By Arjan Schütte, Managing Partner, Core Innovation Capital
Our venture fund, Core Innovation Capital, is singularly focused on investing in scalable financial technology companies that serve the American emerging market, the unbanked and underbanked. We have promised our investors (like Goldman Sachs) above market returns and we spend significant time analyzing the profit potential of each investment we make. That said, we also intend to invest in companies that will have a short- and long-term positive impact on the financial lives of the people they serve. We believe financial services have a significant role in anyone's upward mobility, and millions of responsible, hard working Americans are stuck in a vicious cycle where their financial tools erode, instead of enhance their net worth and financial capabilities.
CFSI's Compass Principles initiative is a bold and critical effort to set a standard for how financial services can and should function for people. It's critical because financial services are complicated. As we can see in the marketplace and Washington, D.C., the tug and pull of organizational priorities leaves both consumers and industry with unsatisfying results (mostly consumers, if you ask me). Our partners at CFSI established the Compass Principles to set an aspirational quality standard that serves both industry and people (also known as consumers).
This is not about concessions. This is about integrity. Given the apparent lack of clarity on what consumer finance with integrity means, it's high time to (re)establish some norms. CFSI's process for doing this is socratic, collaborative and inclusive. Ultimately, we believe the objective should be to settle on standards that are attainable and aspirational, and that consumer finance companies sign up, make commitments and elevate the industry to world-class best practices.
My partner, Mike Harris, and I are in. We're pre-committing (since there is no formal means by which to commit today). We're doing this not because we expect to agree with every last item, nor because we expect to already "comply" to all standards today, but because we agree with the vision and we trust CFSI and their approach. We're doing this because we exclusively invest in disruptive financial technology companies that we intend to set the new gold standard. Commitment isn't just saying so in a blog post. Starting in 2012, we commit to integrate the Compass Principles into our venture fund as follows:
- To participate in the dialogue to refine the meaning of the Principles
- To use the Principles in our underwriting of new potential investments
- To ask our portfolio companies to commit to the Principles
Our intent is to tighten the specificity of our Compass Principles commitment as the Principles become more specific and as we interact with our fund's stakeholders. And our hope is that our partnership and our portfolio companies will both lead the industry and be challenged to improve.
Arjan Schütte is Managing Partner or Core Innovation Capital (www.corevc.com), the only venture fund to focus entirely on financial technology for American emerging market.
By Saud Bangash, Intern, Innovation and Research, Center for Financial Services Innovation
Crowdsourcing is reshaping the way we think about the marketplace. Why? Because it simulates an open market environment very well. It allows providers to swarm into a market space and sell products and services to consumers, tailoring what they offer to consumer preferences. The swarm of consumers and providers grows, and affordability and quality improve as competition increases. All it takes is a well-designed technology platform which provides the necessary tools for products and services to be traded with reliable and sufficient information.
Peer-to-peer (p2p) solutions, enabled by web 2.0 and mobile technologies, are applying the crowdsourcing paradigm and setting the stage for a more efficient method for customer acquisition, service delivery and sourcing of funds. Some see crowdsourcing as a process of ‘disintermediation’, which is limiting reliance on sales agents, middlemen, brokers etc. and reducing transaction costs.
In the consumer lending sphere, ‘crowdfunding’ has emerged and has brought a fresh perspective on how we think about addressing some persistent issues of accessibility and affordability of financial services.
Two Bay Area based companies - Lending Club and Prosper – are the early birds. Both companies are offering crowdfunding services to borrowers and lenders, through which any individual or institution can lend to or borrow from each other, based on the borrower’s pre-assigned credit-risk rating and the lender’s preferences and risk tolerance. The uptake for the service has been strong - the two companies have reported that in 2011, monthly loan originations doubled to $30 million and tripled to $11 million through Lending Club and Prosper respectively. 24,000 new customers signed up on Lending Club and the platform originated a quarter billion dollars worth of new loans in 2011, more than doubling the previous four years combined. These loans were priced with net annualized interest rates ranging between 5.82% and 12.15%.
It is important to note that these two companies are not focusing on providing services which cater directly to the needs of underbanked consumers, who typically borrow in small amounts and have limited or no credit histories. Lending Club originates loans with an average size of $10,945 and rejects 90% of the loan applications it receives. The reason underbanked consumers are not a priority for these two companies is because of regulatory bottlenecks. The Securities and Exchange Commission regulates p2p loans like securities, with pricing based on assigned risk categories using borrower credit reports. This automatically creates a selection bias for consumers with established credit histories and eliminates most underbanked consumers from the pool of potential borrowers.
