By Mark Brousseau
Many people believe that the future of electronic payment processing includes a growing trend toward including accounts receivable, check and deposit capture at the point of presentment. So what are the benefits of this strategy? And what about its challenges?
“The strategy of moving image capture to the point of presentment provides numerous advantages,” Wally Vogel (wally_vogel@creditron.com), president of Creditron, Inc., told me. “Obviously, there is the reduction of payment document handling and forwarding, and the associated lag time. This improves cash control and offers faster funds availability.”
“Beyond that, image capture at the point of presentment allows for greater control and audit capabilities,” Vogel added. “As soon as the document is scanned, it is captured and logged, and can be tracked through various processes for depositing, accounts receivable updates, and handling change of address requests and customer service inquiries, among other functions.”
With the proper systems in place, Vogel added, document images can be viewed from any authorized inquiry station on the network for customer purposes, within minutes of receiving the document. This means that data completion from image can be completed in a remote office or in a centralized location, providing greater flexibility while maintaining strict control and a complete audit trail for each transaction, wherever it is processed.
“One of the significant challenges of image capture at the point of presentment is the need to standardize rules, processes and practices across remote offices. Otherwise, users may not get the full advantage of remote capture,” Vogel said. “This may require a thorough business analysis and a willingness to unify business processes.”
What do you think? E-mail me at m_brousseau@msn.com.
Monday, March 31, 2008
Saturday, March 29, 2008
Barron's High On Fiserv
Posted by Mark Brousseau
An interesting article on Fiserv in Barron's:
Fiserv Is Largely Immune To Banking's Plagues
By JACK WILLOUGHBY
THERE ARE SOME BANK-RELATED companies whose earnings are likely to rise this year.
One of them is Fiserv, a Brookfield, Wis.-based supplier of systems and services that provide banks with the wherewithal to post checks, open new checking and savings accounts, and keep track of loans. Because banks are its main clients, Fiserv (ticker: FISV) has seen its shares dragged down by about 20% since the summer of 2007, to 48.17 last week. But as a founder and former CEO George Dalton says, "No matter how troubled the bank may be, its customers still have to write checks, make payments and pay mortgages."
Under 48-year-old CEO Jeff Yabuki, the company -- which has absorbed more than 100 enterprises over the years -- has sold off a mortgage-credit-reporting business, most of its health-management businesses and a majority of its investment-services group to pay down debt and refocus on its financial-services core.
It's also taken steps to solidify its already-substantial hold on that marketplace: Last year, Yabuki, the former chief operating officer for H&R Block, purchased electronic bill-payment leader CheckFree for $4.4 billion. The acquisition not only gets Fiserv into a fast-growing market, but allows it to sell its own wares to the big banks and corporations that CheckFree serves.
The company, says Yabuki, is "becoming a pure play in the provision of technology-processing to financial institutions." Fiserv last year got 75% of its $3.9 billion in revenue from these core services.
That also lets Fiserv participate in any forthcoming banking recovery without the same risks posed by a bank's credit portfolio.
FISERV'S SAGGING STOCK PRICE offers "an appealing entry point to an industry-leading financial-services processor poised to boost organic growth and margins," according to a report from John Kraft, an analyst at D.A. Davidson who has a Buy rating on the stock. He has a 65 price target on the shares, more than 30% above their recent value.
Fiserv stock now trades at about 14 times expected 2008 earnings of $3.42 a share, about in line with competitors such as Fidelity National Information Services, Metavante Holdings and Jack Henry & Associates. But that multiple doesn't reflect expectations that Fiserv's earnings will rise by almost 19% in 2009 due in part to economies achieved in the CheckFree purchase. The market is valuing the shares at about 12 times '09 earnings of $4.06 apiece -- below Metavante's 13.4 and Jack Henry's 16.6 but very near Fidelity's 11.9.
That's a pretty cheap multiple for a company that holds a commanding 34% share of the core processing business -- taking deposits and making loans -- that banks and credit unions do. Fiserv's customers, who renew its services at a healthy 90%-plus rate, usually sign three-to five-year contracts and pay a fee based either on the assets under management or the volume of transactions.
Although the number of banks almost halved from the early 1990s to about 8,700 by 2006, banking assets doubled to $12 trillion in that time. That provides plenty of opportunities for Fiserv. The drastic consolidation in the industry -- with all those legacy network systems to sort through -- also increases the need for technology solutions like those Fiserv provides.
