it is involved in rulemaking. it stays involved in rulemaking. one of the routes you can use ads in bashing as an advocate try to influence an agency is back to the very congress that wrote the legislation in the first place. the second is the president. the president is an enormously important player in this because he establishes the regulatory program and the regulatory agenda for his administration. if he decides environmental quality is a big deal, it becomes a big deal. if he decides the rules are going to be written on a strict, cost benefit standard, nothing gets written in less you can see net benefit, and nothing will come out of an agency with that characteristic. if on the other hand he decides we're going to produce an enormous body of rules that make up for a decade of laxative rules in protecting the about, protecting workers, protecting the financial security of the american people, then you're going to be seeing signals throughout the government that reignited the rulemaking process. by the way look at a table data. it hasn't hap

as the enabler of rulemaking, as the limiting agent of rulemaking. i know that doesn't sound right, doesn't feel right, because we've all grown up thinking about congress and the legislative process. and that's the way we should think about it. but in effect what congress is doing is setting the stage for dozens if not hundreds, months if not years, if not decades of rulemaking that is going to follow. the other thing, i probably didn't spend enough time on, remember, congress in addition to not being technically knowledgeable, they are not pressure. they are no better than we are anticipating how the world will change a couple years after its statute is in this enacted. to react to these changes, the unanticipated changes in ways that you couldn't do if you had to rewrite the legislation every time an actual condition changed. so what are your opportunities when you are sitting in front of a statute that you think you have the opportunity to alter in a way that positions you well and your interest well? one is make this an incomplete language can be

as the enabler of rulemaking, as the limiting agent of rulemaking. i know that doesn't sound right, doesn't feel right, because we've all grown up thinking about congress and the legislative process. and that's the way we should think about it. but in effect what congress is doing is setting the stage for dozens if not hundreds, months if not years, if not decades of rulemaking that is going to follow. the other thing, i probably didn't spend enough time on, remember, congress in addition to not being technically knowledgeable, they are not pressure. they are no better than we are anticipating how the world will change a couple years after its statute is in this enacted. to react to these changes, the unanticipated changes in ways that you couldn't do if you had to rewrite the legislation every time an actual condition changed. so what are your opportunities when you are sitting in front of a statute that you think you have the opportunity to alter in a way that positions you well and your interest well? one is make this an incomplete language can be

second, we'll consider a notice of proposed rulemaking seeking comment on steps to promote innovation and efficiency in spectrum use under part 5, experimental radio service. for your third item, you will consider a notice of inquiry seeking comment on promoting more intensive and efficient use of the radio spectrum thereby potentially enabling more effective spectrum management through dynamic spectrum use technologies. last on your agenda, the consumer and governmental affairs bureau will present an overview of the 21st century communications and video accessibility act. and the commissions implementation plans and demonstrate accessibility technologies. this is your agenda for today. all three items will be presented by the office of engineering and technology, julius knaap chief of the office will give the introduction. >> thank you, mr. knaap? >> thank you. >> three important items. please go ahead. >> good morning, mr. chairman and commissioners. we'll be presenting three items for your consideration today. each of which serve to advance the commission's spectrum goals and as a

so on the hill -- you know, if you're on the fact that rulemaking will happen, that rulemaking is an arena in which you have to play, if you're going to be successful, the statute itself is the first place to start. then the attention shifts to the agency. and this is why -- this is why i think -- this is where the rulemaking process and the legislative process diverge in terms of the way they're conducted. in my view, the key to a successful participation in rulemaking is the highest quality information you can put together at a critical point in the process. and what is the critical point in the process? first and foremost, look, the empirical work on rulemaking is still very, very primitive. now, this is not a field where the social -- where the social sciences, particularly the policy sciences, have spent the time and effort that's needed to give us confidence in a scholarly sense about who influences rules and how but there's one thing that's out there, the earlier you're in, the earlier you are able to influence the process, the more successful you're going to be. you can't get

