September 30, 2010
Multiple Additional Comments Attached.
While the Dodd-Frank Bill requires the SEC to deploy an Ombudsman in the Office of the Investor Advocate, this may not be the best configuration.
The Opportunity exists to use this powerful human technology on multiple levels: Inside the SEC for its own workforce Inside regulated institutions for those wrkforces and between the SEC and the regulated community, as appears to be the intent of the Dodd-Frank Bill Ombudsman.
As the attached information makes clear, properly structured and executed Organizational Ombudsman are demonstrated to make a significant positive difference in the organizations where they are employed. This would be the case whether these OOs were to work in the SEC or any of the organizations it regulates.
Before preceding with the crafting of policy on this issue, PLEASE consult with recognized expertise (much of which is employed already in the Federal Government), consult the existing standards offered by different organizations, and consider expanding the use of the Ombudsman well beyond the limited description in the Dodd-Frank Bill.
The SEC's previous experience with requiring ombuds programs in mutual fund companies via consent decrees and the outcomes of that effort, suggest it would be wise for the SEC to involve appropriate outside expertise going forward.
Thank you .
John W. Zinsser
Pacifica Human Communications, LLC.