losing. I’ve seen too many companies do that, and those lessons are very much learned by a company like ours, so I find that that is as important as anything coming out of an investigation.

Zach Coseglia: I think one of the things that I talk about with Hui a lot, is my, at times, frustration with the discipline of compliance. That frustration, in part, comes from this instinct to say, “Let’s train more,” or, “Let’s revise our policies and reissue them,” or, “Let’s just have everyone certify to something.” What are some of the Better Ways that you’ve seen around compliance where we’re getting past these obvious things, these things that at times are maybe worth as much as the value of the paper that they’re printed on, and really getting to the core of shaping a culture of integrity?

Katy Choo: I love to talk about this because it’s so true. Training is overrated, but I want to make sure I clarify what I mean by that. It is foundational—you cannot have a program where you don’t train. Education is critical, but education is ephemeral. I can train tomorrow, or you can train tomorrow on antitrust, trade controls, the FCPN, or whatever, and you’re doing it broadly across, perhaps, your entire employee base. Well, they’re not dealing with that every day, and they’re not going to remember it in three months’ time. So, your ethics training, your compliance training only can get you so far. You need processes that are embedded operationally in the business itself so that, for example, if it’s improper to spend a certain amount of money on a government official’s meal, or improper to invite one at all, then have a system and a control in your system such that your accounts payable will not let you pay for that. There are some things that you just think of as steps that are embedded in the system to catch someone who may forget. It’s not even I’m saying that it’s because people are trying to get around the rules—they just may forget. Let’s say it’s a business that almost never deals with government officials. Their product line never goes to government customers, and so, they treat it like a commercial customer, and then lo and behold, “Way back when…I forgot, you’re not supposed to do this.” Being able to catch that so you’re training, but also making sure your systems work, I think, is absolutely critical—so, that’s one thing.

In terms of culture, so much is about the leadership. I am a firm believer that if your leadership does speak about it, talk about it, do it, walk the talk, if you will (I know that’s an overused phrase, too), it is so critical. If it’s important to your leader, it’s important to you. There are so many things you have to do in a day job, but you watch your leader. And then, I hate to say it, but I think culture is generational. I had an interesting conversation with someone once about, “How long do you think it takes for things to change? Once you have new policies, new processes, trainings, and whatnot for a business that has had problems in the past, how long do you think it takes for people to understand it?” And the answer I got was, “Six months.” I said, “No, no, no, no. It’s going to take a long, long time.” Because if you think about, if you have a global company and you have employees that are eight rungs down, working on oil rigs or out servicing engines at every level, and they’re so far away from the U.S., how are they going to understand this? How are they going to appreciate the importance of this to the mother ship? Which means if it’s a mother ship, it’s the entire company—you can’t turn the ship around that quickly. So, again, having an appreciation for how complicated it is for people to understand the newness of it and the actual standards that need to be now met. The fact that it’s written doesn’t mean it soaks into my brain and I understand it. It doesn’t mean that I appreciate what that means practically in my day-to-day job, or even my month-to-month experiences that might invoke that—that takes time. I’m blessed by being at a company where long before me and long after me it has been part of the culture for decades of having business-compliant procedures and success built on compliant practices. And that culture, the importance of that being conveyed to newcomers, it’s just part of our DNA, and for people to appreciate that they carry the reputation of GE on their shoulders is so important, and I think it does make people rise up.

Hui Chen: I want to follow up on this theme about how you create this culture throughout such a large company as GE. The first time I met you, you told me about the corporate audit program, and you said it with such enthusiasm that I started telling the story to other people. So, tell our listeners about the corporate audit program and why you think it’s such a powerful way to shape culture.

Katy Choo: It was, and perhaps unlike many other companies, a career accelerator at GE—highly competitive to get in. The best and the brightest from the corporate audit staff would go on to become CEOs, CFOs, CMOs—just very prominent positions throughout the company. The respect that they commanded within the company was extraordinary. These are young people who started the corporate audit staff, so already the talent that got hired into our audit staff was, in my view, phenomenal, incredibly bright, capable, and young. They were really a secret weapon when it came to investigations, more in terms of, I would say, time, because investigations are time-pressured. The time efficiencies of corporate audit staff to get to this broader understanding of context, of data beyond just the one particular matter—of course, it would help me understand the one particular matter—was critical to being able to understand more broadly what’s going on at GE and may or may not need to be fixed more broadly, was just phenomenal. On top of that, corporate audit staff’s mission when it was created was not only to conduct audits—and they did compliance audits as well as finance audits—but an equally important focus on process improvements. In other words, it wasn’t audit for audit’s sake, it was in order to help the company find “Better Ways,” to use your phrase, and that was really built into the whole ethos of this program. Therefore, any matter, they would always come out with recommendations, and they would often be spot on.