this is certainly true with respect to this particular rulemaking. it is important for us to act expeditiously to meet the requirements of the law and establish regulatory clarity as soon as possible the proposal to date is one that deserves careful attention in light of debit cards increasingly important role in the u.s. patent system. we gather great deal of information bearing on this rulemaking and look forward to receiving the public's comments. let me turn to the vice chair who yields boat committee on clearing and settlement which reviews the proposal. >> as you noted, and staff will consider staff's proposal for implementing the credit card interchange fee and transaction routing provision of the dodd frank act. it is important to note its prominent role in our payments system. the result of a new federal reserve survey published earlier this month showed that nearly forty-eight billion debit card payments were made in the united states in 2009. debit cards are used in 35% of noncash transactions. this eclipse checks as the most frequently us

first he will consider a notice of proposed rulemaking seeking comment on rules to facilitate the most efficient use of the uhc tvd and. these proposals and important steps toward the agency spectrum goals as outlined in the national broadband plan would take steps to enable mobile broadband use currently reserved for use by tv broadcasters including through innovations such as channel sharing and generating increased value. second you will consider a notice of proposed rulemaking seeking comment on steps to promote innovation and efficiency in spectrum he was under part five experimental radio service. for your freedom he will consider a notice of inquiry seeking comment on promoting more intensive and efficient use of the radio spectrum, thereby potentially enabling more management through dynamic spectrum technology. last on your agenda, the consumer and government affairs bureau will present an overview of the 21st century communications and the deal accessibility act, and the commission's implementation plan and demonstrate accessibility technology. this is your agenda for today.

chairman and commissioners. >> the notice of proposed rulemaking before you would initiate a processto further the commission's ongoing commitment to addressing america's growing demand for wireless broadband services, to spur innovation and investment in wireless broadband systems, and ensure that america leads the global wireless revolution. the notice would take preliminary steps towards making additional spectrum available for wireless broadband a portion of the spectrum that is currently used for broadcast television. at the same time, the notice recognizes the important benefits served by broadcast television and takes an approach the would help preserve that service has a healthy viable media. the notice proposes three actions intended to set the underlining a regulatory framework to accommodate wireless broadband uses of the tv dance. the proposals of the notice of adopted will also provide new options for broadcasters. first, the notice proposes to add new allocations or fixed and land global services and the tv dance to become primary with the existing broadcast application

>> guest: well, what you're going to see happen is this: if the fcc does move forward in this rulemaking authority on december 21st, then come january you're going to see some aggressive work on making certain that the fcc keeps its hands off the internet. i have had, i will refile my legislation, h.r. 3924, which is a bill that i've had to prohibit the fcc from enacting net neutrality regulations. and this is a debate that should be held in congress. it should not be held at the fcc. and we are going to see this come back, i think, even as we look at hearings and we look at the way the fcc is trying to approach this, we're going to see the industry come to congress and say, wait a minute. what the fcc is doing by putting this stranglehold is prohibiting all of our innovators from bringing those next generation technologies on to the internet and being able to do so with some predictability. when you look at our innovative and our creative community and you look at some of what are now core services on the internet, things like voip, video conferencing, the use of skype, telemedicine in

such rulemaking will not return investor confidence in our markets.hope to have the opportunity to elaborate on these topics that today's hearing and i ask my remarks be included in the record. >> they will be. thank you very much, nanoj narang. mr. cronin? >> thank you. ranking members and members of the subcommittee for the opportunity to speak here today. i am pleased to participate examinee efficiency, stability and integrity of the u.s. capital market. invesco is a leading management firm with operations in 20 countries and assets under management of $620 billion. i will keep my comments brief but ask for a more detailed statement. an efficient and the fashion capital process is essential to growth and vitality of the u.s. economy. the most important aspect of the process is that it attracts long-term investors capital. it is important to the primary and secondary capital markets to facilitate capital process transparent, effective and fair. to that end is essential that sensible consistent rules and regulations replace to govern the markets and