Small banks or credit unions with limited technology groups outsource almost all of their transaction-processing chores to Fiserv, while others use a narrower selection of its systems.
The very biggest banks usually have their own systems -- however, Fiserv has begun to make inroads with them as well, and estimates that 88 of the largest 100 banks already use more than one Fiserv product. The CheckFree acquisition should help Fiserv improve its penetration still further.
The deal also offers both organizations a chance to diversify. Bank of America, for instance, previously accounted for nearly one-fifth of CheckFree's revenue, a portion that would be about 5% of the combined company's sales. And Fiserv can market its own suite of offerings to these bigger customers as well as CheckFree's electronic bill-payment and Internet services to its own customers.
CHECKFREE SHOULD CONTRIBUTE NOT only to Fiserv's revenue growth this year and next but also to margins, as Yabuki squeezes out costs. Kraft of Davidson estimates that operating margins should increase to 20% in '09, from 18%.
The Bottom Line:
Fiserv shares look cheap. Baring a long recession or major acquisition problems, they could rise by 30% or more in the next year.
Yabuki says the CheckFree merger is proceeding smoothly -- reflecting, in part, the fact that Fiserv, the product of the combination of a subsidiary of Midland Bank of Milwaukee and an affiliate of Freedom Savings and Loan many years ago, has done scores of these deals.
Yes, Fiserv is vulnerable if a sustained recession forces banks to curtail tech spending drastically, or if some of the expected synergies with CheckFree don't materialize.
But Yabuki argues that analysts and investors are unfairly painting Fiserv "with the same brush that's used on the banking system. Their basic idea," the CEO says, "is that the banks, our clients, would stop spending on technology in a slowdown. But they forget that the kind of processes we offer are really nondiscretionary."
Fiserv, which has bought back more than 36 million of its shares over the last three years, does have Wall Street fans. "This is a stock that could easily benefit from both earnings and multiple expansion, even in a slow economy," says Clark Shields, business-services analyst for T. Rowe Price, a buyer of the stock. He thinks the shares could rise more than 15, to north of 65, in the next 12 months. That kind of near-term gain isn't in the cards for most banks.
An interesting article on Fiserv in Barron's:
Fiserv Is Largely Immune To Banking's Plagues
By JACK WILLOUGHBY
THERE ARE SOME BANK-RELATED companies whose earnings are likely to rise this year.
One of them is Fiserv, a Brookfield, Wis.-based supplier of systems and services that provide banks with the wherewithal to post checks, open new checking and savings accounts, and keep track of loans. Because banks are its main clients, Fiserv (ticker: FISV) has seen its shares dragged down by about 20% since the summer of 2007, to 48.17 last week. But as a founder and former CEO George Dalton says, "No matter how troubled the bank may be, its customers still have to write checks, make payments and pay mortgages."
Under 48-year-old CEO Jeff Yabuki, the company -- which has absorbed more than 100 enterprises over the years -- has sold off a mortgage-credit-reporting business, most of its health-management businesses and a majority of its investment-services group to pay down debt and refocus on its financial-services core.
It's also taken steps to solidify its already-substantial hold on that marketplace: Last year, Yabuki, the former chief operating officer for H&R Block, purchased electronic bill-payment leader CheckFree for $4.4 billion. The acquisition not only gets Fiserv into a fast-growing market, but allows it to sell its own wares to the big banks and corporations that CheckFree serves.
The company, says Yabuki, is "becoming a pure play in the provision of technology-processing to financial institutions." Fiserv last year got 75% of its $3.9 billion in revenue from these core services.
That also lets Fiserv participate in any forthcoming banking recovery without the same risks posed by a bank's credit portfolio.
FISERV'S SAGGING STOCK PRICE offers "an appealing entry point to an industry-leading financial-services processor poised to boost organic growth and margins," according to a report from John Kraft, an analyst at D.A. Davidson who has a Buy rating on the stock. He has a 65 price target on the shares, more than 30% above their recent value.
Fiserv stock now trades at about 14 times expected 2008 earnings of $3.42 a share, about in line with competitors such as Fidelity National Information Services, Metavante Holdings and Jack Henry & Associates. But that multiple doesn't reflect expectations that Fiserv's earnings will rise by almost 19% in 2009 due in part to economies achieved in the CheckFree purchase. The market is valuing the shares at about 12 times '09 earnings of $4.06 apiece -- below Metavante's 13.4 and Jack Henry's 16.6 but very near Fidelity's 11.9.
