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september is hunger action month September 2, 2013

Posted by Bradley in : food , add a comment

You can help Feeding America or one of the local offshoots such as Feeding South Florida which states:

In South Florida, 949,910 individuals don’t know from where they will get their next meal. More than 296,000 of those individuals are children and over 150,000 are older adults.

critique of uk proposals to regulate lobbying July 23, 2013

Posted by Bradley in : transparency , add a comment

The Alliance for Lobbying Transparency describes the new UK proposals in the “Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Bill 2013-14” as plans to set up a “fake register.” As the Alliance points out, the proposals to regulate lobbying are to apply to “consultant lobbying” which is defined to occur where in the course of a business and in return for payment, the person makes communications “personally to a Minister of the Crown or permanent secretary” on behalf of another person or persons relating to legislation, government policy, contracting, grants, licensing and authorizations and governmental functions. The complexity of this definition and what it covers and doesn’t cover is quite dramatic. I don’t know what making communications “personally” means (written and oral communications are covered). You have to look at Schedule 1 to the Bill to see that consultant lobbying does not include people and firms whose “business .. is mainly a non-lobbying business” (firms of solicitors, for example). Nor does it include people and firms which act “generally as a representative of persons of a particular class or description” where “the income of the person .. derives wholly or mainly from persons of that class or description”, and “the making of communications within section 2(3) on behalf of those persons is no more than an incidental part of that general activity” (trade associations, environmental groups etc.). But the transparency word in the Bill title isn’t really apt here.

From the Government’s perspective it looks as though the really important lobbying-related issue is to do with Trades Unions: there’s a consultation paper about how to create more transparency with respect to trades unions which states:

As membership organisations, it is important that trade union decisions reflect the will of all their members. Knowing who their members are and being able to engage them is intrinsic to a union’s democratic accountability.

What about other membership organizations that take positions on policy? Why not make trade associations disclose who all their members are and how the positions they take on policy issues reflect the interests of their members?

transparencies: spying and trade negotiations July 2, 2013

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Henri Malosse, President of the European Economic and Social Committee said he was “shocked by the level of naiveté on the part of the European institutions” which objected on revelations of US spying. It’s difficult to believe that the objections were down to naivete rather than an act. But Malosse does make some very good points about who is granted seats at the tables where policies are worked out:

I am even more shocked by the fact that concerning trade negotiations, the European Commission applies the policy of blackout on its entire mandate on the draft transatlantic market, for example, by denying access to some meetings to legitimate representatives of trade unions, to civil society, to small and medium-sized enterprises, to the European Economic and Social Committee, the second assembly of the EU, and even the European Parliament itself.
While at the same time, the Commission maintains no secret with regard to certain lobbies – particularly those of large companies, but also apparently … for the “big ears” of our American cousins​​!”

but then felix salmon lost out with a bank too July 1, 2013

Posted by Bradley in : consumers , add a comment

Not just the poor. Felix Salmon describes his experience with costly “free banking” here. Perhaps we should make the CEOs of employers who pay their employees with prepaid cards pay themselves with those same cards? And subject the CEOs of large banks to the sort of consumer-friendly treatment described in Salmon’s article?

the poor lose out: nytimes on wages via prepaid cards July 1, 2013

Posted by Bradley in : consumers , add a comment

Jessica Silver-Greenberg and Stephanie Clifford have a great (but depressing) article in today’s NY Times. Banks and employers are increasingly paying hourly paid employees via prepaid cards which carry a range of fees which the payees have to incur to access their money. Employers are given financial incentives to use these cards. There’s a great quote from Chuck Harris, the president of NetSpend, the largest issuer of these cards:

We built a product that an employer can fairly represent to their employees as having real benefits to them

He doesn’t say that the cards actually have real benefits to employees but that employers can “fairly represent” that they do. Netspend’s mission is:

to provide products and services that empower consumers with the convenience, security and freedom to be self-banked

Of course this isn’t about empowerment at all, but about cynical exploitation of those with few choices and limited voice.

basel committee summer consultations June 28, 2013

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On the revised Basel III leverage ratio framework and disclosure requirements (deadline 20 September); and three consultations with a deadline of 27 September: on the sound management of risks related to money laundering and financing of terrorism; and on derivatives-related reforms to capital adequacy framework: capitalising counterparty credit risk exposures and capital requirements relating to bank exposures to central counterparties.

summer consultations in the uk June 27, 2013

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The Department of Business, Innovation and Skills is consulting (well, issued a “call for views”) on corporate responsibility (responses due by 27 September). Some of the issues raised in the document relate to responsible supply chain management. And the document asks:

Should corporate responsibility be recognised as a profession?

Meanwhile, there is a Call for Evidence on the Integrity and Assurance of Food Supply Networks (responses due by 7 August). Some received a letter inviting evidence with a list of questions, such as:

Do consumers fully understand the way industry describes the composition and quality of the products on sale?..Has the consumer developed unrealistic expectations of the food industry and if so, what role is there for the food industry and government in doing something about it?