Structuring p2p lending platforms like auction markets, which allow market players to transact freely based on their preferences and risk tolerance, will help open-up the p2p lending market to underbanked consumers. As a first step, a regulatory framework for a true auction based loan products market needs to be developed and introduced.
Crowdfunding is a frontier market space, which has immense potential to be scaled to improve the availability of high-quality, low-cost credit options for underbanked consumers. Considering the high level of connectivity, visibility and traceability that p2p platforms offer, p2p lending could prove to be a promising solution, particularly for consumers with weak credit histories and limited access to affordable loans.
By Joshua Sledge, Analyst, Innovation and Research, Center for Financial Services Innovation
It’s June 13th, 1997 in Chicago, Illinois. Inside the United Center, the Chicago Bulls are battling the Utah Jazz in Game 6 of the NBA finals. Up three games to two, a win for the Bulls would give the team its third consecutive championship. With the score tied and only 28 seconds left in the game, the Bulls work the ball to NBA Legend Michael Jordan. Jordan gets a step on his man, drives the lane, rises into the air…and passes the ball to Steve Kerr, an unremarkable bench player, who knocks down a wide-open 15-foot jump shot, giving the Bulls a two-point lead with five seconds to go. The Jazz blow their final possession and the celebration begins as the Bulls are once again NBA champions.
I’m not a Bulls fan (Go Pistons!), but this sequence has always been one of my favorite moments in NBA history. Why? Because it provides a perfect example of a team achieving success by playing to the specific strengths of its members. By this point in his career, Jordan had established a reputation as perhaps the greatest “closer” in NBA history by making countless big shots in big moments. When he headed toward the basket, the Jazz just knew he was taking the final shot…which is why the player guarding Kerr went to help defend him. Now, on the flipside, Kerr was never regarded as an elite player but, man, could he shoot the lights out! For him, that wide-open jump shot was as routine as they come. On that final play, the Bulls relied on Jordan’s knack for late-game heroics and Kerr’s shooting range – their respective strengths – to bring another championship to Chicago.
Leveraging the respective strengths of different parties to achieve success - not only does it make a great NBA team, but it is also the underlying premise that makes cross-sector partnerships a powerful means of meeting the financial services needs of the underserved. We at CFSI work with a variety of stakeholders – nonprofits, financial institutions, nonbank providers, and more – all of whom are working to better serve the unbanked and underbanked. Just like Jordan and Kerr, each of these groups has certain strengths that can help them achieve their goal. Nonprofits are often able to form deep and trusting relationships with their clients, enabling them to provide the type of ongoing support and advice that leads to asset-building and positive changes in financial behavior. Financial institutions and nonbank providers have expertise and experience in offering the products underserved consumers need to take steps toward greater financial health. Working together allows these organizations to play to their strengths while still providing holistic solutions that help the underserved use products successfully and create opportunities for increased financial prosperity.
The Kindergarten-to-College (K2C) program provides an excellent example of the power of cross-sector partnerships. Under the program, children entering kindergarten in San Francisco Public Schools have a college savings account automatically opened for them, pre-funded with an initial $50 deposit. The program was made possible by a collaboration of government agencies (San Francisco’s Office of Financial Empowerment), nonprofit groups (EARN, CFED, the New America Foundation) and financial institutions (Citibank). By working together, these parties have created a citywide program that will not only encourage San Francisco citizens to plan for college, but also gives them the savings account and ongoing support they need to do so.
So, how about you? Have you considered how a cross-sector partnership could bolster your efforts to responsibly serve the unbanked and underbanked? If not, give it some thought. You never know, the Steve Kerr to your Michael Jordan may be out there, waiting for you to pass them the ball so that, together, you can be Compass Principles Champions.
By Rachel Schneider, Vice President, Innovation and Research
Over the summer, I blogged about a woman I’d met. I called her Joanna. Her story really stuck with me, so I’m going to repeat it here. Joanna puts $2-3 worth of gas in her car at a time. Why doesn’t she fill up her gas tank? Because she’s too worried that she might need the money she’d spent to fill up her gas tank later in the week for some unexpected expense. She can’t afford to leave that value just sitting in her car.