That's a pretty cheap multiple for a company that holds a commanding 34% share of the core processing business -- taking deposits and making loans -- that banks and credit unions do. Fiserv's customers, who renew its services at a healthy 90%-plus rate, usually sign three-to five-year contracts and pay a fee based either on the assets under management or the volume of transactions.
Although the number of banks almost halved from the early 1990s to about 8,700 by 2006, banking assets doubled to $12 trillion in that time. That provides plenty of opportunities for Fiserv. The drastic consolidation in the industry -- with all those legacy network systems to sort through -- also increases the need for technology solutions like those Fiserv provides.
Small banks or credit unions with limited technology groups outsource almost all of their transaction-processing chores to Fiserv, while others use a narrower selection of its systems.
The very biggest banks usually have their own systems -- however, Fiserv has begun to make inroads with them as well, and estimates that 88 of the largest 100 banks already use more than one Fiserv product. The CheckFree acquisition should help Fiserv improve its penetration still further.
The deal also offers both organizations a chance to diversify. Bank of America, for instance, previously accounted for nearly one-fifth of CheckFree's revenue, a portion that would be about 5% of the combined company's sales. And Fiserv can market its own suite of offerings to these bigger customers as well as CheckFree's electronic bill-payment and Internet services to its own customers.
CHECKFREE SHOULD CONTRIBUTE NOT only to Fiserv's revenue growth this year and next but also to margins, as Yabuki squeezes out costs. Kraft of Davidson estimates that operating margins should increase to 20% in '09, from 18%.
The Bottom Line:
Fiserv shares look cheap. Baring a long recession or major acquisition problems, they could rise by 30% or more in the next year.
Yabuki says the CheckFree merger is proceeding smoothly -- reflecting, in part, the fact that Fiserv, the product of the combination of a subsidiary of Midland Bank of Milwaukee and an affiliate of Freedom Savings and Loan many years ago, has done scores of these deals.
Yes, Fiserv is vulnerable if a sustained recession forces banks to curtail tech spending drastically, or if some of the expected synergies with CheckFree don't materialize.
But Yabuki argues that analysts and investors are unfairly painting Fiserv "with the same brush that's used on the banking system. Their basic idea," the CEO says, "is that the banks, our clients, would stop spending on technology in a slowdown. But they forget that the kind of processes we offer are really nondiscretionary."
Fiserv, which has bought back more than 36 million of its shares over the last three years, does have Wall Street fans. "This is a stock that could easily benefit from both earnings and multiple expansion, even in a slow economy," says Clark Shields, business-services analyst for T. Rowe Price, a buyer of the stock. He thinks the shares could rise more than 15, to north of 65, in the next 12 months. That kind of near-term gain isn't in the cards for most banks.
Plan Would Empower Fed
Posted by Mark Brousseau
An interesting article in yesterday's New York Times:
Treasury Dept. Plan Would Give Fed Wide New Power
By EDMUND L. ANDREWS
WASHINGTON — The Treasury Department will propose on Monday that Congress give the Federal Reserve broad new authority to oversee financial market stability, in effect allowing it to send SWAT teams into any corner of the industry or any institution that might pose a risk to the overall system.
The proposal is part of a sweeping blueprint to overhaul the nation’s hodgepodge of financial regulatory agencies, which many experts say failed to recognize rampant excesses in mortgage lending until after they set off what is now the worst financial calamity in decades.
Democratic lawmakers are all but certain to say the proposal does not go far enough in restricting the kinds of practices that caused the financial crisis. Many of the proposals, like those that would consolidate regulatory agencies, have nothing to do with the turmoil in financial markets. And some of the proposals could actually reduce regulation.
According to a summary provided by the administration, the plan would consolidate an alphabet soup of banking and securities regulators into a powerful trio of overseers responsible for everything from banks and brokerage firms to hedge funds and private equity firms.
While the plan could expose Wall Street investment banks and hedge funds to greater scrutiny, it carefully avoids a call for tighter regulation.
The plan would not rein in practices that have been linked to the housing and mortgage crisis, like packaging risky subprime mortgages into securities carrying the highest ratings.