>> yeah, we have had adequate access to the committee rulemaking process. and actually is a coalition, we submitted preliminary comments to the cftc on november 1. some with regard to its rulemaking were actually kind of thrown around a battle bit of discussion. some of those points made was very well taken about the importance for energy and agricultural groups that are concerned about index speculation. and i think that -- i hope tomorrow the proposed rulemaking will attempt to address the situation and maybe like commissioner chilton said to some of segregate the market and address them as appropriate. and if not, will be certain to -- >> what type of form speculation? >> i'm sorry. >> he said various forms speculation. help me understand what a form of speculation this? >> i'm thinking of traditional speculation such as hedge funds. >> so it's not the foremost speculating. >> right, versus index funds which have investment strategy when it comes to commodity investment. >> use a phrase that was interesting. he said basically the speculation as a pejorat

they are the thanks she is able to do individually as opposed to the rulemaking. and i think the rulemaking would go smoother and quite honestly, i think it would have been more balanced had it not been five commissioners. so i would -- i would just say that you have a chance to debate the pros and cons of every single bill. you have people that -- on both sides of the aisle that have different opinions and people that come from different perspectives. once you write the bill, i'm not sure it's so helpful to have four more commissioners that are debating these same things for hours and hours and hours, hiring their own staffs, taking up a lot of office space, keeping the office of general counsel and the professional staff busy answering all of our questions when maybe the administrator should be charged with that responsibility. >> how large is your staff? >> i have three people, one that's paid $150,000 a year. one that's paid $100,000 a year. and one that's paid $50,000 a year. >> well, i followed the chair's example and overstayed my time. let me just say this

again, i would point to what the commission has put forward in terms of its rulemaking. it is mostly about what could potentially be used to add greater teeth to those know your customer requirements. it is just a holding entities for the real customer, we try to look through to have the customer of the customer be treated as a customer of the broker-dealer. i think there is more interpretive rule making and enforcement the needs to be done. >> he made reference to certain unfair aspects that exist in some participants. can you expand on what those unfair aspects of our? >> i will do my best. basically, in the united states equity markets, the vast majority of exchanges observe what is known as price time orders, that is orders that arrive at the exchange at a particular price get first priority to execute against inbound orders based on their arrival time. if your order arrives before mine and somebody wants to trade at that price and actively, they will give you a sell before they give me a cell. because of some technicalities associated with the order protection role

if the fcc does move forward in this rulemaking authority on the december 21st, then come january, you are going to see some aggressive worke on making certain that the fcc keeps its hands off the internet. legislation h.r.-2934 is a bill i had to prohibit fcc interference with net neutrality negotiations. this is something that should happen in congress, not at the fcc. we are going to see the fcc come back, i think, even as we look at hearings and we look at the way the fcc is trying to approach this, we are going to see that what the fcc is doing by putting this stranglehold is putting all of our innovators from banging does next generation technologies to the internet -- from bringing those next generation technologies to dthe internet. look at what are now court services on the internet -- core services on the internet. voip, skype, tele-medical, and the next generations of those services. we want to make sure users can move onto the internet with predictability, with a certain amount of certainty, and innovators are going to get caught up with the fcc. we may be capping the innov

arm twisting on the implementation of the law on the rulemaking and on the enforcement ok so they don't they don't comply with the law until such time as they get caught blatantly breaking the law then they try to change the law so they just have no respect for the rule of law so how can you have a country when your the biggest component of the economy which is the banking and banking services component is just just flagrantly violates the law as of as as a business model of what kind of country is that you know we have a problem with accountability right now we don't have a system where our political players big financial players are being held accountable for their actions ok mike lots of thanks again for being on the kaiser report great thanks max already and that's going to do it for this edition of the cons the report with me max kaiser and stacy herbert i want to thank my guest michael hudson if you want to send me an e-mail please do so at kaiser report at r t t v are you until next time this is max guys are saying go. in india. the move to join. the gateway hotel the grand imper

