May. 13, 2022
Please see the following and the attached comments. We note that there are a number of efforts in this area, but we also note that incompetence, anti-Black discrimination and exclusionary practices based on race are currently operational in investment and finance, including at other regulatory bodies. Given this fact, we decline to directly address the questions raised, having done so over the past 30 years. See: 1. We stated, on February 5, 2015, in testimony to the Norwegian Ministry of Finance (https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-ee6032db67d5fe1a&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=http%3A%2F%2Fwww.creativeinvest.com%2FNorwayTestimonyFeb52015.pdf ) and on April 22, 2015 in testimony to the Government of the United Kingdom: /As the market value of environmental, social and governance factors continues to grow, companies and investment managers will engage in fraudulent practices related to these factors. These practices will range from simple falsification of environmental, social and governance records to more sophisticated, but no less fraudulent methods related to environmental, social and governance ratings./ On September 22, 2015 automaker Volkswagen admitted that defeat devices used to cheat emissions testing were installed in 11 million vehicles worldwide. 2. We designed the first mortgage security backed by Targeted Energy Efficient Mortgages in June 2006. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-245d39c01c44fe36&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.creativeinvest.com%2FEnergyEfficientMortgageMBSJune2006.pdf 3. We have quantified the impact that environmental issues have on stock prices: \"Environmental Issues and Stock Returns.\" Our 2015 report quantifies the impact environmental issues have on company stock prices. https://www.eventbrite.com/e/how-environmental-issues-impact-stock-returns-tickets-2029288657 4. In October 1998, in a petition to the United States Court of Appeals for the District of Columbia Circuit in opposition to the Citigroup/Travelers merger, we cited evidence that growing financial market malfeasance greatly exacerbated risks in financial markets, reducing the safety and soundness of large financial institutions. We went on to note that: The nature of financial market activities is such that significant dislocations can and do occur quickly, with great force. These dislocations strike across institutional lines. That is, they affect both banks and securities firms. The financial institution regulatory structure is not in place to effectively evaluate these risks, however. Given this, the public is at risk. On July 25, 2012, the New York Times reported that Sanford I Weill, former chairman and chief executive of defendant Citigroup called for a wall between a banks deposit-taking operations and its risky trading businesses. In other words, he would like to resurrect the regulation (Glass-Stegall) that he once fought. 5. On June 15, 2000, we testified before the House Financial Services Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises (GSEs) of the US Congress. We suggested that the GSEs (Fannie Mae and Freddie Mac) be subject to a thorough Social Audit. A Social Audit is an examination of the performance of an enterprise relative to certain social objectives. It also includes a review of ethical practices at the firm. Had they been subject to this audit, certain flaws in their operation which led to their failure, including ethical shortcomings, may have been revealed earlier. See: https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-7c266ed041077b02&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.creativeinvest.com%2Ffnma%2F 6. Our June 11, 2016 forecast predicted the election of Donald J. Trump. See: Why Trump Will Win. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-249320cc1170ad27&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.linkedin.com%2Fpulse%2Fwhy-trump-win-william-michael-cunningham-am-mba%2F Following the election, our December 26, 2016 forecast stated: Under any conceivable scenario, the current situation is very bad, and I mean toxic, for democratic institutions in general and for people of color specifically. Bottom line: our Fully Adjusted Return Forecast indicates that, over time, things will get much, much worse..... See: Trumpism. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-f2a811e79646df0f&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.linkedin.com%2Fpulse%2Ftrumpism-william-michael-cunningham-am-mba%2F 7. As we predicted on January 27, 2022, the Russian Federation and the Bank of Russia have agreed on a future regime..in which cryptocurrencies are recognized as an analogue of currencies, and not digital financial assets (DFA).\" See: https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-328bb467fbebb9c0&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fyoutu.be%2Fn1i4J8df0t0 8. Seaweed as a Substitute for Russian Fertilizer. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-03d5c1340f8116c1&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.impactinvesting.online%2F2022%2F03%2Fseaweed-as-substitute-for-russian.html%3Fspref%3Dtw 9. Climate Change and the OCC. Emily G. Fowler, Impact Investing Intern, McGill University. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-44412f90f2b068bd&q=1&e=c4d61492-fb0a-482d-8f67-8ec2eb0d4f08&u=https%3A%2F%2Fwww.impactinvesting.online%2F2022%2F03%2Fclimate-change-and-occ-emily-g-fowler.html%3Fspref%3Dtw Additional specific input would be futile. We have attached comments to the Office of the Comptroller of the Currency (OCC), the International Sustainability Standards Board (ISSB) and the House Financial Services Committee of the United States Congress.