The plan would give the Fed some authority over Wall Street firms, but only when an investment bank’s practices threatened the entire financial system.
And the plan does not recommend tighter rules over the vast and largely unregulated markets for risk sharing and hedging, like credit default swaps, which are supposed to insure lenders against loss but became a speculative instrument themselves and gave many institutions a false sense of security.
Parts of the plan could reduce the power of the Securities and Exchange Commission, which is charged with maintaining orderly stock and bond markets and protecting investors. The plan would merge the S.E.C. with the Commodity Futures Trading Commission, which regulates exchange-traded futures for oil, grains, currencies and the like.
The blueprint also suggests several areas where the S.E.C. should take a lighter approach to its oversight. Among them are allowing stock exchanges greater leeway to regulate themselves and streamlining the approval of new products, even allowing automatic approval of securities products that are being traded in foreign markets.
The proposal began last year as an effort by Henry M. Paulson Jr., secretary of the Treasury, to make American financial markets more competitive against overseas markets by modernizing a creaky regulatory system.
His goal was to streamline the different and sometimes clashing rules for commercial banks, savings and loans and nonbank mortgage lenders.
“I am not suggesting that more regulation is the answer, or even that more effective regulation can prevent the periods of financial market stress that seem to occur every 5 to 10 years,” Mr. Paulson will say in a speech on Monday, according to a draft. “I am suggesting that we should and can have a structure that is designed for the world we live in, one that is more flexible.”
Congress would have to approve almost every element of the proposal, and Democratic leaders are already drafting their own bills to impose tougher supervision over Wall Street investment banks, hedge funds and the fast-growing market in derivatives like credit default swaps.
But Mr. Paulson’s proposal for the Fed echoes ideas championed by Representative Barney Frank, the Massachusetts Democrat who is chairman of the House Financial Services Committee.
Both see the Fed overseeing risk across the entire financial spectrum, but Mr. Frank is likely to favor a stronger Fed role and to subject investment banks to the same rules that commercial banks now must follow, especially for capital reserves.
The Treasury plan would let Fed officials examine the practices and even the internal bookkeeping of brokerage firms, hedge funds, commodity-trading exchanges and any other institution that might pose a risk to the overall financial system.
That would be a significant expansion of the central bank’s regulatory mission.
When Fed officials agreed this month to rescue Bear Stearns, once the nation’s fifth-largest investment bank, they pointedly noted that the Fed never had the authority to monitor its financial condition or order it to bolster its protections against a collapse.
In two unprecedented moves, the Fed engineered a marriage between JPMorgan Chase and Bear Stearns, lending $29 billion to JPMorgan to prevent a Bear bankruptcy and a chain of defaults that might have felled much of the financial system.
For the first time since the 1930s, the Fed also agreed to let investment banks borrow hundreds of billions of dollars from its discount window, an emergency lending program reserved for commercial banks and other depository institutions.
But Mr. Paulson’s proposal would fall well short of the kind of regulation that Democrats have been proposing. Mr. Frank and other senior Democrats have argued that investment banks and other lightly regulated institutions now compete with commercial banks and should be subject to similar regulation, including examiners who regularly pore over their books and quietly demand changes in their practices.
In a recent interview, Mr. Frank said he realized the need for tighter regulation of Wall Street firms after a meeting with Charles O. Prince III, then chairman of Citigroup.
When Mr. Frank asked why Citigroup had kept billions of dollars in “structured investment vehicles” off the firm’s balance sheet, he recalled, Mr. Prince responded that Citigroup, as a bank holding company, would have been at a disadvantage because investment firms can operate with higher debt and lower capital reserves.
Senator Charles E. Schumer, Democrat of New York, has taken a similar stance.
“Commercial banks continue to be supervised closely, and are subject to a host of rules meant to limit systemic risk,” Mr. Schumer wrote in an op-ed article on Friday in The Wall Street Journal. “But many other financial institutions, including investment banks and hedge funds, are regulated lightly, if at all, even though they act in many ways like banks.”
Mr. Paulson’s proposal is likely to provoke bruising turf battles in Congress among agencies and rival industry groups that benefit from the current regulations.
Administration officials acknowledged on Friday that they did not expect the proposal to become law this year, but said they hoped it would help frame a policy debate that would extend well after the elections in November.