But this creates a major loss of value for her in other ways. First, there is the loss of time: who has time to go to the gas station a few times a week? Second, there is the anxiety: will she run out of gas on her way to work today?
Seems to me that a loss of value like this should be something you can build a business out of fixing. Imagine the long-term customer loyalty (and genuine appreciation) that a business could inspire if it fixed Joanna’s problem.
Perhaps the answer lies in a new, yet-to-be-designed, small dollar revolving credit product. Or maybe Joanna’s employer could adjust her payment schedule so that the timing of her incoming cash better matches her spending needs… start-upFlexWage is developing a payroll-based credit product that could potentially accomplish this goal. Or, a planning-based approach might work: another early stage start-up, Juntos Finanzas, is developing a real-time, cell-phone powered cash budgeting system that might give Joanna enough visibility into her finances to allow her to spend $15 rather than $3 at once.
In all likelihood, there is no one right answer. Multiple business opportunities probably exist in trying to serve Joanna’s need. But it is certainly the case that generating the right insight, the right creative idea, requires deep consumer knowledge.
By Kate Marshall Dole, Analyst, Innovation and Research, Center for Financial Services Innovation
If you are like most people, you carry your mobile phone everywhere you go. Your mobile phone may even be the first thing you look at when you wake up in the morning. In other words, your mobile phone has your eyes and ears throughout the day unlike anything (or possibly anyone) else. It stands to reason, then, that your mobile device may be the perfect tool for delivering real-time access to your financial account information. Mobile devices, and more specifically, mobile financial services, have significant implications for promoting success in consumers’ financial lives.
In the early fall, when we published our latest white paper on mobile financial services for the underbanked (written in partnership with Celent), one of the areas we identified as holding potential for financially underserved consumers was mobile remote deposit capture (RDC). We argued that mobile RDC, particularly when paired with prepaid accounts, could improve these consumers’ lives by saving them time and expense relative to the alternatives. However, we noted two barriers to broadly offering mobile RDC to underserved consumers – the potential fraud risk to providers and the delay in funds availability for consumers. In our research, we heard these concerns from many players across the spectrum of mobile financial services companies.
While these two barriers have not yet been entirely overcome, it’s a testament to the rapidly evolving nature of technology that, in the few months since the paper’s release, we’ve seen several announcements of plans to offer mobile RDC with prepaid. Processing companies such as Chexar, FIS and FactorCheck have developed risk-management software that can evaluate check images. These companies then take on the risk of the transaction, rather than the prepaid program manager.
The speed with which funds can be made available remains paramount, and more work needs to be done to ensure that the value proposition for consumers is in place – if it takes several days for funds to be deposited in their accounts using RDC, these consumers would likely choose a trip to the check casher for immediate funds instead. However, mobile RDC could be a key entry point for underserved consumers to begin to take advantage of the full array of tools that are available on the mobile phone – everything from balance checking capability to bill pay alerts and savings reminders to locating ATMs with the most favorable fee structure. These mobile financial services offerings, and many more, will only grow over time in their availability and ability to promote successful consumer behaviors.
By Karen Biddle Andres, Manager and Consultant, Advisory Services, Center for Financial Services Innovation.
Meet Rupert. Rupert has been coming to Big Grocery Store for his financial services for years. He cashes his check there every two weeks. He pockets a little bit of cash, and now he is putting the rest on a prepaid card he bought at Big Grocery Store. He often uses the expedited bill pay that Big Grocery Store offers. Rupert feels really satisfied with what Big Grocery Store is offering, since it allows him to manage his financial life efficiently and well. He doesn’t need anything more. So Big Grocery Store feels good about meeting Rupert’s needs and about creating a nice fee-based revenue stream that will allow them to sustain this relationship. Well done, Big Grocery Store.
But as Rupert walks out the door of Big Grocery Store, whistling in satisfaction, Ethel is hurrying in. Ethel started out with the same set of needs as Rupert, using the same set of products. But there is something in Ethel that wants more. Ethel has a dream of owning a house someday. She also wants the rewards and the cash management flexibility that come with a higher limit credit card. If Big Grocery Store doesn’t have a way for Ethel to transition to a different suite of products over time, then Ethel will probably leave. She doesn’t want to leave – she just wants some choices. She trusts Big Grocery Store – they’ve been transparent and inclusive, and they’ve met her needs for a good while now. She just wants to know what her options are, and golly, it would be great if Big Grocery Store would help her take the next step. Maybe Big Grocery Store could build out some savings options on their prepaid card with some in-store rewards built in, since she already does her grocery shopping there. Or they could offer some low-limit credit cards. Maybe a secured card to help Ethel build her credit?
