Overview of the 2018 U.S. Resolution Stay Rule & Protocol

For an in-depth overview of the FSOC's QFC Recordkeeping and Reporting Rules, take a look at our explainer presentation here.

Why are these regulations necessary?

The U.S. Resolution Stay Rule and the U.S. Resolution Stay Protocol are regulatory reforms introduced post financial crisis.  They were part of the initiative to improve financial stability in the event that a U.S. global systemically important bank (G-SIB) entered resolution or filed for bankruptcy.

Before the collapse of Lehman Brothers, Lehman’s parent company acted as a guarantor on its subsidiaries’ financial contracts. When the parent filed for bankruptcy, counterparties on those existing financial contracts were permitted to exercise their rights to terminate their agreements.  These “cross-default rights” terminated contracts and resulted in great losses. Subsidiaries attempted to quickly meet contractual obligations by selling assets to produce cash and selling collateral that secured the now-terminated contracts.  This compromised the viability and stability of Lehman and its subsidiaries, creating a ripple effect throughout the global economy.

Currently, many financial contracts at G-SIBs contain similar cross-default clauses, allowing counterparties to exercise their default rights if a G-SIB or its subsidiaries file for bankruptcy or require resolution.  To mitigate risk and ensure that the global financial system is not thrown into chaos once again, international and domestic regulatory bodies introduced the U.S. Resolution Stay Rule and Protocol.


Who is affected by the new regulations?

The Rule and the Protocol apply to the following entities (referred to as “Covered Entities”):

  • The 17 U.S. G-SIBs and their subsidiaries (U.S. and non-U.S.)
  • The U.S. subsidiaries, branches, and agencies of the 18 non-U.S. G-SIBs


Which regulators are involved?

  • U.S. Resolution Stay Protocol (“the Protocol”): ISDA (International Swaps & Derivatives Association)
  • U.S. Resolution Stay Rule (“the Rule”): The Federal Reserve, FDIC (Federal Deposit Insurance Corporation), Office of the Comptroller of Currency (OCC)

It is important to note that there is a distinction between the “Rule” and the “Protocol.”


What is the difference between the Protocol and the Rule?

In 2015, the original ISDA Protocol came into effect as a suggestion by regulators. Covered Entities agreed to comply with the new resolution protocols, however, buy-side entities were not able to come to agreeable terms with regulators.  After years of negotiation, the 2018 version of the ISDA Protocol included terms that affected buy-side entities, Covered Entities must have their buy-side counterparties agree to new resolution protocols.


The Rule, when implemented, is the governing regulation which G-SIBs must comply with as it relates to their existing and new financial contracts.  The Protocol refers to the actions that are required of G-SIBs in amending existing contracts.


What type of financial contracts are subject to the new regulations?

Covered Qualified Financial Contracts (QFCs) are agreements pertaining to derivatives, securities lending, and short-term funding transactions.  A QFC is within the scope of the Rule and Protocol if it meets any of the following criteria:

  • It contains one or more “default rights” that may be exercised against a Covered Entity. Default rights include:
    • Direct default rights: right to terminate the QFC or exercise other default rights based on its direct counterparty becoming subject to an insolvency proceeding
    • Cross-default rights: right to terminate the QFC or exercise other default rights based on a parent or other affiliate of the direct counterparty becoming subject to an insolvency proceeding
  • It explicitly restricts the transfer of the contract from a Covered Entity
  • It was entered into on or after January 1, 2019, by a Covered Entity


What are the deadlines for compliance?

  • January 1, 2019: for covered QFCs between two Covered Entities
  • July 1, 2019: for covered QFCs, between a Covered Entity and a counterparty (excluding small financial institutions), entered into in order to apply the final U.S. margin rules applicable to swaps
  • January 1, 2020: for covered QFCs between a Covered Entity and any other counterparty (including small financial institutions)


What are the requirements of the new regulations?

Covered Entities must add two amendments to existing QFCs:

  1. Buy-side counterparties must “opt in” to certain resolution protocols that would be followed should the Covered Entity require resolution or file for bankruptcy. These resolution protocols contain requirements related to the exercise of default rights that buy-side counterparties must follow.
  2. Buy-side counterparties must be restricted from exercising cross-default rights to terminate contracts immediately, through a 48 hour stay.

8of9's Client Appreciation Party!