In a nod to the debacle in mortgage lending, the administration proposed a Mortgage Origination Commission to evaluate the effectiveness of state governments in regulating mortgage brokers and protecting consumers.
The bulk of the proposal, however, was developed before soaring mortgage defaults set off a much broader credit crisis, and most of the proposals are geared to streamlining regulation.
This plan would consolidate a large number of regulators into roughly three big new agencies.
Bank supervision, now divided among five federal agencies, would be led by a Prudential Financial Regulator, which could send examiners into any bank or depository institution that is protected by either federal deposit insurance or other federal backstops. It would eliminate the distinction between “banks” and “thrift institutions,” which are already indistinguishable to most consumers, and shut down the Office of Thrift Supervision.
Any effort to merge the Commodity Futures Trading Commission with the S.E.C. is likely to provoke battles.
Yet another proposal would, for the first time, create a national regulator for insurance companies, an industry that state governments now oversee.
Administration officials argue that a national system would eliminate the inefficiencies of having 50 different state regulators, who have jealously guarded their powers and are likely to fight any federal encroachment.
Arthur Levitt, a former S.E.C. chairman who has long pushed for stronger investor protection, said his first impression of the plan was positive. Even though the S.E.C.’s powers might be reduced, Mr. Levitt said, the plan would create a broader agency to regulate business conduct in all financial services.
“It’s a thoughtful document,” he said. “I’m intrigued by the fact that it puts an emphasis on investor protection, and that it establishes an agency specifically for that purpose, which would operate across all markets. I think that’s a very constructive first step.”
An interesting article in yesterday's New York Times:
Treasury Dept. Plan Would Give Fed Wide New Power
By EDMUND L. ANDREWS
WASHINGTON — The Treasury Department will propose on Monday that Congress give the Federal Reserve broad new authority to oversee financial market stability, in effect allowing it to send SWAT teams into any corner of the industry or any institution that might pose a risk to the overall system.
The proposal is part of a sweeping blueprint to overhaul the nation’s hodgepodge of financial regulatory agencies, which many experts say failed to recognize rampant excesses in mortgage lending until after they set off what is now the worst financial calamity in decades.
Democratic lawmakers are all but certain to say the proposal does not go far enough in restricting the kinds of practices that caused the financial crisis. Many of the proposals, like those that would consolidate regulatory agencies, have nothing to do with the turmoil in financial markets. And some of the proposals could actually reduce regulation.
According to a summary provided by the administration, the plan would consolidate an alphabet soup of banking and securities regulators into a powerful trio of overseers responsible for everything from banks and brokerage firms to hedge funds and private equity firms.
While the plan could expose Wall Street investment banks and hedge funds to greater scrutiny, it carefully avoids a call for tighter regulation.
The plan would not rein in practices that have been linked to the housing and mortgage crisis, like packaging risky subprime mortgages into securities carrying the highest ratings.
The plan would give the Fed some authority over Wall Street firms, but only when an investment bank’s practices threatened the entire financial system.
And the plan does not recommend tighter rules over the vast and largely unregulated markets for risk sharing and hedging, like credit default swaps, which are supposed to insure lenders against loss but became a speculative instrument themselves and gave many institutions a false sense of security.
Parts of the plan could reduce the power of the Securities and Exchange Commission, which is charged with maintaining orderly stock and bond markets and protecting investors. The plan would merge the S.E.C. with the Commodity Futures Trading Commission, which regulates exchange-traded futures for oil, grains, currencies and the like.
The blueprint also suggests several areas where the S.E.C. should take a lighter approach to its oversight. Among them are allowing stock exchanges greater leeway to regulate themselves and streamlining the approval of new products, even allowing automatic approval of securities products that are being traded in foreign markets.
The proposal began last year as an effort by Henry M. Paulson Jr., secretary of the Treasury, to make American financial markets more competitive against overseas markets by modernizing a creaky regulatory system.
His goal was to streamline the different and sometimes clashing rules for commercial banks, savings and loans and nonbank mortgage lenders.
“I am not suggesting that more regulation is the answer, or even that more effective regulation can prevent the periods of financial market stress that seem to occur every 5 to 10 years,” Mr. Paulson will say in a speech on Monday, according to a draft. “I am suggesting that we should and can have a structure that is designed for the world we live in, one that is more flexible.”
