Jul. 07, 2021
SEC I applaud the SEC for its efforts in promoting Diversity in Asset management industry. Its report is a great summary and reference tool. However it misses the point. I have sent you info on this in the past, your recommendations overlook standard government reporting practices . Some of these practices have been in existence since 1977. I know this first hand because I was involved with the passage of the act. As Ronald Reagan and others say " Trust but Verify " . I would add, that a " Pessimist is an optimist with experience". In Summary : I. FDIC and other regulators require banks to issue an annual CRA ( Community Reinvestment Act of 1977 ) statement. Why can't SEC require annual publicly disclosed Diversity Statement ? The reluctance to disclose is a natural , uninformed knee jerk reaction. Banks objected to mortgage disclosure when the Home Mortgage Disclosure Act was introduced in 1975. They complained it was socialism and it would result in the end of capitalism as we know it. The Banking community has thrived since then. II.CRA requires banks to keep an open comment file in case people want to review the company's CRA statement and make comments or complaints for regulators , why can't SEC require an open comment file for the public to register complaints and comments ? III. CRA is taken into account whenever a bank wants to merge or make an acquisition ( i.e. some TEETH). I don't see any teeth in this at all. Imagine if M&A was detained until a Diversity plan was developed or reviewed? IV. What is the penalty for failure to disclose or for Discrimination ? Until Discrimination is penalized , it will continue. Until Models of Success are described and rewarded , as we did with the US Commission On Minority Business Development under President Bush in 1991, it will be ignored. I was a consultant to that Commission , and can share its insights if interested. Where is EEOC data on discriminatory complaints and fines paid over the years? Who has the most complaints, Highest dollars paid in settlements? Public has a right to know. IV. SEC website provides investment information to the public , including analyst information. Why can't SEC provide information on Various efforts to promote Diversity in Asset management Industry and other research on this subject ? Why can't SEC do annual research on programs and practices that promote Diversity ? The CFA Institute ( the Industry ) has failed in this effort. Government can share research just as the Fed Reserve Department of Community Affairs provides research. Once again, I offer to address the commission directly on this matter , of which I am as much, if not MORE of a subject matter expert than others that have presented before you. RESPECTFULLY AND Dorien Nunez celebrating 50 years on Wall St. PS I resent the term " people of color " Here in the South , that sounds a lot like " Colored People ". Happy to suggest better terms.