8of9 was thrilled to invite clients to the new office for our Client Appreciation Party on Thursday, October 18, 2018. A huge thank you to everyone who attended. It was wonderful to see our supporters and friends – both old and new. As we continue providing regulatory consulting services and building RegTech products, we appreciate the support and loyalty you’ve shown us throughout the years. We love and appreciate you all so much!  

Our Values

Intelligence | Inspiration | Initiative | Innovation | Integrity | Inclusion

The 6I's above represent our goals as a company and as a team. At 8of9, we strive for excellence within the FinTech/RegTech space and regulatory consulting industry by sticking to these six values. This is the foundation of our company:

Intelligence. Our team isn’t just intellectually capable, but also intellectually curious. We have a genuine desire to educate ourselves and others on the rapidly changing regulatory space. By attending training seminars, speaking on panels alongside other industry leaders or speaking in on industry group calls, we ensure that we are up to date with the latest information in our industry. Taking the time to learn and teach our colleagues as well as our clients are a large part of what sets us apart.

Inspiration. Our team maintains the mentality that the glass is half full rather than half empty. At 8of9, we find it essential to go about our day with a positive attitude. We pride ourselves on finding simple solutions to complex regulatory issues, which isn’t always the easiest task. By bringing a can-do attitude to client projects, we inspire not only our team but those around us.

Initiative. We are problem solvers! We are committed to coming up with creative solutions for regulatory issues and attempt to recognize problems before they even arise. Taking initiative comes as second nature to us. In the field of financial regulations, 8of9 is always ready and eager to tackle new challenges.

Innovation. We believe in a world where compliance should create fewer headaches. Through our products and the way in which we deliver consulting services, we bring future focused thinking to the regulatory community. 

Integrity. The culture at 8of9 values integrity, hard work, and perseverance, which goes hand in hand with delivering value to our clients. We focus on what is right rather than who is right. Instead of focusing on getting credit, we focus on solving the problem at hand. We maintain our integrity through our ethical principles, respectful conduct and the way we treat every person we interact with.

Inclusion. Our sixth value is fostering inclusivity. We practice inclusion within large financial institutions by reaching across all departments and specialties, to ensure the best possible work is done with input from multiple perspectives. More importantly, we value having a diverse team with a variety of backgrounds and areas of expertise. Our culture allows for people with unique viewpoints to come to the table and communicate openly.

The Credit Risk Mitigation Framework in the EU

Developments in the Credit Risk Mitigation Framework in the European Union

The financial crisis of 2008 revealed shortcomings in the way financial institutions evaluated risk exposure. These shortcomings led to insufficient regulatory capital in times it was most needed. In the aftermath of the crisis, criticism was directed at poor risk management practices, specifically at the failure of internal model-based approaches to accurately measure risk. In response, regulators, specifically the Basel Committee on Banking Supervision, commenced reviews and revisions of internal model-based methodologies to reduce excessive variability of risk-weighted assets (“RWAs”) across institutions. While Basel III introduced changes to calculating risk-weighted assets for credit risk, using the Standardized approach and the Internal-Ratings Based (IRB) approach, rules regarding credit risk mitigation ("CRM") remained largely unchanged.

In 2013, the European Union (“EU”) introduced the Capital Requirements Regulation (“CRR”) which implements the Basel III framework in Europe and serves as a “Single Rulebook,” providing a set of harmonized prudential requirements for the EU banking sector. The CRR specifies the CRM techniques available to financial institutions and eligibility requirements for each technique. The regulation also mandates that the European Banking Authority (“EBA”) develops regulatory technical standards (“RTS”) on select issues in this area, including three mandates pertaining to the application of CRM. The mandates by the CRR, as well as the EBA’s own assessment of the need to conduct a review of the CRM framework, laid the groundwork for the EBA’s IRB Review program.

The IRB review program is in four phases:

  1. reviewing supervisory practices used by authorities in assessing an institution's compliance with IRB requirements,
  2. harmonizing the definition of default,
  3. providing more clarity on modelling approaches in the areas of risk parameter estimation and treatment of defaulted assets, and
  4. reviewing the credit risk mitigation framework. The March 2018 report on the CRM framework was a product of this final phase (see below).