the comments that have been submitted in the apa rulemaking, i can just imagine what their secretary's office looks like. i ran a regulatory commission for a number of years. the comment that you get in a major rulemaking are, i mean, there are just stacks and stacks and stacks and stacks. they have who's who in the whole electric -- actually, the whole nam chamber, american petroleum institute opposing what they're doing, and the clean guys sporting what their -- supporting what they're doing. and one of the reasons the coal guys are really worried about this, you remember i talked about that $500 billion in new investment that they need to put in generation? that doesn't even include carbon regulation. so it is a very expensive proposition. now, the clean guys aha, we're already clean. we have nuke la power plants or natural gas plants. they see this as a benefit to them. so as we talked earlier, it's, like, follow the money and what's going on here. the greenhouse gas requirements would be imposed on both existing and new utilities, so they have to involve of, have to apply the best

that was because the faa did the rulemaking that allow them to be used on airplanes. parents and guardians of small children have a lot of child restraint options now. in commercial aviation and general aviation, we have the typical ford and after approved child restraints. but the ones that i just talked about that are approved under faa process these as well. you reach out to general aviation and commercial aviation, carriers and operators, with guidance and tools they need to facilitate the use of child restraint on aircraft. our guidance helps our carriers develop crewmember policies and procedures, crewmember education, address specialized tissues. we discussed the use of chuggers trend for children with disabilities, education about new types of child restraints. we address many of the fit and placement issues that were raised in the presentation. we give airlines the best information that they need to develop emergency procedures to be used when their children on board in an aircraft. the faa continues with its education and outreach. we developed a very large,

much of that burden of dodd-frank rulemaking really falls on other divisions, most notably trading andes, regulation, division of investment management for the private funds, regulation and a division of finance for the new public company disclosure requirements that has been decreed by the law. so i think we will be able to not have ifrs or other accounting initiatives delayed any way by the dodd-frank effort. many of those have commented on the possible adoption of ifrs by domestic registrants, have been larger companies, investors and audit firms. healthy sec identifies the issues and concerns of the rest of corporate america? i.e. the vast majority of domestic registrants, investors and audit firms who do not have the resources to write comment letters or to invest in preliminary and -- evaluations of the effect of adopting ifrs. it's a great question and one we've been very focused on, and in our workplan, you will note that we talk extensively about our desire and really need and determination to understand what the impact of incorporating ifrs would be on smaller u.s. public com

. -- rulemaking and our reforms are not enough to achieve that goal.ce, there is one in particular we cannot dismantle without your help. one barrier without which you have to leave the fight. skepticism that springs from a decade they see marked as misleading window dressing and quarterly reports and off- balance sheet exposures that prevented them from making fully informed investment decisions. an essential touchdown is an investor's ability to get an unvarnished assessment of the company's financial condition. that is why the foundation of markets is accurate and transparent financial reporting. and honest verification of that reporting by an independent objective party. the commission's role in promoting uniform principles for these tasks is an important chapter in our history. while accurate and transparent reporting begins with detailed reporting from every corner of an enterprise, which generates numbers that add up at the bottom line, it does not end there. that is because accurate reporting is also about time we come awful, and fair disclosur

the federal rulemaking in regulation has also been growing at an unprecedented rate in recent years.o revise and extend most of its important environmental and pollution control rules as a result of the deployment of many energy conservation regulations in demand statute in the bush administration as a result of the fcc's ambition to regulate the internet and dozens of other initiatives. and that scheduled growth -- and that growth is going to increase vary significantly in the next couple of years as a result of the regulatory juggernaut created by the obamacare legislation and the.frank at, which are launching literally hundreds of new rulemaking proceedings. yet under current arrangements come the trajectory of regulatory growth will be little influenced by the elections because it is on autopilot as far as our elected legislature is concerned. here, but was i returned, costs, benefits disbursement by congress or by regulatory agencies in the executive branch. and under delegations of power from past congresses, from congresses 2009, in 1970 he were in the new deal earlier. we hav