Hui Chen: Do they necessarily come from audit backgrounds, or do they come from all kinds of backgrounds?

Katy Choo: All kinds of backgrounds—a lot of them do have finance backgrounds, but all kinds of backgrounds. They really prove themselves—they would go through 360s, I think, pretty much every year. They would be presenting to CEOs of the businesses, or a CEO and a CFO of GE, regularly, and that was part of their whole development. The whole thing is: It’s a development program. You’re not just auditing—you are in a development program that is shaped around the audit needs of the company.

Zach Coseglia: One of the things that I think must have been really exciting about that, is that whenever we talk about compliance, investigations, or corporate audit, there’s often this tension between the business and those functions—this view of them being the police. How did that dynamic that you described in corporate audit enable them to actually be more effective with the business, and not be viewed in a negative light because of who they were, and the value that they seemingly were bringing?

Katy Choo: Absolutely. I read this somewhere, and I believe this to be true, that the genius behind the creation of this program when it was formed and intended to have this dual purpose, was exactly that, which is not for audit staff to be viewed as just the police on the block—they’re really there to help the business. Their real purpose was to make sure that in the course of auditing, they then were helping the business with improvements that the business would embrace. They didn’t have the authority to say, “You must do X.” They’d be making those recommendations—highly iterative. It’s a very discussion-oriented kind of place, and so, businesses would actually pull in corporate audit. So, if they were having a problem, they’d bring in the audit staff and say, “Can you please go look at this and find a different way for us to do this?” I imagine for those who were in audit staff, that was incredibly both empowering, but also inspiring. Knowing that you’re being brought in at senior levels from that business, or even from corporate, and asked to take on that challenge and that project, and you’re all of 25 or 28, I think that’s a pretty heady experience—and they would attack it with gusto, with great rigor.

Zach Coseglia: All right. Katy, now it’s time to get to know you a little bit better. At the end of every one of our podcast episodes, we have a little questionnaire—we ask everyone the same questions. It’s inspired by the Proust questionnaire, Bernard Pivot, and James Lipton from Inside the Actors Studio. And so, Hui and I will rotate back and forth. Hui, I’ll let you take question number one.

Hui Chen: Katy, the first question is a choice of one of two questions—we’re going to ask you two questions, and you choose to answer one of them. If you could wake up tomorrow having gained any one quality or ability, what would it be? The other version, or question option number two would be: Is there a quality about yourself you are currently working to improve? If so, what?

Katy Choo: Those are great questions. I would say that if I could change one quality about myself, is—I’m a very shy person—if I could be more gregarious, I think I’d be happier and more successful. But it is who I am—I am a bit of an introvert—that is my nature. I do envy those who are more extroverts than I am, and so, if I could, in a blink of an eye, make a change, that’s what I’d do.

Zach Coseglia: I love that. The next one is also a choice of two questions—either: Who is your favorite mentor? Or: Who do you wish you could be mentored by?

Katy Choo: I have so many mentors that I think of, and I think of mentors that are not sponsors, per se, but people that I really respect and enjoyed getting advice from. So, I would say in terms of government, certainly Denis McInerney, who was the head of the Fraud Section. Just a tremendous person, and the person who called me about the U.S. Attorney’s Office and said, “You should apply here.” And then, Briggs Tobin was another colleague at GE who recently passed away, but like Denis, just had this joy of life, and would always see the best in people and circumstances, and the fun. That causes inspiration like none other—if your leader’s happy, if they’re inspired, it brings people along. And with Briggs, we would giggle. He was head of M&A at GE. A lot of M&A has gone on at GE, and the stories that both he would tell, but also enjoy, and his enjoyment in the moment of high-pressured matters were like none other. I just remember every time I’d see him, he’d have this smile on his face, this twinkle in his eye. Denis had the same quality. Those are the two that I think of immediately.

Hui Chen: That’s wonderful. What is the best job, paid or unpaid, that you’ve ever had?

