March 3, 2004

U.S. SHADOW FINANCIAL REGULATORY COMMITTEE

2003 Annual Report

Administrative Office

c/o Professor George G.  Kaufman
Loyola University Chicago
820 N. Michigan Avenue
Chicago, Illinois  60611
312-915-7075
 

In 2003, the U.S. Shadow Financial Regulatory Committee completed its eighteenth year of operation.  As in most of its previous years, the Committee met quarterly. It issued seventeen policy statements. Three new members joined the Committee: Kenneth Dam, University of Chicago and former Deputy Secretary of the U.S. Treasury; Kenneth Lehn, University of Pittsburgh and former chief economist of the Securities and Exchange Commission; and Randall Kroszner, University of Chicago and former member of the President’s Council of Economic Advisers.  Robert Litan, a member of the Committee since 1996 and co-chair since 1998, resigned for personal reasons.  Richard Herring, a member since 1990 was elected co-chair to succeed Litan. (Current and past members of the Committee are listed in Appendix A.)

In addition to the U.S. Shadow Financial Regulatory Committee, similar committees currently operate in Europe, Japan, and Latin American, and a new committee in East Asia had its initial organizing meeting.  The committees operate independently, but keep each other informed of their activities and generally meet jointly once a year. Although there was no joint meeting in 2003, a meeting is scheduled in late 2004 in Washington, D.C. The membership and statements of all the committees are posted on the U.S. Committee’s website at the AEI--www.aei.org--scroll to Shadow Financial Regulatory Committee.

Meetings

As usual, the Committee met quarterly for two days--all day on Sundays and on Monday mornings.  The 2003 meeting dates were on Sunday-Monday, February 23-24, May 4-5, September 21-22 and December 7-8. All meetings were at the offices of the American Enterprise Institute in Washington, D.C. 

At its February meeting, the Committee discussed the bank regulators’ proposal for disciplining bank auditors; remaining unresolved issues concerning the Sarbanes-Oxley and Gramm-Leach-Bliley Acts; Fannie Mae and Freddie Mac, and the settlement between state attorney generals and some investment banking firms and their research analysts.  In May, the Committee discussed improving the efficiency of the transatlantic securities market, terrorism insurance, the House of Representative’s deposit insurance reform bill, the Basel Capital Accord, and the European Union’s proposed regulations on financial conglomerates.  In September, the Committee discussed predatory lending and federal preemption of certain state banking laws, pending legislation regarding Fannie Mae and Freddie Mac, the responsibilities of financial professionals and firms in recent financial scandals, and taxpayer exposure to liabilities of the Pension Benefit Guarantee Corporation.  The December meeting focused on the problems in the mutual fund industry and the NYSE, Basel capital requirements, nominating nonmanagement corporate directors, and the Comptroller of the Currency’s annual report.  In particular, the Committee developed a simple plan for resolving a number of the mutual fund problems at low cost by delaying settlement by one day (t + 1).   At these meetings, the Committee followed its usual practice of devoting part of the session to meeting with guests. Guests are usually representatives of policy-makers, regulatory agencies, financial services firms, and trade associations. These meetings are private, closed-door exchanges of ideas on issues of current concern to both parties. Guests in 2003 included Cynthia Glassman, SEC Commissioner; Donald Powell, FDIC Chairman; Vicki Tillman, Executive VP of S&P; representatives of government agencies; and private consultants.

Policy Statements 

The Committee continues to serve as a major independent public watchdog for monitoring and evaluating events affecting the efficiency and safety of the financial services industry.  The primary means of disseminating its views on these issues is through policy statements adopted at its meetings after thorough discussion. A listing of all policy statements since its establishment in 1986 appears in Appendix B. Through 2003, the Committee has issued 202 policy statements.

In a sharp break from past policy statements, the Committee’s statements in 2003 focused greatly on investment banking, mutual funds, and the SEC rather than on commercial banks, S&Ls, and bank regulators.  This reflected the changed areas of current public policy concern and problems.  Ten of the seventeen statements reflected this concern, two focused on GSEs and the remainder primarily on more traditional banking and bank regulation issues.