CFSI’s fourth Compass Principle, “Create Opportunity”, is all about the thoughtful contemplation of the next steps that a consumer like Ethel might want. Rupert is cool where he is, and that’s great. But we submit that Big Grocery Store has a lot to gain by giving Ethel some choices. By being a force for good in her life, if she asks for it. By helping create some opportunity for her.
Create opportunity. Seems reasonable. Desirable, even – yes?
No?
Alas. It seems that with this principle, we have kicked up some philosophical dust.
As part of the Compass project team at CFSI, I have had a front row seat to many of the discussions that our Compass Principles have sparked. As the leader of our Innovators Roundtable and our Underbanked Solutions Exchange, our network forums for financial services providers looking to learn and strategize about underserved strategies, I have facilitated numerous discussions on the Compass Principles. And without fail, every time, like clockwork, when we get to Create Opportunity, I see people pulling on their gloves, waiting for the bell to ring.
Here’s their point: doesn’t this Principle really amount to us telling the customer what to do? Haven’t we, the self-identified “underserved industry”, evolved our thinking beyond migration or graduation? Haven’t we all heard over and over (even from CFSI!) that we’re supposed to “meet the customer where they are”? So all of a sudden we’re supposed to revert to our previous well-intentioned-but-paternalistic ways and try to force them up a product ladder? What gives?
That’s the gist of the argument. I fully get it. I understand that there’s something about this Principle that summons images of ladders or stairs. Yes, meeting the customer where they are is the right first step. And no, we don’t want to patronize or condescend to our customers by essentially telling them that we know what’s good for them. But here’s the thing: this is not a debate about free will or laissez faire. This is about choice. Our point with this principle is that consumers should have a choice.
Let’s put it this way. Just because Big Grocery Store builds a ladder, it doesn’t mean Rupert has to climb it. But it’s a sure thing that if Big Grocery Store doesn’tat least offer the next rung up, or a path to it, Ethel will stay right where she is.
By Karen Biddle Andres, Manager and Consultant, Advisory Services, Center for Financial Services Innovation.
Champion.
That’s a big word with many associations.
Here’s what my brain digs out of its files when I enter “champion” into the Boolean search engine in my head:
- George R. R. Martin’s Game of Thrones justice system, wherein the accused may call upon a champion to swordfight on his behalf – to the death! (Stop laughing. And call me when you’ve read the first book.)
- The legendary Queen rock anthem to whose iconic vocals and signature bass line many a sports team has hoisted a trophy in a confetti snowstorm, after earning the title of league champion.
- The legendary University of Michigan football coach Bo Schembechler and his belief that “Those who stay will be champions.”
The disorganization of my mental file cabinet notwithstanding, these search results reveal something interesting about what it means to be a champion. Some champions are called to greatness in an instant. Some spend years practicing and dreaming and sweating in order to earn their shot. But others need only make a choice or a commitment. Sometimes, being a champion does not require herculean feats of strength or skill. It might be that all you need is to raise your hand and say, “I will.” As it turns out, we are all capable of that – as Coach Schembechler knew.
With the Compass Principles, the Center for Financial Services Innovation (CFSI) is embarking upon a critical journey toward higher quality financial products and services for all consumers, including the underserved segment that is so central to our work. We are looking for fellow travelers, and we are delighted to find so many friends, old and new, from across the industry, who are jumping into our boat with both feet. These friends are giving us feedback on our website, on the phone, at conferences. They are asking us how they can incorporate the Compass Principles into their operations and into their corporate cultures in a real way. They are asking us for slides, for materials that they can use to build support and enthusiasm for this framework within their organization. (Hint, hint, Dear Reader – have you engaged with us yet?)