the comments that have been submitted in the apa rulemaking, i can just imagine what their secretary's office looks like. i ran a regulatory commission for a number of years. the comment that you get in a major rulemaking are, i mean, there are just stacks and stacks and stacks and stacks. they have who's who in the whole electric -- actually, the whole nam chamber, american petroleum institute opposing what they're doing, and the clean guys sporting what their -- supporting what they're doing. and one of the reasons the coal guys are really worried about this, you remember i talked about that $500 billion in new investment that they need to put in generation? that doesn't even include carbon regulation. so it is a very expensive proposition. now, the clean guys think, aha, we're already clean. we have nuke la power plants or natural gas plants. they see this as a benefit to them. so as we talked earlier, it's, like, follow the money and what's going on here. the greenhouse gas requirements would be imposed on both existing and new utilities, so they have to involve of, have to apply t

much of that burden of dodd-frank rulemaking really falls on other divisions, most notably trading and markets for all other derivatives, regulation, division of investment management for the private nds, regulation and a division of finance for the new public company disclosure requirements that has been decreed by the law. so i think we will be able to not have ifrs or other accounting initiatives delayed in any wa by the dodd-frank effort. many of those have commented on the possible adoption of ifrs by domestic registrants, have been larger companies, investors and audit firms. healthy sec identifies the issues and concerns of the rest of corporate america? i.e. the vast majority of domestic registrants, ivestors and audit firms who do not have the resources to write comment letters or to invest in preliminary and -- evaluations of the effect of adopting ifrs. it's a great question and one we've been very focused on, and in our workplan, you will note that we talk extensively about our desire and really need and determination to understand what the impact of incorporating ifrs woul

that was because the faa did the rulemaking that allow them to be used on airplanes. parents and guardians of small children have a lot of child restraint options now. in commercial aviation and general aviation, we have the typical ford and after approved child restraints. but the ones that i just talked about that are approved under faa process these as well. you reach out to general aviation and commercial aviation, carriers and operators, with guidance and tools they need to facilitate the use of child restraint on aircraft. our guidance helps our carriers develop crewmember policies and procedures, crewmember education, address specialized tissues. we discussed the use of chuggers trend for children with disabilities, education about new types of child restraints. we address many of the fit and placement issues that were raised in the presentation. we give airlines the best information that they need to develop emergency procedures to be used when their children on board in an aircraft. the faa continues with its education and outreach. we developed a very large,

>> yes in the midst of a lot of rulemaking.hairman. >> chairman schapiro, would be less than half the cost and half the time? is that too optimistic? >> any estimate i give you will be wrong. we think between 50%-8% of the current cost estimate is associated with the requirement for the broker-dealers to build the recording systems. there are existing technologies that would facilitate that and it should make a significant change in the cost of all. >> it could be as much as half? >> i would hope so. i think it is important to point out that while it is a very large number, $4 million, either market trades $220 billion every day. it is a big number, but there is a lot at stake in getting the market structure right. >> absolutely. that is why we are pressing. do you think the to be done for half of the previously estimated time? >> i do not know when i do not want to be misleading. it would very much be my hope. it is out for me, perhaps, one of the most important things that could accomplish that the sec. >> in your opening sta

part of the rulemaking of the department of transportation that they're looking at and part of the ruling should come down in a couple months they require the airlines to allow everybody to have at least 24 hours to make up their minds. so, at least you've got a one-day hold on your ticket. but in terms of flying, do your research ahead of time. southwest charges nothing for any bags. jetblue charges for first bag, no, they do not charge for the first bag, but then they charge for the second bag. other airlines almost always charge money for all the bags and all these fees are nonrefundable. even if your bags don't show up with you when your flight gets there. they keep the money. >> they keep my fee, too? >> they keep your fee and it's gone all the way through federal courts and the federal court said, sorry, they get to keep the money. it's crazy. >> it is crazy. well, happy travels, charles. thanks so much we appreciate you being with us. >> take care, chris. bye. >>> a deadly winter storm slowly making its way east across the country. americans from the great lakes to florida have bee