Dissemination and Public Service

The Committee seeks both to raise the level of debate on public policy affecting the financial services industry and to improve public policy itself largely through its policy statements and the underlying analytical reasoning. The policy statements are released at a press conference immediately following the quarterly meetings. The press conferences, which are attended by Committee members, serve two purposes. One, they provide the representatives of the media and other attendees, such as congressional and agency staff members, with an opportunity to obtain additional information about the statements, including background information and underlying reasons, through both an introductory briefing and from questions asked of Committee members. Two, the conferences provide the Committee with an opportunity to educate the press and Washington-based staff on the underlying economics arguments for each statement and to assist them in formulating appropriate questions. The policy statements and the press conferences receive regular coverage in financial trade publications, such as the daily American Banker and the daily and weekly BNA Banking Reports, and occasional coverage in major national daily and weekly publications, such as the Wall Street Journal and Washington Post. In addition, segments of the press conferences and interviews with Committee members at the conferences have in the past been broadcast on a number of TV and radio stations, including CSPAN, PBS, CNBC, CNN and Bloomberg.

The policy statements are posted shortly after the press conference on the AEI website, alongside the past statements, and are delivered the same day to the appropriate policy-makers, regulatory agencies, and other interested parties. To the extent that the statements pertain to specific issues and proposed regulations on which agencies have requested public comment, they are submitted to the agency.  Members of the media who do not attend the press conference, as well as policy-makers, regulators, and members of the general public who request being on the mailing list, are emailed notifications that the statements are available on the AEI website.  In addition, requests for policy statements and other information are made by telephone and letter through the Committee’s administrative office at Loyola University Chicago. 

The other three Shadow Financial Regulatory Committees also met throughout the year and released a number of policy statements.  These statements are available on the U.S. Shadow Committee AEI website.

Administrative and Financial

The Committee is a tax-exempt 501(c)(3) nonprofit organization. The Committee’s administrative office is at Loyola University Chicago.  Beginning in 1999, the Committee has been financially supported entirely by the American Enterprise Institute and has held all of its meetings there, but retains its policy independence.
 
Appendix A: Statement of Purpose and Membership

The Shadow Financial Regulatory Committee is a group of independent experts on the financial services industry and its regulatory structure.

The purpose of the Committee are: (1) to identify and analyze developing trends and ongoing events that promise to affect the efficiency and safe operation of sectors of the financial services industry, (2) to explore the spectrum of short- and long-term implications of emerging problems and policy changes, (3) to help develop appropriate private, regulatory and legislative responses to such problems, and (4) to assess and respond to proposed and actual public policy initiatives with respect to their impact on the public interest.

The results of the Committee’s deliberations are intended to increase the awareness and sensitivity of members of the financial services industry, public policy markets, the communications media and the general public to the importance and implications of current problems, events and policy initiatives affecting the industry.

Members of the Shadow Financial Regulatory Committee are drawn from academic institutions and private organizations and reflect a wide range of views.  The Committee is independent of any of the members’ affiliated institutions or of sponsoring organizations.  The recommendations of the Committee are its own.  The only common denominators of the members are their public recognition as experts on the industry and their preferences for market solutions to problems and the minimum degree of government regulation consistent with efficiency and safety.

Past and Present Members (1986-2003)

George G. Kaufman, (1986-) Robert E. Litan, (1996-03) Richard J. Herring (1990-) Richard Aspinwall (1986-01) George J. Benston (1986-) Marshall Blume (2002-) Charles Calomiris (1998-) Lawrence Connell (1986-98) Kenneth Dam (2003-)  Neil A. Doherty (1997-98) Franklin Edwards (1986-) Robert A. Eisenbeis (1986-96) Wendy Lee Gramm (1994) Scott E. Harrington (1998-) John D. Hawke (1986-95)  Paul M. Horvitz (1986-) Edward J. Kane (1986-96) Randall S. Kroszner (2003-) Kenneth M. Lehn (2003-) Jonathan R. Macey (1998-99) Robert W. Mehle (1986-93) Allan H. Meltzer (1986-90) Franco Modigliani (1992-98)  Roberta Romano (2000-01)  Hal S. Scott (1998-) Kenneth E. Scott (1986-) Peter J. Wallison (1995-)

Loyola University Chicago Brookings Institution University of Pennsylvania Chase Manhattan Bank (retired) Emory University University of Pennsylvania Columbia University Attorney at Law University of Chicago University of Pennsylvania Columbia University University of North Carolina University of Texas at Arlington University of South Carolina   Arnold & Porter  University of Houston Boston College University of Chicago University of Pittsburgh Cornell Law School Attorney at Law Carnegie-Mellon University Massachusetts Institute of Technology Yale Law School Harvard Law School Stanford Law School American Enterprise Institute