While the report provided clarification on technical aspects of using CRM techniques, the EBA highlighted the necessity for regulators to undertake an analysis of the overall CRM framework to determine whether reform would be beneficial. The EBA’s report relied on feedback received from stakeholders; this feedback underlined the need for more clarity in the CRM framework. Regulators are continuously improving the consistency of RWAs across institutions, and these improvements will lead to future changes to the CRM framework.

Primer on the EBA’s Report Assessing the Current Credit Risk Mitigation Framework

Part I: Overview of the current design of the CRM framework in the CRR

There are several factors to consider in CRM rule implementation. CRM rules are implemented differently depending on:

  • whether the institution is using the Standardized Approach or the IRB Approach. The EBA’s review covered the use of CRM techniques under all approaches. The report maps relevant provisions to the corresponding credit risk approach;
  • whether an institution, under IRB, is permitted to use their own estimates of loss given default (LGD) and credit conversion factors (this is known as Advanced IRB, or A-IRB) versus supervisory inputs (this is known as Foundation IRB, or F-IRB). The EBA pointed out the limited guidance on the use of CRM for exposures under A-IRB and indicated it would start work on this topic in the future.

Part II: Data collected about the use of the CRM framework in the EU

The report includes a quantitative overview of the collateral types and CRM techniques used by institutions to calculate capital requirements for credit risk:

  • Findings show that the use of techniques varies significantly across jurisdictions, as the choice of technique varies by institution’s type of approach and business model.

Part III: Policy Issues related to CRM

  • The EBA recommends amendments to the CRR, with the aim of reducing variability in the application of CRM provisions.
  • The EBA presents arguments reinforcing its negative opinion of the development of RTS on recognition of conditional guarantees, on liquid assets and on master netting agreements. The EBA emphasizes that the mandates cover select aspects of the CRM framework that are not expected to have a significant impact on the regulatory capital and rating systems of financial institutions. According to the report, “pursuing work on these three mandates…would create the risk of disproportionate regulation given the limited benefit of such additional provisions.”
  • The EBA further recommends deleting the mandate for RTS on liquid assets. The CRR already covers the requirements for the liquidity of assets usable for CRM purposes and the stability of the value of these assets.
  • The EBA communicated it does not intend to deliver on these mandates until further notice.



9 Lessons from Our Moms

Moms really do know best. They helped us with our homework, cheered us on at little league games and bandaged our scraped knees. Above all else, our mothers imparted upon us tidbits of wisdom that helped shape who we are today. In appreciation of all the wonderful mothers around the world, we would like to share some of the most important lessons they’ve taught us here at 8of9. Here’s what we’ve learned:

  1. “Take big projects and break them down into smaller, more manageable tasks.”
  2. “My mother taught me manners and it has paid off in every relationship I have ever had.”
  3. “My mother taught me to be kind often without expecting payback - no excuses.”
  4. Fear is meaningless in the face of conviction, and never be late.”
  5. “You catch more flies with honey than vinegar. Having a good/friendly attitude gets you a long way.”
  6. “Be independent.”
  7. Taking your time to do things right the first time is always easier than having to do something twice.”
  8. “My mother taught me to keep track of my responsibilities and obligations by writing them in a calendar.”
  9. “The more friends and family you have, the sweeter success feels.  Tiny successes can feel huge when you have people to share them with.”

Trading Non-Centrally Cleared Derivatives Under IOSCO

Trading Non-Centrally Cleared Derivatives Under IOSCO


The Regulator: International Organization of Securities Commissions (IOSCO)


The International Organization of Securities Commissions (IOSCO) is an international body that is recognized as the global standards setter for the securities industry. IOSCO works with the G20, the Financial Stability Board (FSB), and other securities regulators and publishes directives that serve as the global framework for financial regulatory requirements. IOSCO’s stated objectives for securities regulation are to protect investors, to maintain fair, efficient and transparent markets, and to seek to address systemic risks.[1]

IOSCO publishes directives that serve as the natural starting point for international regulators. For example, in 2015 IOSCO published the final framework for “margin requirements for non-centrally cleared derivatives,” which established minimum standards for margin requirements as agreed by the Basel Committee on Banking Supervision (BCBS) and IOSCO.[2] This framework has been implemented in the United States through "CFTC Final Margin Rules" and "Prudential Regulator Final Margin " and in Europe as the “European Market Infrastructure Regulation” (EMIR). IOSCO’s margining standards have also been implemented in APAC throughout the various jurisdictions.[3]