Given that “value” products sold in the UK recently turned out to be products made with ingredients (such as horsemeat) different from those listed on the packaging it does seem that consumers didn’t understand the descriptions fully and that their expectations were unrealistic.

And there is a consultation on the draft action plan for open government (comments due 19 September). Here’s a taste:

With regards to our Open Data objectives going forward, our default position is for data to become open where it represents value for money for taxpayers, unless there are robust legal (including Freedom of Information (FoI) Act), security, or financial complexities. We will be enriching this plan with further commitments from the Cabinet Office Transparency Team and from other government departments. Our relentless focus will be on maximising the amount of data released in this way. In the relatively few areas where public open data publication is not possible there can still be benefits to sharing this information under strict conditions, a subject on which the Administrative Data Taskforce has recently reported.

A “relentless focus” on making data “open” where it “represents value for money for taxpayers”? There’s some material in the paper on public participation in policy-making, but it is rather amorphous.

lough erne declaration June 18, 2013

Posted by Bradley in : transparency , add a comment

The G8 made a declaration about tax transparency and trade. In addition to a number of statements about improving the ability of governments to impose and collect taxes, the declaration states:

Private enterprise drives growth, reduces poverty, and creates jobs and prosperity for people around the world. Governments have a special responsibility to make proper rules and promote good governance. Fair taxes, increased transparency and open trade are vital drivers of this….
Governments should roll back protectionism and agree new trade deals that boost jobs and growth worldwide.
Governments should cut wasteful bureaucracy at borders and make it easier and quicker to move goods between developing countries.
Governments should publish information on laws, budgets, spending, national statistics, elections and government contracts in a way that is easy to read and re-use, so that citizens can hold them to account.

This is a very limited version of what transparency might mean, and not nearly all of what citizens should be able to expect in order to hold governments to account.

announcement of eu-us trade negotiations June 17, 2013

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Happened today. The Council of the EU approved the beginning of negotiations on Friday. Regulatory convergence is an important aspect of the proposed FTA, and, although SIFMA worried recently that financial services regulation wouldn’t be part of the negotiations, that doesn’t seem so clear. The EU Commission says it’s not just about regulation of goods:

The need for regulatory convergence is not limited to trade in goods. With regards to financial services, for instance, negotiations should consider creating common frameworks for prudential cooperation. Stakeholders on both sides have provided guidance on where the most significant barriers lie.

I have been examining the consultations that produced “stakeholder” comments. Unsurprisingly the “stakeholders” most concerned to comment in the lead-up to the decision to begin negotiations were businesses and trade associations. And the official narrative is relentlessly positive about the advantages of these negotiations and ignores the discomfort of a range of groups concerned with issues of privacy, extravagant IP protections, the lives of workers, and the environment.

english only financial regulation June 14, 2013

Posted by Bradley in : multilingualism , add a comment

Yesterday the EU Ombudsman’s website published a Decision of the European Ombudsman closing his inquiry into complaint 1363/2012/BEH against the European Banking Authority. A German citizen:

submitted a petition to the Committee on Petitions of the European Parliament (henceforth the ‘Committee on Petitions’) concerning the use of official languages on the website of the European Banking Authority (‘EBA’). Specifically, he pointed out that, contrary to Article 73(1) of Regulation 1093/2010[1] in conjunction with Article 4 of Regulation 1/58[2], the EBA’s website provides information exclusively in the English language. The complainant considered this practice also to amount to an instance of language discrimination. He stated that this was particularly serious, considering that the EBA’s activities affect the entire EU, including European bank customers, who should be able to grasp EBA guidelines without facing any language barriers. The complainant asked the Committee on Petitions to prevail upon the EBA to comply with Article 73(1) of Regulation 1093/2010. Referring to Parliament’s role as legislator, he also suggested that the Committee include in its assessment the other “European supervisory authorities” likely to give rise to the same concerns.

The Ombudsman found no maladministration although the Decision states:

As far as the external communication of EU institutions, bodies, offices and agencies with citizens is concerned, it has been the Ombudsman’s longstanding position that it would be ideal for the material intended for such purposes to be published in all official languages. This position is based on the rationale that, in order for such communication to be effective, it is necessary that citizens can understand the information provided to them…. transparency and accessibility have a very important role to play in building citizen trust in EU institutions, while also constituting essential parts of the citizens’ right to participate in the democratic life of the Union. It follows from the above that it is of paramount importance for citizens to be able to access information concerning the EBA’s work in a language they can understand.

However, the Ombudsman noted that the EBA had not been in existence for very long, that it had limited resources, and that it was making progress in translating documents. Nevertheless, the EBA’s Annual Report for 2012 is today published only in English. The announcement of the publication of the Annual Report states:

A separate publication summarising the key features of the 2012 Annual Report is also published and it will soon be available in all EU languages.

This doesn’t look like a real commitment to multilingualism: a multilingual summary of the real document will be provided to those who don’t read English – and are therefore not included in a real sense in debates about EU financial regulation.