Capitalism at the Crossroads – Becoming Indigenous

Becoming Indigenous

The Monsanto experience holds an important lesson: If corporate sustainability strategies are narrowly construed, they will fall seriously short. It is not enough to develop revolutionary technology with the potential to leapfrog currently unsustainable methods. Antiglobalization demonstrators have made it apparent that if corporate expansion is seen to endanger local autonomy, it will encounter vigorous resistance. Multinationals seeking new growth strategies to satisfy shareholders increasingly hear concerns from many quarters about consumer monoculture, labor rights, and cultural hegemony. As long as multinational corporations persist in being outsiders—alien to both the cultures and the ecosystems within which they do business—it will be difficult for them to realize their full commercial, let alone social, potential.

Today corporations are being challenged to rethink global strategies in which one-size-fits-all products are produced for the global market using world-scale production facilities and supply chains. Even so-called locally responsive strategies are often little more than pre-existing corporate solutions tailored to “fit” local markets: Technologies are frequently transferred from the corporate lab and applied in unfamiliar cultural and environmental settings; unmet needs in new markets are identified through demographic (secondary) data. The result is stillborn products and inappropriate business models that fail to effectively address real needs. As GE CEO Jeff Immelt recently noted, existing large corporations will be pre-empted by more nimble local players from the developing world unless they learn how to innovate from the ground up—what he calls “reverse innovation.”38

[wcm_restrict]Indeed, in response to the failure of traditional development assistance and large corporations’ inability to effectively address the needs of the poor, “social entrepreneurship” has burst onto the scene.39 Rather than innovating from within existing institutions, this new breed of change agent seeks to launch new enterprises that address directly the problems of poverty, inequity, and unsustainability. Led by organizations such as Ashoka and Grameen Bank, there are now thousands of such fledgling enterprises around the world, each seeking to develop the new strategies and business models needed to catalyze social change.

The past decade has also seen the emergence of a new brand of financier—the “patient capitalist.” Patient capitalists are not aid agencies or large corporations, but rather groups of investors and intermediaries focused on supporting small, high-impact entrepreneurs on the ground. This emerging sector includes groups such as the Acumen Fund, E+Co, Root Capital, Grassroots Business Fund, Intellicap, Microvest, New Ventures, and Technoserve. Taken together with the rapidly growing social investing, clean tech investing, and microfinance sectors, we are witnessing the birth of an entirely new industry—impact investing. Indeed, at the 2009 Clinton Global Initiative, the Global Impact Investing Network (GIIN) was announced as a vehicle for accelerating the development of this new financial sector.

Clearly then, the next challenge for large corporations will be learning how to become “indigenous” to the places in which they operate (see Exhibit 1.2). Doing so will require that they first widen the corporate bandwidth by admitting voices that have, up to now, been excluded; this means becoming radically transactive rather than just radically transparent. It will also entail the development of new “native” capabilities that enable a company to develop fully contextualized solutions to real problems in ways that respect local culture and natural diversity. When combined with multinational corporation’s (MNC) ability to provide technical resources, investment, and global learning, native capability can enable companies to become truly embedded in the local context. It was with this realization that I embarked on a new professional challenge in 2003, having accepted the Samuel C. Johnson Chair in Sustainable Global Enterprise at Cornell University’s Johnson School of Management. Our initiative at Cornell has spawned a new effort, the Base of the Pyramid Protocol, which seeks to develop a practical approach for becoming indigenous.

Unilever’s Indian subsidiary, Hindustan Lever Limited (recently changed to Hindustan Unilever Limited), provides an interesting glimpse of the development of native capabilities in its efforts to pioneer new markets among the rural poor.40 Hindustan Lever Limited (HLL) requires all employees in India to spend six weeks living in rural villages, actively seeks local consumer insights and preferences as it develops new products, and sources raw materials almost exclusively from local producers. The company also created an R&D center in rural India focused specifically on technology and product development to serve the needs of the poor. HLL uses a wide variety of local partners to distribute its products and also supports the efforts of these partners to build local capabilities. In addition, HLL provides opportunities and training to local entrepreneurs and actively experiments with new types of distribution, such as selling via local product demonstrations and village street theaters.