Global Margin Requirements for Non-Centrally Cleared Derivatives


Since the global financial crisis, a key role of IOSCO has been producing standards, guidelines, and sound practices for the regulation of derivatives. Specifically, IOSCO has worked with the Basel Committee on Banking Supervision (BCBS) to develop a policy for margin requirements for non-centrally cleared derivatives. The policy addresses several principles:

  • Initial Margin (IM) and Variation Margin (VM) must be exchanged by all financial firms and systemically important non-financial entities[4]
  • IM should be exchanged by both parties on a gross basis:
    • There is an optional IM threshold of €50 million, so that IM need not be posted if less than €50 million and if threshold is exceeded then a €50 million reduction in IM would be applicable.
    • These requirements were phased in from September 2016 to September 2020 according to volume of trades, starting with institutions trading over €3 trillion.
    • Margin must be immediately available and fully protected.
    • Firms can use a quantitative portfolio margin model (supervisor approved) or a standardized schedule to calculate IM.
  • VM: The VM must be calculated and collected frequently (i.e. daily) for all non-cleared derivatives (phased in from September 2016 – March 2017).
  • Eligible collateral: Eligible collateral includes cash; high quality government and central bank securities; high quality corporate and covered bonds; equities included in major stock indices; and gold.
  • Exemptions:
    • Products: Physically settled FX swaps and forwards are exempted from IM.
    • Counterparties: Counterparties include non-financial entities that are not systemically important, sovereigns and central banks.
  • Re-hypothecation of initial margin collateral: IM collateral can only be re-hypothecated under strict conditions. Re-hypothecation of collateral is only permitted for hedging the IM collector’s derivatives position arising out of customer transactions.
  • Main conditions:
    • The customer must express consent for re-hypothecation in writing.
    • Collateral must be segregated from the IM collector’s assets, and re-hypothecated collateral must be segregated from the third party’s assets.
    • Re-hypothecation is only permitted once. The third party is not allowed to re-hypothecate the collateral again.
    • The customer and the third party may not be within the same group.
    • The IM collector and the third party must keep appropriate records.


EU Adaptation: European Market Infrastructure Regulation (EMIR)


Overall, the European Supervisory Authority’s (ESA) regulatory technical standards (RTS) are broadly in line with the BCBS-IOSCO standard.[5] However, a few significant differences exist between the BCBS-IOSCO standard and the RTS. The RTS includes:[6]

  • A broader list of eligible collateral. The list includes debt securities issued by credit institutions and investment firms, convertible bonds, and the most senior tranche of securitizations that is not re-securitization.
  • An explicit diversification requirement. Initial margin and variation margin is subject to concentration limits to avoid counterparties becoming overly exposed to specific assets or issuers.
  • An outright ban on re-hypothecation and other re-use of collateral as initial margin.


The Pros and Cons of the Requirements


As a result of the new margin requirements, large financial institutions benefit from reduction in both counterparty and systemic risk but face significant capital and operational costs.

Margin requirements for non-centrally cleared derivatives are expected to reduce contagion and spillover effects by ensuring that collateral is available to offset losses caused by the default of a derivatives counterparty. The added burden of tying up assets as margin collateral also forces parties to have more “skin in the game.” It reduces the number of swap agreements a firm can execute, and therefore reduces the “build-up of risk that may ultimately pose systemic risk” to the financial system as a whole.[7]

The reduction of risk comes at a cost. In addition to the costs arising from the requirement for additional collateral, the new bilateral margin standard may lead to costs in terms of liquidity management and collateral optimization due to restrictions on the rehypothecation of collateral.[8] Furthermore, firms would need to maintain highly liquid, risk-free assets beyond their initial margin requirements in order to ensure that they could meet their variation margin obligations in the event of mark-to-market losses in a fast-moving market.[9]

European margin rules go a step further and define strict limits for concentration to specific asset types posted as collateral to meet uncleared derivative margin calls. If non-European firms trading with European covered entities do not also implement the EU-style concentration limit checks as part of their margin processing workflow, they risk operational challenges with rejection by their counterparty due to breaches of limits.

In addition to the capital costs, operational costs include:[10]

  • Educating counterparties and sales teams on regulatory changes,
  • Managing the balance sheet for liquidity and capital impacts,
  • Initial and variation margin computations,
  • Creating and maintaining internal ratings for counterparties for internal haircut model,
  • Management and settlement of collateral through segregated custody accounts for IM,
  • Updating client onboarding process, and
  • Negotiating new CSAs, and re-papering of existing CSAs, with counterparties in scope of regulations.