Congress would have to approve almost every element of the proposal, and Democratic leaders are already drafting their own bills to impose tougher supervision over Wall Street investment banks, hedge funds and the fast-growing market in derivatives like credit default swaps.
But Mr. Paulson’s proposal for the Fed echoes ideas championed by Representative Barney Frank, the Massachusetts Democrat who is chairman of the House Financial Services Committee.
Both see the Fed overseeing risk across the entire financial spectrum, but Mr. Frank is likely to favor a stronger Fed role and to subject investment banks to the same rules that commercial banks now must follow, especially for capital reserves.
The Treasury plan would let Fed officials examine the practices and even the internal bookkeeping of brokerage firms, hedge funds, commodity-trading exchanges and any other institution that might pose a risk to the overall financial system.
That would be a significant expansion of the central bank’s regulatory mission.
When Fed officials agreed this month to rescue Bear Stearns, once the nation’s fifth-largest investment bank, they pointedly noted that the Fed never had the authority to monitor its financial condition or order it to bolster its protections against a collapse.
In two unprecedented moves, the Fed engineered a marriage between JPMorgan Chase and Bear Stearns, lending $29 billion to JPMorgan to prevent a Bear bankruptcy and a chain of defaults that might have felled much of the financial system.
For the first time since the 1930s, the Fed also agreed to let investment banks borrow hundreds of billions of dollars from its discount window, an emergency lending program reserved for commercial banks and other depository institutions.
But Mr. Paulson’s proposal would fall well short of the kind of regulation that Democrats have been proposing. Mr. Frank and other senior Democrats have argued that investment banks and other lightly regulated institutions now compete with commercial banks and should be subject to similar regulation, including examiners who regularly pore over their books and quietly demand changes in their practices.
In a recent interview, Mr. Frank said he realized the need for tighter regulation of Wall Street firms after a meeting with Charles O. Prince III, then chairman of Citigroup.
When Mr. Frank asked why Citigroup had kept billions of dollars in “structured investment vehicles” off the firm’s balance sheet, he recalled, Mr. Prince responded that Citigroup, as a bank holding company, would have been at a disadvantage because investment firms can operate with higher debt and lower capital reserves.
Senator Charles E. Schumer, Democrat of New York, has taken a similar stance.
“Commercial banks continue to be supervised closely, and are subject to a host of rules meant to limit systemic risk,” Mr. Schumer wrote in an op-ed article on Friday in The Wall Street Journal. “But many other financial institutions, including investment banks and hedge funds, are regulated lightly, if at all, even though they act in many ways like banks.”
Mr. Paulson’s proposal is likely to provoke bruising turf battles in Congress among agencies and rival industry groups that benefit from the current regulations.
Administration officials acknowledged on Friday that they did not expect the proposal to become law this year, but said they hoped it would help frame a policy debate that would extend well after the elections in November.
In a nod to the debacle in mortgage lending, the administration proposed a Mortgage Origination Commission to evaluate the effectiveness of state governments in regulating mortgage brokers and protecting consumers.
The bulk of the proposal, however, was developed before soaring mortgage defaults set off a much broader credit crisis, and most of the proposals are geared to streamlining regulation.
This plan would consolidate a large number of regulators into roughly three big new agencies.
Bank supervision, now divided among five federal agencies, would be led by a Prudential Financial Regulator, which could send examiners into any bank or depository institution that is protected by either federal deposit insurance or other federal backstops. It would eliminate the distinction between “banks” and “thrift institutions,” which are already indistinguishable to most consumers, and shut down the Office of Thrift Supervision.
Any effort to merge the Commodity Futures Trading Commission with the S.E.C. is likely to provoke battles.
Yet another proposal would, for the first time, create a national regulator for insurance companies, an industry that state governments now oversee.
Administration officials argue that a national system would eliminate the inefficiencies of having 50 different state regulators, who have jealously guarded their powers and are likely to fight any federal encroachment.
Arthur Levitt, a former S.E.C. chairman who has long pushed for stronger investor protection, said his first impression of the plan was positive. Even though the S.E.C.’s powers might be reduced, Mr. Levitt said, the plan would create a broader agency to regulate business conduct in all financial services.
“It’s a thoughtful document,” he said. “I’m intrigued by the fact that it puts an emphasis on investor protection, and that it establishes an agency specifically for that purpose, which would operate across all markets. I think that’s a very constructive first step.”
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