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	<title>Comments for GlynHolton.com</title>
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	<link>http://glynholton.com</link>
	<description>A Blog About Risk</description>
	<lastBuildDate>Thu, 08 Mar 2012 01:29:37 +0000</lastBuildDate>
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		<title>Comment on Zombie Glass–Steagall by gholton</title>
		<link>http://glynholton.com/2011/10/zombie-glass%e2%80%93steagall/comment-page-1/#comment-397</link>
		<dc:creator>gholton</dc:creator>
		<pubDate>Thu, 08 Mar 2012 01:29:37 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.contingencyanalysis.com/?p=1298#comment-397</guid>
		<description>Dodd-Frank was made sweeping to satisfy voters and made ineffective to satisfy Wall Street. It is riddled with half-measures and loopholes. It isn&#039;t all bad. For example, the new consumer protection agency is a positive step. I would repeal the Volcker Rule and restore the Glass–Steagall Act’s separation of commercial and investment banking. Overall, we need much stronger regulation of the financial services industry. Dodd-Frank was a huge disappointment.</description>
		<content:encoded><![CDATA[<p>Dodd-Frank was made sweeping to satisfy voters and made ineffective to satisfy Wall Street. It is riddled with half-measures and loopholes. It isn&#8217;t all bad. For example, the new consumer protection agency is a positive step. I would repeal the Volcker Rule and restore the Glass–Steagall Act’s separation of commercial and investment banking. Overall, we need much stronger regulation of the financial services industry. Dodd-Frank was a huge disappointment.</p>
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		<title>Comment on The SEC&#8217;s Problem With the First Amendment by gholton</title>
		<link>http://glynholton.com/2011/03/the-secs-problem-with-the-first-amendment/comment-page-1/#comment-396</link>
		<dc:creator>gholton</dc:creator>
		<pubDate>Thu, 08 Mar 2012 01:22:44 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.com/?p=424#comment-396</guid>
		<description>The article is vague about such matters precisely because the SEC is vague about them. If you plan to run your own sate of directors at a company&#039;s annual meeting, the Commission&#039;s proxy solicitation rules are fairly clear (and are likely in conflict with the First Amendment). If you plan merely to publicly advocate about upcoming votes, then it is not clear what is permissible. The rules are open to interpretation ... but the threat of heavy handed enforcement is there.</description>
		<content:encoded><![CDATA[<p>The article is vague about such matters precisely because the SEC is vague about them. If you plan to run your own sate of directors at a company&#8217;s annual meeting, the Commission&#8217;s proxy solicitation rules are fairly clear (and are likely in conflict with the First Amendment). If you plan merely to publicly advocate about upcoming votes, then it is not clear what is permissible. The rules are open to interpretation &#8230; but the threat of heavy handed enforcement is there.</p>
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		<title>Comment on The SEC&#8217;s Problem With the First Amendment by Richard Treumann</title>
		<link>http://glynholton.com/2011/03/the-secs-problem-with-the-first-amendment/comment-page-1/#comment-316</link>
		<dc:creator>Richard Treumann</dc:creator>
		<pubDate>Wed, 04 Jan 2012 00:59:23 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.com/?p=424#comment-316</guid>
		<description>I think this blog could be improved by adding a bit more background on the implications of the SEC rules which seem to be in conflict with the first amendment.

A bit more about who might be likely to violate a rule and need to resort to a first amendment argument against the weight of the SEC. Also what would trigger the SEC to act.

For example, if I were to place this ad, would the SEC come down on me because Goldman Sachs asked them to?</description>
		<content:encoded><![CDATA[<p>I think this blog could be improved by adding a bit more background on the implications of the SEC rules which seem to be in conflict with the first amendment.</p>
<p>A bit more about who might be likely to violate a rule and need to resort to a first amendment argument against the weight of the SEC. Also what would trigger the SEC to act.</p>
<p>For example, if I were to place this ad, would the SEC come down on me because Goldman Sachs asked them to?</p>
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		<title>Comment on Zombie Glass–Steagall by Richard Treumann</title>
		<link>http://glynholton.com/2011/10/zombie-glass%e2%80%93steagall/comment-page-1/#comment-315</link>
		<dc:creator>Richard Treumann</dc:creator>
		<pubDate>Tue, 03 Jan 2012 18:20:40 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.contingencyanalysis.com/?p=1298#comment-315</guid>
		<description>Glyn -

Are you urging that we press for repeal of Dodd Frank as a whole or that we urge revising a piece of it.