More Confusion: What is Considered a Derivative in Each Jurisdiction?


Generally, the scope of IOSCO’s margin requirements affect non-centrally cleared over the counter (OTC) derivatives.[11] However, derivatives may be defined differently across various jurisdictions.

US: For example, to-be-announced (TBA) trades relate to a distinct market in the US and are classified as spot trades (cash market trades), instead of derivatives, since they settle within the standard settlement cycle of the securities being purchased. As such, they are considered Covered Agency Transactions under FINRA Rule 4210.

EU: The definition of derivative in EMIR simply states "options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities … which may be settled physically or in cash".[12] Since the EU has not issued a clarification of derivatives in relation to securities, it is possible that Covered Agency Transactions entered into between a U.S. registered broker-dealer and an entity subject to the requirements in EMIR will be subject to both the margin requirements under FINRA Rule 4210 and the margin requirements for non-cleared OTC derivatives under EMIR.[13]

Although TBA’s are still a mystery, the European Commission (EC) recently announced an equivalence decision which finds that the CFTC’s uncleared swap margin rules are comparable in outcome to the EU’s corresponding margin requirements for uncleared OTC derivatives.[14] This provides a little comfort for parties trading uncleared OTC derivatives from different jurisdictions who were unsure whether they would have to comply with both countries’ margin rules.


[1] https://www.iosco.org/about/?subsection=about_iosco

[2] https://www.bis.org/bcbs/publ/d317.pdf

[3] Australia implemented Prudential Standard CPS 226, Hong Kong implemented the Supervisory Policy Manual CR-G-14, Japan implemented the Final Margin Rules for Non-Centrally Cleared OTC Derivative, and Singapore implemented the Securities and Futures Act. http://securities.bnpparibas.com/files/live/sites/web/files/medias/documents/research-paper/broch_apac_2017-06-29.pdf



[6] For a detailed comparison of US vs EU margin rules see http://www.fieldfisher.com/media/5054275/margin-rules-12-16-v4.pdf. See also https://www.lw.com/thoughtLeadership/US-EU-margin-rules-reference-guide.

[7] http://www.cftc.gov/idc/groups/public/@aboutcftc/documents/file/oig_rcbcmrus060517.pdf

[8] https://www2.deloitte.com/content/dam/Deloitte/uk/Documents/financial-services/deloitte-uk-fs-otc-derivatives-april-14.pdf


[10] https://assets.kpmg.com/content/dam/kpmg/pdf/2016/03/SG-Bracing-for-change.pdf

[11] See Appendix 1 for a list of financial products subject to margin requirements across various jurisdictions.

[12] https://www.sifma.org/wp-content/uploads/2017/05/sifma-amg-submits-comments-to-fca-to-exclude-mortgage-tbas-from-the-definition-of-derivative-contracts-under-emir.pdf

[13] https://www.ropesgray.com/newsroom/alerts/2016/July/Amended-FINRA-Rule-Will-Require-Margin-for-TBA-Transactions.aspx

[14] http://www.cftc.gov/PressRoom/PressReleases/pr7629-17#PrRoWMBL

SIFMA C&L 2018 Annual Seminar RECAP

SIFMA C&L’s (Compliance & Legal Society’s) Annual Conference this year was in sunny Orlando, and 2000 of the financial industry’s senior compliance and legal professionals gathered to discuss current and emerging issues in the securities industry.


We were so happy to see old friends and make new ones at our booth. As always, 8of9 became known for the best swag at the conference. We gave out beanies with built in Bluetooth speakers – since we are helping regulatory information get communicated over all the noise in the market!

It was an especially exciting event as it was the 50th anniversary of the conference, the theme, “A Constant Voice Through 50 Years of Change.” Overall, the keynote speeches discussed the goal of recalibrating regulations within the U.S. and internationally. And as always, a pressing concern was ensuring that our capital markets are able to run efficiently in the face of stress. Visit our friends at SIFMA for their debrief.

A few interesting takeaways on some of our favorite regulations:

  • Volcker Rule

o   The House Financial Services Committee recently reported a bill to designate the Federal Reserve Board as the lead regulator for the Volcker Rule. The Federal Reserve Board would hold all rulemaking and interpretive authority.