Appendix B: Policy Statements

1. The Baker Plan and LDC Lending, Feb. 15, 1986 2. Aid to Failing Banks, Feb. 14, 1986 3. Federal Reserve Ruling on Junk Bonds, Feb. 14, 1986 4. Disclosure of Supervisory Actions Examiners' Ratings, June 9, 1986 5. Disclosure by Regulated Financial Institutions, June 9, 1992 6. Proposals for Risk-Related Bank Capital Guidelines, June 9, 1986 7. Capital Forbearance Policy for Agricultural and Energy Banks, June 9, 1986 8. Recapitalizing FSLIC and Zombie S&L's, June 9, 1986 9. Proposal to Facilitate the Interstate Takeover of Failing Depository Institutions, June 9, 1986 10. Federal Home Loan Bank Board (FHLBB) Proposed Rules on Regulatory Capital and Nationwide Lending by Insured Savings and Loan Associations, Aug. 5, 1986 11. Federal Regulation of Activities of State Chartered Financial Institutions, Nov. 17, 1986 12. Conversion of S&Ls from FSLIC to FDIC Insurance Coverage, Nov. 17, 1986 13. Current Bank Holding Company Applications for Increased Securities Activities, Nov. 17, 1986 14. Policies Toward Troubled Depository Institutions, Nov. 17, 1986 15. Proper Financing of Private Party Securities Fully Guaranteed by the Federal Government, Dec. 1, 1986 16. FSLIC Recapitalization, Feb. 9, 1987 17. The Federal Reserve Board's "Source-of-Strength" Policy, May 18, 1987 18. Regulatory Proposals for Risk-Related Capital Standards (Rev.), May 18, 1987 19. Supplementary Statement: Regulatory Proposals for Risk-Related Capital Standards, May 18, 1987 20. Unnecessary Costs of FSLIC Recapitalization Program, Sept. 14, 1987 21. International Debt, Nov. 13, 1987 22. FSLIC Handling of Insolvent Thrift Institutions, Nov. 13, 1987 23. Brady Commissions and Recent Market Events, Nov. 13, 1987 24. The Federal Reserve Board's Request for Comment on the Acquisition of Healthy Thrift Institutions by Bank Holding Companies, Nov. 13, 1987 25. Moratorium on Bank Securities Activities, Feb. 8, 1988 26. Studies of the Stock Market Crash, Feb. 8, 1988 27. Disposal of FDIC Equity Interests in Assisted Banks, Feb. 8, 1988 28. The Southwest Plan for Ailing Thrift Institutions, Feb. 8, 1988 29. Regulatory Proposal for Risk-Related Capital Standards, Feb. 8, 1988 30. Disclosure by Financial Institutions of Financial Assets and Liabilities, Feb. 8, 1988 31. FDIC's New Policy on "Whole Bank" Takeovers, May 16, 1988 32. Proposed FDIC Policy Statements Encouraging Independent Outside Audits of Banks, May 16, 1988 33. Policy Responses to the Stock Market Crash, May 16, 1988 34. FSLIC's Handling of Failed Thrifts, May 16, 1988 35. Need to Make FSLIC and FDIC Assistance Deals Accountable, Sept. 25, 1988 36. The Need to Estimate the True Economic Condition of the FDIC, Dec. 5, 1988 37. Assessing FDIC Premiums Against U.S. Banks' Unsubordinated Debt and Deposits in Foreign Branch Offices, Dec. 5, 1988 38. An Outline of a Program for Deposit Insurance Reform, Dec. 5, 1988 39. The Administration's Plan to Resolve the Thrift Crisis, Feb. 13. 1989 40. Risk-Based Capital and Early Intervention Proposal of Federal Home Loan Bank Board, Feb. 13, 1989 41. An Outline of a Program for Deposit Insurance and Regulatory Reform (Revision of No. 38), Feb. 13, 1989 42. The On-Budget Status of Expenditures to Resolve Thrift Insolvencies, May 15, 1989 43. Financial Institutions Reform, Recovery and Enforcement Act of 1989, May 15 1989 44. The Comptroller of the Currency's Proposal for a Minimum Bank Leverage Ratio, Sept. 18, 1989 45. Federal Reserve Proposal to Modify the Payments System Risk Reduction Programs, Sept. 18, 1989 46. Proposals to Modify Loan Loss Reserves for Third World Debt, Sept. 18, 1989 47. Congressionally-Mandated Accounting for Junk Bond Sales, Sept. 18, 1989 48. The Activities of the Resolution Trust Corporation, Dec. 4, 1989 49. Latin American Debt, Dec. 4, 1989 50. Capital Standards for Member Banks*, Dec. 4, 1989 51. Proposal