Testimony, Speeches and Presentations

Petition and exhibits for rulemaking regarding resubmission of shareholder proposals, 4/11/14

Petition and exhibits for rulemaking regarding resubmission of shareholder proposals failing to elicit meaningful shareholder support.

FSR Statement re: “Examining How Washington Red Tape Impairs Economic Freedom” – 4/8/14

The member institutions of FSR believe strongly that there is a proper role for regulation in the financial services sector, to protect consumers and to protect the entire financial system. There are, however, regulatory burdens that pressure our members to stop offering financial products that are safe for our institutions, and provide a needed...

“Data Breach on the Rise: Protecting Personal Information from Harm” – Tim Pawlenty Testimony, 4/2/14

Cyber risk is increasing in pace, complexity and potential impact. The threat has expanded from fraudsters committing financial theft to hacktivists causing disruptions and nation states threatening serious data manipulation and destruction. Cyber risk affects all institutions in our sector – large and small, banks, credit unions, insurers and...

Joint Amicus Brief re: Economic Substance Doctrine, 03/31/14

As originally conceived by this Court, the economic substance doctrine imposed a narrow restriction on what the government otherwise concedes is lawful activity: a taxpayer may not claim tax benefits from a transaction that generates “nothing of substance” other than those tax benefits.

“Finding the Right Capital Regulations for Insurers”, Statement for the Record – 3/11/14

Applying bank-centric leverage and capital requirements, as contemplated in Basel III, to insurance companies ignores fundamental differences between banks and insurers.