  • SEC Best-Interest Standard

o   The SEC is looking to simplify regulations for investors. Currently, if an individual with a 401(k) account buys an annuity and holds a brokerage account with stocks in it, that person will have a financial relationship with five regulators. The SEC believes this creates too many standards to comply with and is working towards simplification.

Harmonizing International Regulations

o   Treasury reports have given approximately 200 recommendations on prudential regulations. A SIFMA panel discussed how to adapt international standards in ways that keep U.S. capital markets running efficiently. They discussed a path to move forward based on four principles:

  • Efficiency via a cost-benefit assessment    
  • Transparency through appropriate notifications and comment periods
  • Simplicity
  • Coherency in regulations
  • Crapo Bill

o   The Senate recently passed this bill which differentiates regulations according to the size of a bank, and is meant to provide regulatory relief for smaller regional and community banks. This is viewed by many conference participants as critical to spurring U.S. bank lending.

DOL Fiduciary Rule

o   Days before SIFMA’s annual conference, the 5th Circuit’s Court of Appeals vacated the DOL Fiduciary Rule.

o   The rule will be out on May 7th unless the DOL appeals to the 5th Circuit or takes the appeal to the Supreme Court.

o   SIFMA and other market participants seem pleased with the 5th Circuit’s decision.

o   However, many market participants’ compliance teams have already updated policies and procedures and changed contract language to comply with the rule. Now, these teams will need to go back to review and potentially make changes.




Interview with Aaron Heisler, 8of9's New COO

8of9 is excited to welcome Aaron Heisler as our new COO! As a financial industry veteran and longtime supporter of 8of9, Aaron brings his reputation for delivering exceptional value in strategy and implementation to our team.

Working closely alongside our internal team, Aaron has already set innovative initiatives in motion.

Read on to learn more about our new COO and his passions inside and outside of 8of9. Welcome Aaron!

What are you most excited about regarding your work with 8of9?

There are a lot of things that really excite me about joining 8of9!  I’ve known 8of9 well for over 4 years as a client, an advisor, and a friend.  There are tons of exciting things about finally joining the team but if I must pick one it is the opportunity to tackle the big industry challenges from a truly unique institution.  8of9 has the agility and culture of a startup firm, but deep experience working with bulge-bracket banks inside their existing organizations and infrastructure.  We’re helping the industry take the incremental moves that they must currently do while also developing the leapfrogging opportunities of tomorrow.  And we’re doing it without the massive overhead and complications that come from being a large firm, which allows us to be more nimble.

What challenges and opportunities are you eager to explore?

Everything!!!  Okay – maybe not “everything,” but I’m thrilled to have the opportunity to build products while simultaneously staying in touch with the latest industry drivers.  The industry is shifting really fast and really slow at the same time.  Seeing how all the pieces are coming together is loads of fun – and very challenging.  Specifically there are a huge number of data issues across the industry and until firms aggressively tackle those they won’t be able to automate many of their processes.  There is a huge opportunity to create and maintain better data as well as developing tools to help firms use that data to meet regulations and expand business capabilities.

How do you see 8of9 aiding in the mission to help bring ease and understanding to RegTech?

Mary K and the 8of9 team have always operated at the intersection of legal/regulatory issues, the “business” of financial services, and technology.  Being able to speak the various languages across these functions is how to get problems solved within the regulatory space.  I’ve spent time across each of these areas and I understand how challenging these translations are between functions.  8of9 is able to get things done because of this expertise and that has allowed us to build a good services business.  With our move into RegTech we are working on making technology tools that can dramatically improve firms’ abilities to meet existing and new regulatory challenges.

What are some of your interests and passions outside of work?

I feel blessed (and a little cursed) to have an extraordinary number of interests and passions.  First, I love to spend time with my wife and sons.  Playing card games, swimming, and watching movies are favorite pastimes for us.  Second, I am an active alumnus of Baruch College and I take part in all kinds of activities there.  This semester, for the first time, I’m teaching a full class as an Adjunct Professor and loving the opportunity to help the students think about all the layers of business strategy.  Third (and fourth and fifth and…) I love to draw, attend the theater, hang out with friends, volunteer for nonprofits, read, mentor entrepreneurs, collect artwork, etc.  Life is full of wonderful things to explore!