to Curb Stock Market Volatility, Dec. 4, 1989 52. The FDIC's Proposed Regulation on Purchased Mortgage Servicing Rights, Feb. 26, 1990 53. Subsidized Federal Reserve Assistance, Feb. 26, 1990 54. The Failure of the Treasury's Study of the Federal Deposit Insurance System to Focus on Identifying and Correcting Defects in Government Incentives, Feb. 26, 1990 55. RTC Thrift Resolution Policies, May 7, 1990 56. The Elimination of Restrictions on Bank Securities Activities and Affiliations, May 7, 1990 57. Proposals to Consolidate the SEC and CFTC, May 7, 1990 58. Provision of Seller Financing by RTC in Asset Sales, Sept. 24, 1990 59. Condition of the Bank Insurance Fund, Sept. 24, 1990 60. RTC Property Disposition Policies, Sept. 24, 1990 61. Limiting Taxpayer Loss Exposure in Government-Sponsored Credit Enterprises, Sept. 24, 1990 62. Congressional Intercession with the Financial Regulatory Agencies, Dec. 10, 1990 63. National Branching, Dec. 10, 1990 64. FDIC Ownership of Continental Illinois Stock, Dec. 10, 1990 65. Treasury's Deposit Insurance Reform Recommendations, Feb. 11, 1991 66. Proposals to Inject Additional Funds into the Bank Insurance Fund, Feb. 11, 1991 67. Concerns About the Availability of Bank Credit, Feb. 11, 1991 68. OTS Proposal for Capital Requirement for Interest Rate Risk, Feb. 11, 1991 69. FASB's Proposed Statement of Financial Accounting Standards Concerning "Disclosures About Market Value of Financial Instruments", Feb. 11, 1991 70. Funding of the BIF and Depository Insurance Reform Proposals in H.R. 2094, May 20, 1991 71. Need to Develop a Satisfactory Data Base With Which to Analyze the Economic Condition of Insurance Companies ,May 20, 1991 72. OMB & CBO Statements Calling for More Informative Accounting & Budgeting for Deposit Insurance, Sept. 16, 1991 73. Additional Comments of Deposit Insurance Reform Legislation, Sept. 16, 1991 74. Bank of Credit & Commerce International, Sept. 16, 1991 75. Protecting Taxpayers from Risks of Government Sponsored Enterprises, Sept. 16, 1991 76. FDIC Improvement Act of 1991, Dec. 16, 1991 77. Accounting for Taxpayers' Stake in the FDIC's Bank Insurance Fund, Dec. 16, 1991 78. United States Listing Requirements for Foreign Companies, Dec. 16, 1991 79. Interagency Policy Statement on Commercial Real Estate Loans, Dec. 16, 1991 80. FDIC's Program for "Hospitalizing Sick Banks", Feb. 17, 1992 81. Using Risk-Related Capital Standards to Promote Housing, Feb. 17, 1992 82. Need to Regulate Interest Rate Risk, Feb. 17, 1992 83. The FDIC's Proposed Schedule of Risk-Sensitive Premiums, June 1, 1992 84. Brokered Deposits and Capital Requirements, June 1, 1992 85. The TDPOB's Proposed Early Resolution/Assisted Merger Program, June 1, 1992 86. SEC Listing Requirements for Foreign Securities, June 1, 1992 87. Rule Proposed by Bank Regulators to Control Interest Rate Risk, Sept. 14, 1992 88. Proposed Rule on Interbank Exposure, Sept. 14, 1992 89. Standards for Safety and Soundness, Sept. 14, 1992 90. An Open Letter to President Clinton, Dec. 14,1992 91. Proposed Changes in the FDIC's Risk-Related Premium System, March 1, 1993 92. FDIC Action on Critically Undercapitalized Banks, March 1, 1993 93. Taxpayer Risks in the Pension Benefit Guarantee System, March 1, 1993 94. The Policy of Authorizing "Minimal Documentation" Loans, May 24, 1993 95. "Fair Value" Reporting for Insured Depository Institutions Required Under FDICIA, May 24, 1993 96. Modifying Risk-Based Capital Standards to Account for Interest-Rate Risk, May 24, 1993 97. FDIC Pilot Reinsurance Program, May 24, 1993 98. The New Depositor Preference Legislation, Sept. 20, 1993 99. Proposals to Permit Banks to Branch on an Interstate Basis, Sept. 20, 1993 100. The Proposed Federal Banking Commission, Dec. 13, 1993 101. Safety and Soundness Standards, Dec. 13, 1993 102. Deterioration in the Financial Condition of the Pension