October 1, 2010
With regard to Title II, Sec. 204(a)(3), it is important for "the Corporation and all other appropriate agencies" to regulate in a manner that 1) is consistent from one covered financial company to the next, 2) is transparent and available to the public, and 3) applies meaningful gravity to those who are found to have neglected their responsibilities "for the condition of the financial company." The Section's aim to minimize "moral hazard" must be undergirded by policies that do not represent inconsequential "slaps on the wrist" to the negligent but instead represent highly consequential civil penalties seen by potential offenders as not remotely worth the risk of negligence.
Robert O.L. Lynn
Financial services consultant