Wouldnt a level Playing Field as you said from your testimony, we have concerns about things like there is a some Data Retention obligations and we think you could do it differently. There is a best interest contract framework and weve heard feedback from folks saying it is clunky and there is a more streamlined way to do it. We have a point of sale disclosure requirement and people have said that that is not necessary. And so what weve done in every circumstance when someone said that the best interest contract is clunky, our response is tell us how to do it better. How do we retain that north star of enforceable best interest contract and still get it done and that is the feedback weve been getting and it has been helpful. And youve incorporated it. We havent made final decisions yesterday. We wont put out a rule until weve gotten all of the comments. Im confident if history is a guide the final rule will be materially different than and better than the proposal because you have to b
Their own studies show the main drivers of default are loan devalue, borrower credit score. Everything else is literally a rounding error. And so of course, the final doddfrank rules essentially abandon the things that actually drive default. And endless servicing requirements, again making it near impossible to foreclose. My opinion is the rule increased foreclosures last time around rather than decrease them. And the harder it is and the mission has nothing to do with financial stability. The mission is to use the the regulatory system to force prudent borrows to subsidize imprudent. We all knew the crisis was quite costly. It also will provide a cover for massive expansion and government powers. One minute. Im not even go i think to need that. So i would say and would say avoid financial cryises. I think a repeal is not enough. The presystem was broken. It was flawed. And to me one of the real flaws of doddfrank is it extends the precrisis system. The theme of doddfrank is, lets exp
Minerals for firms not only firms getting the actual hard commodities there, but also for firms well down the supply chain, who have no idea where the aluminum in the electronic parts came from. So i think its telling when a liberal law ultimately convinces the Washington Post Editorial Board that it was a bad idea, which they have come out against conflict minerals. Its time to revisit the motion all together of including immaterial disclosures in security laws. Both by legislative fiat and by the sccs own power. And republican and democratic chairmen have both been guilty of this. I think it should be a binding constraint on any rule making. And business round table stands for the proposition. How is a mandatory immaterial disclosure going to provide benefit to investors . None. By definition fails cost benefit analysis. We have ways to measure immateriality. Methodology that has gotten great in the last ten years. I think it should be a binding constraint, the same way for litigants
Blogger undeniably some bad apples, this is not a case about bad people doing bad things. The majority of folks and nospace are trying to do the right thing every day. Enough of the problem is good people operating within a structurally flawed system. A market that sees personal financial interest of the advisor in the firm all too frequently missed the links in the best interest of the country. The result is what we saw happen. Our goal is straightforward to align the best interest of the customer what does that the advisor in the firm. The proposed rule in the product of a significant amount of average to stakeholders. I appreciate support from so many in the industry. People are trying moynihan, ceo of bank of america is bank of america is it doing what is in the best interest for customers is absolutely the right thing to do. Founder of vanguard very strong supporter will hear from the witness sure they have played in this space every day as a fiduciary work in the small investors
Other sister agency. Its a meritorious move. You said is, quote, good people operating in a flawed system. Would you explain that . Sure. There is a misalignment between the incentives that a person giving advice has and the best interest of the consumer. So, for instance, again, getting back to the tofels, if you have four or five different products under the current suitability rule that are suitable and product the first product, the variable annuity generates 26,000 a year in fees and another product, which would have a comparable return has a fraction of those fees, you have per verse incentive to steer them to the product that generates the most fees. And again, that is totally permissible so im not casting aspersions on the person that does it. Im saying thats not right. And we can device a system and i underscore what i said in my testimony, theres a substantial number of people, including one of the witnesses who will come up on the next panel, that operate under a fiduciary m