Benefit Guarantee Corporation, Dec. 13, 1993 103. Principles of Regulatory Restructuring, Feb. 14, 1994 104. Mutual to Stock Conversions of Thrift Institutions, Feb. 14, 1994 105. Proposed Revisions to Community Reinvestment Regulations, Feb. 14, 1994 106. Proposed Lengthening of Examination Schedules and Required Independent Audits for Thrift Institutions, May 23, 1994 107. Federal Displacement of State Laws: Fair Credit Reporting and Interstate Branching, May 23, 1994 108. Proposed Increases in FHA Insurance Limits, May 23, 1994 109. Financial Accounting Standard 115, May 23, 1994 110. Final Rules on Incorporating Concentrations of Credit Risks Into Risk-Based Capital Standards, Sept. 26, 1994 111. Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994, Sept. 26, 1994 112. Regulatory Agency Measurement of Bank Capital for Prompt Corrective Action, Dec. 12, 1994 113. Proposed Community Reinvestment Act Regulations, Dec. 12, 1994 114. FDIC Insurance Assessments, Dec. 12, 1994 115. Repeal of the Bank Holding Company Act and Restrictions on Product Diversification for Banking Organizations, Dec. 12, 1994 116. Open Letter on Financial Reform to the Senate and House Banking Committees, Feb. 13, 1995 117. Emergency Assistance for Mexico, Feb. 13, 1995 118. Principles of Bank Reform: Guidelines for Assessing Pending Legislative Proposals, May 22, 1995 119. Wholesale Banking Proposal Under H.R. 1062, May 22, 1995 120. The Leach Bill, May 22, 1995 121. Proposed Amendments to Part 5 of the Regulations of the Office of the Comptroller of the Currency, May 22, 1995 122. Federal Reserve Proposal for Pricing Daylight Overdrafts, May 22, 1995 123. Alternatives to Recapitalizing the Savings Association Insurance Fund, May 22, 1995 124. The Banking Agencies' Proposed Interest Rate Risk Capital Standards, September 18, 1995 125. Alternatives to Recapitalizing the Savings Association Insurance Fund and Defeasing the FICO Bonds, September 18, 1995 126. Values of Bank Capital Tripwires for Prompt Corrective Action and Least Cost Resolution, December 11, 1995 127. Reduction in Premiums for BIF-Insured Institutions, December 11, 1995 128. Bank Merger Law and Policy, December 11, 1995 129. Ownership of Stock by Bank Directors, December 11, 1995 130. Expansion of Bank Powers by Regulation, February 12, 1996 131. Extending the Credit Reform Act to GSEs, February 12, 1996 132. Disclosure of Examination Reports and Ratings, May 6, 1996 133. Proposed Legislation on Enterprise Resource Banks (The "Baker Bill," H.R. 3167), May 6, 1996 134. A Proposal for Privatization of the Federal Home Loan Bank System, May 6, 1996 135. An Open Letter to President Clinton on Financial Reform, December 9, 1996 136. Recent Fed and OCC Rulings on Permissible Bank Activities, December 9, 1996 137. Bank Activities and the Extension of Bank Subsidies, May 5, 1997 138. Restrictions on Banking-Commerce Affiliations, May 5, 1997 139. H.R. 10 ("Leach Bill") and the Commerce Subcommittee Draft,. September 22, 1997 140. Mortgage Lending by Federal Home Loan Banks, September 22, 1997 141. Strategic Plans of Federal Financial Institution Regulatory Agencies, December 7, 1997 142. Congress and Financial Reform, December 7, 1997 143. Sweep Accounts and the Prohibition on Paying Interest on Reserve, December 7, 1997 Balances and Demand Deposits. 