As I understand the situation, the vast majority of opposition to Dodd, Frank comes from people who want to return to the no-rules world of GLB.

I will need a lot of convincing to consider lending the zero-regulation side any support.

Your comments on this hamstrung Volcker rule seem reasonable so if you can be more specific about what message you think congress should get, I may be ready to do my part.</description>
		<content:encoded><![CDATA[<p>Glyn -</p>
<p>Are you urging that we press for repeal of Dodd Frank as a whole or that we urge revising a piece of it.</p>
<p>As I understand the situation, the vast majority of opposition to Dodd, Frank comes from people who want to return to the no-rules world of GLB.</p>
<p>I will need a lot of convincing to consider lending the zero-regulation side any support.</p>
<p>Your comments on this hamstrung Volcker rule seem reasonable so if you can be more specific about what message you think congress should get, I may be ready to do my part.</p>
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		<title>Comment on Abolishing Corporate Personhood: Be Careful What You Ask For. by jack ucciferri</title>
		<link>http://glynholton.com/2011/10/abolishing-corporate-personhood-be-careful-what-you-ask-for/comment-page-1/#comment-238</link>
		<dc:creator>jack ucciferri</dc:creator>
		<pubDate>Tue, 15 Nov 2011 20:31:32 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.contingencyanalysis.com/?p=1314#comment-238</guid>
		<description>Glyn you&#039;ve done it again. 

Just like you did with your paper back in 2006, you&#039;ve identified a key set of issues and proposed a novel solution.  

Thank you and I&#039;ll be in touch.</description>
		<content:encoded><![CDATA[<p>Glyn you&#8217;ve done it again. </p>
<p>Just like you did with your paper back in 2006, you&#8217;ve identified a key set of issues and proposed a novel solution.  </p>
<p>Thank you and I&#8217;ll be in touch.</p>
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		<title>Comment on I&#8217;ll Be Gone. You&#8217;ll Be Gone. by Online brokers &#124; My 2 cents tips</title>
		<link>http://glynholton.com/2007/01/ill-be-gone-youll-be-gone/comment-page-1/#comment-195</link>
		<dc:creator>Online brokers &#124; My 2 cents tips</dc:creator>
		<pubDate>Mon, 10 Oct 2011 14:04:36 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.wordpress.com/?p=47#comment-195</guid>
		<description>[...] papers by Glyn Holton showed my a new way of thinking about my own mistrust in banks, funds, insurers &amp; co. I [...]</description>
		<content:encoded><![CDATA[<p>[...] papers by Glyn Holton showed my a new way of thinking about my own mistrust in banks, funds, insurers &amp; co. I [...]</p>
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		<title>Comment on The Case for Incoherence by Kwak Axe</title>
		<link>http://glynholton.com/2008/09/the-case-for-incoherence/comment-page-1/#comment-116</link>
		<dc:creator>Kwak Axe</dc:creator>
		<pubDate>Sat, 18 Jun 2011 07:01:47 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.wordpress.com/?p=102#comment-116</guid>
		<description>There is an old Indian proverb that goes like... &quot;do not mix your curry and rice [until before you eat]&quot;. If the curry spoils while the rice does not, at least one has the rice. And vice-versa. But if they are mixed and one of them spoils, the other has to be discarded too. Which is a case of sub-additivity not holding.</description>
		<content:encoded><![CDATA[<p>There is an old Indian proverb that goes like&#8230; &#8220;do not mix your curry and rice [until before you eat]&#8220;. If the curry spoils while the rice does not, at least one has the rice. And vice-versa. But if they are mixed and one of them spoils, the other has to be discarded too. Which is a case of sub-additivity not holding.</p>
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		<title>Comment on CEO Pay at Fannie Mae and Freddie Mac by Claire F</title>
		<link>http://glynholton.com/2011/04/ceo-pay-at-fannie-mae-and-freddie-mac/comment-page-1/#comment-123</link>
		<dc:creator>Claire F</dc:creator>
		<pubDate>Sun, 15 May 2011 20:48:18 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.com/?p=869#comment-123</guid>
		<description>There are a couple of different approaches here:
1) Educate more individuals as investors so we become a larger proportion of stock owners in all companies; at that point we can chose to sell the stock in the companies that pay their execs more than we think is wise