much of that burden of dodd-frank rulemaking really falls on other divisions, most notably trading and markets for all other derivatives, regulation, division of investment management for the private funds, regulation and a division of finance for the new public company disclosure requirements that has been decreed by the law. so i think we will be able to not have ifrs or other accounting initiatives delayed in any way by the dodd-frank effort. many of those have commented on the possible adoption of ifrs by domestic registrants, have been larger companies, investors and audit firms. healthy sec identifies the issues and concerns of the rest of corporate america? i.e. the vast majority of domestic registrants, investors and audit firms who do not have the resources to write comment letters or to invest in preliminary and -- evaluations of the effect of adopting ifrs. it's a great question and one we've been very focused on, and in our workplan, you will note that we talk extensively about our desire and really need and determination to understand what the impact of incorporating ifrs

we're working closely on a policy level, specifically tried to coordinate with rulemaking implement a taste -- implementation. we also look for surveillance and data sharing. after macy's, one example, our staff promptly shared with the sec position data and transaction data with regard to that day's events. and the exchanges and self- regulatory organizations, is a board to conduct front-line market surveillance and coordinate closely not just on may 6 but on other days as well, and have regular interactions. in terms of data, the cftc proceeds futures data on a daily basis. its most important for us to get the very next morning. we do not regularly get the order book because we do not have the resources to get that. may 6, we ask for it. there were 14 million orders. i just calculated that, 476 times more than that stack right there. for that one day and one contract and one month. and that was why it took all while to analyze that data. but we did get it and share it with that -- with the sec. we have what we would call a pre-trade risk management functionality. these safeguards pr

i think again 2.2, i would point to what the commission has put forward in terms of its rulemaking, that is mostly around naked access but could be used to add greater cheap to those know your customer requirements because there is that concerned that the customer of the broker-dealers is just a holding entity for the real customer sitting behind that construct exist in the u.s., to come in some master subaccount scenarios that we try to look through to have the customer of the customer be treated as a customer of the broker-dealer i think there's both further interpreted the rulemaking and in force but that needs to be done. >> mr. narang, you made reference to certain other aspects that exists to some participants. can you expand on what those unfair aspects are? >> yes. they are a little esoteric but i will do my best. basically in the united states equity markets the vast majority of exchanges observe what is known as price time priority. that means that orders that arrive at the exchange at a particular price get first priority to execute against inbound orders, based on their arriv

the notice of proposed rulemaking before you will initiate a process to further the commission's goingent to broadband services and to spur innovation in wireless broadband systems and ensure that america leads the global wireless revolution. the notice would take preliminary steps toward making additional spectrum available for wireless broadband from a portion of the spectrum that is currently used for broadcast television. at the same time, the notice recognizes the important benefits served by broadcast television and takes an approach that will help preserve that service as a healthy, viable medium. the notice proposes three actions that are intended to set the underlining framework to, that -- to accommodate. it would also provide new options for broadcasters. first, the notice proposes to add new allocations for fixed and land mobile services and the tv bands to be primary with the existing broadcast allocation in those bands. this proposal would make all of the spectrum in the tv dance available for fixed mobile and broadcast use and thereby provide the maximum flexibility for

the initial ability to steer and to this council and a provision that entirely separate from the rulemakinge are discussing today, we would say that there will be some pressure on the signature debit networks just due to the fact that merchants will have more flexibility. >> thank you, mr. chairman. l> > in the initia presentation, mark noted that there's no well-established economic definition of incremental costs. you have proposed the, using average variable costs. in all the comments, were there any plausible measures or forms of costs suggested for implementing the concept of incremental? plausible. >> i think the three major alternatives that were presented are the ones i discussed in my presentation. the first would be marginal costs. the second would be something along the lines of average variable costs. the third with the average total costs. >> that is not plausible, given the language. >> that is why we excluded fixed costs. >> mark, on the, enter superposed using marginal costs , what was their argument? other than the fact that it was probably lower? what was the legal argumen