144. Expanded Powers for Federal Home Loan Banks, May 4, 1998 145. International Monetary Fund Assistance and International Crises, May 4, 1998 146. The Credit Union Membership Access Act, H.R. 1151, May 4, 1998 147. Mergers and Acquisitions in the Banking Industry, May 4, 1998 148. Principles for Reforming the "Global Financial Architecture", September 28, 1998 149. The Use of Private Credit Ratings for Determining Capital Requirments, September 28, 1998 for Securitizations 150. The Senate vs. Version of H.R. 10, September 28, 1998 151. The Issues Posed by the Near-Collapse of Long-Term Capital Management, September 28, 1998 152. The G-7’s New Precautionary Credit Line Facility for the IMF and Its Use in Brazil, December 7, 1998 153. The Federal Reserve Board and Prudential Supervision, December 7, 1998 154. Revising the Basle Capital Standards, April 26, 1999 155. The Latest Round of Bills on Financial modernization, April 26, 1999 156. The Basel Committee’s New Capital Adequacy Framework, September 27, 1999 157. The Failures of BestBank and First National Bank of Keystone, September 27, 1999 158. Proposed Federal Catastrophe Reinsurance, December 13, 1999 159. Federal Home Loan Banks, December 13, 1999 160. Reforming Bank Capital Regulation, March 2, 2000 161. Proposal on Full Cost Pricing of Supervisory and Examination Services by the Federal Banking Agencies, May 8, 2000 162. Proposal to Increase Deposit Insurance coverage to $200,000, May 8, 2000 163. The Regulation of Derivative Instruments, September 25, 2000 164. Privatizing the Housing GSEs, September 25, 2000 165. Deposit Insurance Reform Options, December 4, 2000 166. An Open Letter to the New President and Congress On an Agenda for Financial Reform, December 4, 2000 167. Comptrollers' Proposed Pilot Program Permitting Increased Lending Limits for Community Banks, December 4, 2000 170. Optional Federal Chartering of Insurance Companies, May 7, 2001 171. Assuring Discipline of the Housing GSEs, May 7, 2001 172. Terrorism Insurance, December 3, 2001 173. Predatory Lending, December 3, 2001 174. The Gramm-Leach-Bliley Act, December 3, 2001 175. Deposit Insurance Reform, February 25, 2002 176. Enron and Accounting Issues, February 25, 2002 177. Pension Reform in the Wake of Enron’s Collapse, February 25, 2002 178. Statement on Shay-Marky Bill on GSE Disclosure, May 6, 2002 179. The Basel 2 Approach to Bank Operational Risk, May 6, 2002 180. The Responsibility of Independent Auditors to Shareholders of Publicly Traded Corporations, May 6, 2002 181. The Responsibility of Independent Auditors to Shareholders of Publicly Traded Corporations, May 6, 2002 181. Fannie Mae’s Duration Gap, September 23, 2002 182. A Proposed Federal Backstop for Terrorism Insurance and Reinsurance, September 23, 2002 183. SEC Standards for Designating Nationally-Recognized Credit Rating Organizations, December 9, 2002 184. Statement on Disclosure of Portfolio Holding of Registered Investment Companies, December 9, 2002 185. A Financial Agenda for the New Congress, December 9, 2002 186. State and Federal Securities Market Regulation, February 24, 2003 187. The SEC’s Concern with Short Selling, February 24, 2003 188. Glass Steagall, Tying and Conflicts of Interest, February 24, 2003 189. The Registration of Mortgage Backed Securities of Fannie Mae and Freddie Mac, February 24, 2003 190. Access by Institutional Investors to Foreign Electronic Trading Venues, May 5, 2003 191. The European Union’s Financial Conglomerate Directive, May 5, 2003 192. Enforcement Settlement with Wall Street Investment Firms, May 5, 2003 193. The Latest Revisions to Basel II and Implementation Plans in the United States, May 5, 2003 194. Removal of Archaic Bank Regulatory Restrictions, May 5, 2003 195. Predatory Lending and Federal Preemption of State Laws, September 23, 2003 196. Legislation on Fannie Mae and Freddie Mac, September 23, 2003 197. The Responsibilities of Financial Professionals and Firms in Recent Financial Scandals, September 23, 2003 198. Taxpayer Exposure to Liabilities of the Pension Benefit Guarantee Corporation (PBGC), September 23, 2003 199. SEC Proposals for More Shareholder Democracy, December 8, 2003 200. Mutual Fund Expenses and Soft Dollars, December 8, 2003 201. New York Stock Exchange Governance and Market Structure Issues, December 8, 2003 202. Simple Proposal to Deal with Market Timing and After Hours Trading, December 8, 2003