2) Propose laws that require that mutual funds to pass on voting rights to mutual fund holders. This could be an accounting nightmare but if it were given to fundholders of record that had a) held the fund for at least one year and b) passed on voting rights for companies in the holdings that represent 10% of fund holdings. Fundholders could chose to pass that responsibility to the directors but would not have to.</description>
		<content:encoded><![CDATA[<p>There are a couple of different approaches here:<br />
1) Educate more individuals as investors so we become a larger proportion of stock owners in all companies; at that point we can chose to sell the stock in the companies that pay their execs more than we think is wise</p>
<p>2) Propose laws that require that mutual funds to pass on voting rights to mutual fund holders. This could be an accounting nightmare but if it were given to fundholders of record that had a) held the fund for at least one year and b) passed on voting rights for companies in the holdings that represent 10% of fund holdings. Fundholders could chose to pass that responsibility to the directors but would not have to.</p>
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		<title>Comment on Stress Testing: A Reminder from Fukushima by Glyn A. Holton</title>
		<link>http://glynholton.com/2011/03/stress-testing-a-reminder-from-fukushima/comment-page-1/#comment-122</link>
		<dc:creator>Glyn A. Holton</dc:creator>
		<pubDate>Thu, 21 Apr 2011 11:58:38 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.com/?p=583#comment-122</guid>
		<description>First of all, let me say I am sorry for what your family, and all families impacted by this tragedy, are going through.

Yours is a classic problem of decision making in the face of uncertainty. You don&#039;t have all the &quot;facts&quot;, and there are potentially significant consequences. Having family members stay with you is the safe course. Its downside — predictable inconvenience for you and those family members — is known. The alternative entails the potentially staggering consequence of radiation poisoning of family members. If you believe there is a material likelihood of that outcome, you should do everything you can to help family members leave the affected area. 

How do you assess the likelihood of that outcome? You are not a nuclear physicist or a government official (I presume) with privileged information about conditions near the plant. You can, however, consider what the eventual outcomes were of other nuclear accidents — especially Three Mile Island and Chernobyl. You can also consider your impression of how reliable assurances of the Japanese Government are. The goal of such assessments is not to figure out what is going to happen. That is impossible. It is to assess whether you think there is a material likelihood of family members&#039; health being impacted.

If I were in your shoes, I would strongly encourage family members to stay with me. I would even mail them airline tickets.</description>
		<content:encoded><![CDATA[<p>First of all, let me say I am sorry for what your family, and all families impacted by this tragedy, are going through.</p>
<p>Yours is a classic problem of decision making in the face of uncertainty. You don&#8217;t have all the &#8220;facts&#8221;, and there are potentially significant consequences. Having family members stay with you is the safe course. Its downside — predictable inconvenience for you and those family members — is known. The alternative entails the potentially staggering consequence of radiation poisoning of family members. If you believe there is a material likelihood of that outcome, you should do everything you can to help family members leave the affected area. </p>
<p>How do you assess the likelihood of that outcome? You are not a nuclear physicist or a government official (I presume) with privileged information about conditions near the plant. You can, however, consider what the eventual outcomes were of other nuclear accidents — especially Three Mile Island and Chernobyl. You can also consider your impression of how reliable assurances of the Japanese Government are. The goal of such assessments is not to figure out what is going to happen. That is impossible. It is to assess whether you think there is a material likelihood of family members&#8217; health being impacted.</p>
<p>If I were in your shoes, I would strongly encourage family members to stay with me. I would even mail them airline tickets.</p>
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		<title>Comment on Stress Testing: A Reminder from Fukushima by Debbi Mase</title>
		<link>http://glynholton.com/2011/03/stress-testing-a-reminder-from-fukushima/comment-page-1/#comment-121</link>
		<dc:creator>Debbi Mase</dc:creator>
		<pubDate>Thu, 21 Apr 2011 08:14:55 +0000</pubDate>
		<guid isPermaLink="false">http://glynholton.com/?p=583#comment-121</guid>
		<description>My family members live in Fukushima. I&#039;m really concerned about the problem and also about their health. After all, we do not understand the repercussions of the radiations&#039;s magnitude on their health, they might get particularly sick!!! Do you reckon I should ask them to come and live together with me?</description>
		<content:encoded><![CDATA[<p>My family members live in Fukushima. I&#8217;m really concerned about the problem and also about their health. After all, we do not understand the repercussions of the radiations&#8217;s magnitude on their health, they might get particularly sick!!! Do you reckon I should ask them to come and live together with me?</p>
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