that was because the faa did the rulemaking that allow them to be used on airplanes. parents and guardians of small children have a lot of child restraint opons now. in commercial aviation and general aviation, we have the typical ford and after approved child restraints. but the ones that i just talked about that are approved under faa process these as well. you reach out to general aviation and commercial aviation, carriers and operators, with guidance and tools they need to facilitate the use of child restraint on aircraft. our guidance helps our carriers develop crewmember policies and procedures, crewmember education, address specialized tissues. we discussed the use of chuggers trend for children with disabilities, education about new types of child restraints. we address many of the fit and placement issues that were raised in the presentation. we give airlines the best information that they need to develop emergency procedures to be used when their children on board in an aircraft. the faa continues with its education and outreach. we developed a very large, o

we had really hoped that would have been done a long time ago but we recognize the massive rulemaking undertaking that is. so we feel that they are listening to our concerns. it hasn't always articulated itself into a ruling that was going to be helpful. but we do feel they are listening. they are trying. >> okay. good. mr. lamar, let me ask you, if i may, kind of follow up on that same question. i know that your industry has had a lot of contact with the cpsc. >> uh-huh. >> and i'm curious about, you know, if your perception is that they've been receptive and willing to listen? and even if they have, do they kind of come back and say that their hands are tied? so same question? >> i think they have been extraordinarily responsive. i would agree with jill. we've had conversations, multiple conversations, with commissioners or staff, several of the commissioners have come and presented at training workshops that we've held and throughout the united states and around the world. they've been very eager to help out when they can. many times the reaction we get is you raise some good point

actually had superintendents have been that come to our state board hearings, and we did this in rulemaking, because that was the best process -- we actually had superintendents who intended and said this -- if we do not want to move to an eight- f grade, because our system is confusing and we like that. [laughter] another says that we have never had to explain our schools' performance and now we will have to. it was not just teachers' unions. but the teachers' unions have been very galvanized against all the reforms we are after, as have many of the other. the tackle wait for us has been, and paul and i were talking about this earlier, as i talk to legislatures, my strong suggestion is go right to the belly of the beast. you have to have the courage -- what you'd say, you're talking points, you have to walk out to your communities, look people in the eye and say this is what we are for, this is what we're about, because it is best for job and print you cannot say one thing behind closed door and another behind communities. we've gone to the teachers' unions and school boards and superinten

given rulemaking dodd-frank requires the next 12 months as june 2011 real estate? how do demands of dodd-frank affect the timeline clicks as i said, we are not strictly committed to a june 2011 decision day, but rather sometime in 2011. i will say that while i'm sure you've all read in the press we have an extraordinary amount of work to do with respect to pcaob. over a hundred will strike, many within the first 12 months, certainly within the first 18. twenty studies to create within the agency. i will say that only a small amount of that burden has fallen on the office of the chief accountant and jim kroeker can probably speak to this later, much of the burden of dodd-frank rule-making faults in other, most notably tradename markets world the truth of its regulations, division of investment management for the private funds regulation and division of corporation finance for the new public company disclosure requirement have been decreed by the law. so i think they will be able to not have ifrf or other accounting initiatives related in any way by the pcaob effort.

this regulation is not a final regulation, it is a notice of proposed rulemaking, proposed rule making. that means we will be taking comments. based on those comments the regulation could change. but we believe that it maximizes the consumer protection and transparency without unduly burdening the industry. importantly, it leaves state law and procedure in tact. we therefore believe it strikes the right balance and we are pleased to release it today. i am also pleased now to introduce the commissioner of a state that is really a leader in rate regulation throughout the country, a small state but they are a leader in this area, chris kohler, health insurance commissioner of rhode island. >> thank you, jay. small state, big regulators. inro islands we concur with the federal -- in rhode island, we concur. rate review is absolutely essential for meaningful health- care reform. without it, you have on fairfax on individual consumers -- as we are going to hear about in a moment -- and no predictability for purchases. no accountability for health plans. and what ultimately no change in a sys