In addition to fellow travelers, we are actively seeking Compass Champions. Specifically, we are looking for a handful of companies to raise their hand publicly to say, “I will” – and then to back up that commitment with action. At Compass Champion companies, senior leaders will agree to commit to a specific, measurable initiative to demonstrate the application and adoption of the Compass Principles. They will then invest resources to support that commitment, share progress toward the commitment with the marketplace via CFSI’s channels, and, in the process, advise CFSI on the development of Compass adoption tools for the rest of the industry based on their own experiences putting the Principles into action.
Are you as committed as we are to high quality financial products for all consumers? Does that level of engagement set your feet to stamping to some imaginary stadium rock? Will your company be one of our official Compass Champions? If you’re interested, call us. Raise your hand.
(And hey, at least we’re not putting a sword in it.)
By Rob Levy, Manager, Innovation and Research, Center for Financial Services Innovation
Since launching the Compass Principles (guidelines for quality in financial services) last year, we at CFSI have gotten a lot of feedback that the Principles aren’t clear enough in articulating that for-profit companies can and should make a profit while serving consumers through high-quality products. To be fair, the Principles are largely focused on consumer outcomes and not provider bottom lines. However, we certainly believe that for-profit companies can and must make a profit while serving underserved consumers well. They can’t do it otherwise. They won’t do it otherwise.
This is why “Sustainable and Scalable” is the very first of our core underlying values for all the Compass Principles. In fact, we will be updating that value to say “Profitable and Scalable” to be even more explicit in response to some of the feedback.
We not only believe that providers can and should make money serving consumers with high quality products, we are convinced they will. Underserved consumers often rely upon expensive, unsupportive, and sometimes predatory financial products. Providing a viable alternative that is both affordable and consumer-oriented can bring in major new revenue streams through the acquisition of new customers or by more fully meeting the needs of existing customers.
So yes, it’s OK to make a profit serving the underserved. But then the question often becomes, how much profit is too much when it comes from the wallets of the poor? When is a checking account fee too high? When is a loan too expensive?
Some would suggest the answer is a number, a reasonable margin above cost or an appropriate growth rate. Others would say any profit cap is un-American, and that providers should charge as much as they can get away with. I would like to suggest that the answer isn’t a number, a profit margin, or a cart-blanche defense of free market capitalism.
The answer is quality. To be more specific, the answer is a high-quality product (see: Compass), in a free and open marketplace, with appropriate consumer protections in place and enforced. Let me explain.
If your product is aligned with the Compass Principles for quality, abides by all applicable law, and exists in an open, fair, and well-regulated market, then as far as this writer is concerned, charge as much as you think the market will bear. Consumers will balk if the price is too high. Competitors will undercut you if you’ve left them room to do so. Regulators will rein you in if you’ve abused the customer or the law. And adhering to quality standards will mean that you've done all this while improving the financial well-being of the end consumer.
Of course, making a high-quality product isn't easy. We don't know the exact path, but certainly it takes commitment, innovative thinking, and lots of trial and error to design a product that fully embraces inclusion, builds trust with the consumer, promotes their success, and creates opportunity for their upward mobility. It’s no cakewalk to create a profitable financial product for an underserved consumer that leaves him or her better off at the end of the day. But if you can figure out that formula, sky’s the limit.
So how do you design a product that you can confidently and justly make gobs and gobs of money off of, no matter who’s your customer? The answer is quality.
By Kate Marshall Dole, Analyst, Innovation and Research, Center for Financial Services Innovation
Oftentimes, responsibly expanding access to financial services for underserved consumers means taking a creative, new spin on an old model. As observed by Mark Hookey, founder of Demyst.data, social interactions and connections have been used for a long time to support lending decisions in the microfinance world – and today, several start-ups are looking for ways to incorporate social media behaviors as an additional layer of data to analyze when determining whether to extend credit to consumers. While this new frontier of credit risk analysis carries obvious potential dangers to consumers, it also holds the potential to unlock a new source of positive information that could improve access to credit for those who need it most.
As Romy Parzick explained in last week’s blog posting, the “Embrace Inclusion” principle has implications for everything from the physical location and design of branches to account structure to product features. Today, we’re focusing on the principle of inclusion as it applies to the knotty world of credit, and specifically, the data that lenders use to make their lending decisions.
People who lack a credit history are often in a tough spot when they want or need to get credit. You need a credit score to access reasonably priced credit – and yet, without credit lines to repay, it’s tough (or impossible) to bolster your credit score. Over the last decade or so, companies have emerged that look at all kinds of data outside of that captured by traditional credit reporting agencies. A number of companies have found ways to collect and analyze non-traditional pieces of information – like rental payments, utility and cell phone payments, public records, and more – to evaluate creditworthiness.