Katy Choo: My current job—it’s been a great job. I have learned so much. It’s funny, I loved my job at the U.S. Attorney’s Office—it was an amazing job. And talk about fun—you just have the weirdest things happen when you’re a prosecutor that you have to deal with, and immediately. Also, doing trials, and the friendships you make in the U.S. Attorney’s Office are like none other—they are for life. But I will say that the broadening I’ve experienced at GE with the kind of work that I’ve gotten to do, the leadership opportunities I’ve been given at GE, and the exposure I’ve been given have been like none other. As much as I loved being a prosecutor, and I truly did, it’s very one-dimensional. Having a broader appreciation for private sector experiences, the functions within a company, the cross-functionality in order for a company to succeed, to see that, the brilliance of the people at GE, and the respect that GE has been held in, has enabled me to do my job so much more easily. And the ability, but also the accountability, to maintain that level of quality and humility in the job that I do, to appreciate what we do and what we stand for, but also to advocate for—I’m a fierce advocate for GE because I so strongly believe in it—gives me that purpose. I have always felt that purpose and that mission, and without any doubt, felt that GE deserved all my advocacy, because I feel so strongly about the company. It’s been just a world-class experience for me. I really am very grateful for having had the chance.

Zach Coseglia: Katy, what is your favorite thing to do?

Katy Choo: I love to read. I just finished Malcolm X’s biography, Arising. And I’m starting to read some short stories by Flannery O’Connor. I am an avid reader. I actually love fiction—I love to get lost in fiction. For me, really the most transformative experience is to take me out of myself and my life—as much as I love my life—to have the imagination of fiction that really transports me somewhere else is the best thing for me.

Zach Coseglia: That’s wonderful. Not fiction, but we’ll be launching a book club soon, so we would love for you to be a part of it.

Katy Choo: I’d love to do that.

Zach Coseglia: That sounds great.

Hui Chen: Now, next question is: What is your favorite place?

Katy Choo: My favorite place I’d probably say is Myanmar, Burma. It’s a fascinating place, and a place that I’ll never forget for its beauty and how enchanting it is. And Pagan, in particular—I went there easily 20 years ago. In terms of imaginary space, I come back to my reading, which I love when I can totally lose myself in a book, because it’s so well written that I feel transported.

Zach Coseglia: What makes you proud?

Katy Choo: I’m super proud when my team succeeds and knocks it out of the park. I love when I hear from others telling me how great they are and what a great job they did, because, of course, I feel that way, but it’s different when others who are lauding their work, the value they’ve brought, and the help that they’ve rendered is like none other. And, of course, I have three kids, so what makes me immensely proud is as they grow up, as they become good adults, learning and becoming well-rounded, giving human beings, that gives me great joy.

Hui Chen: We move from the profound to the mundane: What email sign-off do you use most frequently?

Katy Choo: I just use my name. The one thing that occurs to me when you say that is I don’t put my title—I never have, so I always just sign it, “Katy.” I don’t want people to be either intimidated by my title or not, so it’s a deliberate thing that I just sign my name.

Zach Coseglia: What trend in your field is most overrated?

Katy Choo: The phrase, “Do more with less,” is something that I don’t believe is such a great phrase, if taken to an extreme. There’s no doubt that companies are about efficiencies, and we all get more efficient with our jobs and our day jobs over time, but at some point in the legal function, in the compliance function, doing more with less becomes a bit illusory, and you get too stretched. And so, I caution everybody, and myself, that at some point you say, “Enough is enough. We need more help.”

Hui Chen: That’s a very fair point. And the last question is: What word would you use to describe your day so far?

Katy Choo: Thought-provoking.

Zach Coseglia: That’s great. I just want everyone to know it’s 9:30 in the morning, so she’s referring to us when she says that.

Katy Choo: Exactly.

Zach Coseglia: Katy, thank you so much. Any final words of wisdom to share with our listeners? This has been such a wonderful conversation.

Katy Choo: I’d just say, do what you love and do it well, and you will inspire others.

Zach Coseglia: What more can be said? Wonderful. Katy, thank you so much. Thank you all for tuning in to the Better Way? podcast and exploring all of these better ways with us. For more information about this or anything else that’s happening with R&G Insights Lab, please visit our website at www.ropesgray.com/rginsightslab. You can also subscribe to the series wherever you regularly listen to podcasts, including on Apple and Spotify. And, if you have thoughts about what we talked about today, the work the Lab does, or just have ideas for Better Ways we should explore, please don’t hesitate to reach out—we’d love to hear from you. Thanks again for listening.