proxy, that we are not going to let be pushed off the agenda just by the exigencies of the current rulemaking workload. what changes have been made or are anticipated to be made to the sec's internal structure to meet the deadlines imposed by the odd frank act? for example, you've indicated you expect the commission to hire a number of people to meet the mandate, can you discredit in general the skill set that you expect to focus on, lawyers or accountants -- accounts? and in what areas do you expect about the most people. you know, we have, we are often criticized for being an overbloated agency, and i take ception to that, not because i'm a lawyer but because we are inside a law enforcement agency. so our lawyers are very important to us and we also write a lot of rules and we do in the law. that said, there's a great need at the sec for our accountants the really critical to almost every division and every function we perform. but also for some less traditional skill sets in the context of the work of the sec. so we've been bringing people from trading desks, from investment banking firms,

is this one of the mandatory responsibilities for statutory rulemaking? >> i am not sure how early that will come realistically. we're focused overwhelmingly on trying to make sure we are fixing the existing problems in service or performance. it will be a very important priority. what should be the basic future of the housing industry or generally. not that we want to take some much time to them because it's so consequential, but we got this terrible wrong as a country and what to make sure we're getting a ride to make sure we have a durable set of fixes. >> how do we proceed with national standards to avoid 50 states proceeding down the road requesting david -- requesting data from servicers? >> i cannot tell you if it's something where we will have a proposal in six or 12 months, i can't tell you. we will see what is the best way to proceed. >> do you foresee a new era of cooperation, particularly between the states and the agencies? >> we will have a test of this in the mortgage documentation problems that have been the subject of any of your -- worki

actually had superintendents have been that come to our state board hearings, and we did this in rulemaking, because that was the best process -- we actually had superintendents who intended and said this -- if we do not want to move to an eight- f grade, because our system is confusing and we like that. [laughter] another says that we have never had to explain our schools' performance and now we will have to. it was not just teachers' unions. but the teachers' unions have been very galvanized against all the reforms we are after, as have many of the other. the tackle wait for us haseen, and paul and i were talking about this earlier, as i talk to legislatures, my strong suggestion is go right to the belly of the beast. you have to have the courage -- what you'd say, you're talking points, you have to walk out to your communities, look people in the eye and say this is what we are for, this is what we're about, because it is best for job and print you cannot say one thing behind closed door and another behind communities. we've gone to the teachers' unions and school boards and superintende

each complaint filed about create more uncertainty as the enforcement process becomes a de facto rulemaking circus, just as the commission attempted in the ill-fated comcast case. how does this framework create regulatory certainty. even european commission recognized the harm such rules would cause to the capital markets when it decided last month not to impose measures similar to these. part of the argument in favor of new rules alleges that giant corporations will serve as hostile gatekeepers to the internet. first, in the almost nine years since those fears were first sewn, net regulation lobbyists can point to fewer than a handful of cases of alleged misconduct out of an infinite number of internet communications. all -- all of those cases were resolved in favor of consumers under current law. more importantly, however, many broadband providers are not large companies. many are small businesses. taken, for example, larette, a fixed wireless internet service provider serving rural communities in wyoming. they told the commission that the imposition of network management rules will imped

it is involved in rulemaking. it stays involved in rulemaking. one of the routes you can use ads in bashing as an advocate try to influence an agency is back to the very congress that wrote the legislation in the first place. the second is the president. the president is an enormously important player in this because he establishes the regulatory program and the regulatory agenda for his administration. if he decides environmental quality is a big deal, it becomes a big deal. if he decides the rules are going to be written on a strict, cost benefit standard, nothing gets written in less you can see net benefit, and nothing will come out of an agency with that characteristic. if on the other hand he decides we're going to produce an enormous body of rules that make up for a decade of laxative rules in protecting the about, protecting workers, protecting the financial security of the american people, then you're going to be seeing signals throughout the government that reignited the rulemaking process. by the way look at a table data. it hasn't hap