Today, the latest generation of alternative credit data companies is trying to discover whether and how a person’s online presence can be used to give lenders a fuller picture of the credit risk they pose. In recent weeks, we, at CFSI, have come across some interesting new innovators that fit into this category. We offer these examples to spur conversation about the Compass Principles, not as an endorsement of the emerging business models. Two of the below examples are directly using social media to score consumers (Demyst.data, Kabbage SocialKlimber), one is offering consumers the opportunity to show-off the positive credit standing through social media channels (Credit Sesame Certified Badge), and one is scoring people’s online influence outside of the realm of credit (Klout).
Demyst.data
Mark Hookey of Demyst.data thinks that social media behavior could eventually replace the traditional credit system. That’s why his company is looking at ways to use information about a person’s presence and activities on social media sites like Facebook, LinkedIn, Twitter, and more, and trying to figure out the predictive power of that information. Demyst.data is in pilot with several financial institutions, with the eventual goal of helping them grow their portfolios by offering a different perspective on their consumers. Mark sees the social media information – along with other information, including geolocation and telecommunication usage data – as creating a more complete profile of a large group of potential customers.
Credit Sesame Certified Badge
Personal finance website Credit Sesame recently launched its new Certified Badge program, which lets consumers post a Badge in various places (including social media profiles) to showcase positive credit behavior. Certified Badge acts as a consumer-level equivalent of signals like BBB, VeriSign and Trust-e, with possible relevance for everyone from job seekers and employers to online sellers to renters to dating site members.
Kabbage
Kabbage uses crowdsourcing to decide whether to lend money to small online merchants, looking at the user feedback they’ve received on eBay. The company then uses Paypal both to transfer funds to the merchants and to accept payments. Kabbage’s new SocialKlimbing feature lets merchants connect their social activities to their Kabbage accounts, providing an additional layer of information for underwriting.
Klout
At ID Analytics’ Advance 2011 Conference in September, Matt Thomson, the VP of Platform from Klout, compared his company’s Klout score to a FICO score for today’s social-media-dependent world. Klout scores the influence of social media users, based on personal and professional connections. Your Klout score, measured on a scale of 1 to 100, indicates the level of influence you have in the social media sphere. The Klout score is not envisioned today as a tool for making credit decisions. However, it fits into the larger trend of evaluating and scoring consumers’ online lives.
There are certainly risks to this approach for consumers, and it’s still very early. But the young are a large segment of underbanked consumers, and you can bet that young unbanked and underbanked consumers are using social media sites. In order to embrace inclusion, we have to keep an open mind about tools that can be used – both old and new – to facilitate healthy and responsible credit usage for all consumers.
By Romy Parzick, Manager, Innovation and Research, Center for Financial Services Innovation
Our first Principle is “Embrace Inclusion: Responsibly Expand Access.” When this Principle is applied, consumers, including those from traditionally underserved groups or communities, are creatively reached and well-served with a relevant suite of quality, affordable financial services, provided in a dignified, comfortable, and convenient manner.
The word “responsibly” is an intentional modifier to “expanding access”? We all know too well that the subprime mortgage crisis expanded access tremendously, but in ways that were irresponsible and ultimately disastrous for business, communities, and families. Expanding access in a responsible way means critically evaluating your strengths and weaknesses as a provider, assessing the marketplace demand for your product or service, and thinking creatively about how to reach as many consumers as possible with a solution that is mutually sustainable.
Given the Census Bureau report released last month showing that poverty numbers rose by 2.6 million last year, bringing the number of Americans living below the official poverty line to 46.2 million people, there is both social and business value to providers embracing inclusion.
I like to think about this Principle in terms of lowering barriers-to-entry. As applied to traditionally underserved consumers, barriers-to-entry may come in many forms, including: minimum account balances, hours of operation, credit score requirements, Chex systems reports, and Know Your Customer identification requirements. Providers who embrace inclusion design and deliver their products and services in a manner that successfully manages risk without unnecessarily limiting access to potential consumers.
Watch the Embrace Inclusion video on our website to learn more!
What providers have you seen do this well? Tell us about them!