By developing local understanding, building local capacity, and encouraging a creative and flexible market development process, HLL has been able to generate substantial revenue and profits from operating in low-income markets. Today more than half of HLL’s revenue comes from customers at the base of the economic pyramid. Using the approach to product development, marketing, and distribution pioneered in rural India, Unilever has also been able to leverage a rapidly growing and profitable business focused on low-income markets in other parts of the developing world. Not surprisingly, Unilever has encountered challenges and bumps in the road in its journey to reach the base of the pyramid; these are discussed in later chapters. Importantly, however, through its strategy, the company has created tens of thousands of jobs, improved hygiene and quality of life for millions, and become a partner in development with the poor themselves.

The Road Ahead

To summarize, the greening initiatives of the late 1980s and early 1990s were revolutionary, if insufficient, steps: They repositioned social and environmental issues as profit-making opportunities rather than profit-spending obligations. More recent “beyond greening” strategies are even more significant: They hold the potential to reorient corporate portfolios around inherently clean technologies and create a more inclusive form of global capitalism that embraces the four billion poor at the base of the economic pyramid. If narrowly construed, however, such strategies still position MNCs as outsiders, alien to both the cultures and the ecosystems within which they do business. The challenge is for multinationals to move beyond “alien” strategies imposed from the outside to become truly indigenous to the places in which they operate. To do so will require companies to widen their corporate bandwidths and develop entirely new “native” capabilities that emphasize deep dialogue and local codevelopment. A more inclusive commerce thus requires innovation not just in technology, but also in business models, business processes, and mental frames.

Indeed, over the past ten years, “Clean Technology” and “Base of the Pyramid” strategies have exploded onto the scene, and social entrepreneurship has emerged as a new force for innovation. Each strategy provides important pieces to the sustainable enterprise puzzle: The former contributes “next generation” technologies with dramatically lower environmental impacts, and the latter creates innovative new ways to reach and include all of humanity in the capitalist dream. Yet each also comes with its own baggage and blind spots. Therefore, a crucial next step is to converge these strategies into what I call the “Green Leap.” Such a strategic convergence recognizes that clean technologies are almost always “disruptive” in character. (That is, they threaten incumbents in current served markets at the top of the pyramid.) As a result, the base of the pyramid might be the best place to focus initial commercialization attention. At the same time, the Green Leap approach also recognizes that successful strategies must be cocreated with communities and local partners so as to ensure cultural embeddedness, rather than imposing technological solutions from the top down.41

Given the urgency of both the need and opportunity described here, Cornell’s Center for Sustainable Global Enterprise launched the Cornell Global Forum on Sustainable Enterprise—an initiative to accelerate the rate of change toward this Great Convergence in the world. Indeed, nearly 100 of the world’s leading practitioners on the forefront of the “Green Leap” participated as delegates to explore entrepreneurial strategies for the growth and scaling of ventures in the “convergence zone.” The inaugural Global Forum was held in New York City, June 1–3, 2009, and the plan is to build this initiative into a growing global social network and an ongoing business movement.

Thus, as we enter the second decade of the new millennium, capitalism truly does stand at a crossroads. The old strategies of the industrial age are no longer viable. The time is now for the birth of a new, more inclusive form of commerce, one that lifts the entire human family while at the same time replenishing and restoring nature. The path to a sustainable world, however, will be anything but smooth. It will be a bumpy ride strewn with the remains of companies that variously dragged their feet, made promises they could not keep, bet on the wrong technology, collaborated with the wrong partners, and separated their social and business agendas. Only those companies with the right combination of vision, strategy, structure, capability, and audacity will succeed in what could be the most important transition period in the history of capitalism.

-This is part 3 of a 3 part series excerpted from Stuart L. Hart’s, Capitalism at the Crossroads (3rd Edition), published by Wharton School Publishing, an Imprint of Pearson.

Sources

  1. Jeffrey Immelt, Vijay Govindarajan, and Chris Trimble, “How GE Is Disrupting Itself,” Harvard Business Review, October 2009.
  2. See John Elkington and Pamela Hartigan, The Power of Unreasonable People, (Boston, MA: Harvard Business Press, 2008).
  3. Brian Ellison, Dasha Moller, and Miguel Angel Rodriguez, Hindustan Lever: Reinventing the Wheel (Barcelona, Spain: IESE Business School, 2003).
  4. Stuart Hart, “Taking the Green Leap,” Cornell University, Working Paper, 2009.

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About the Author

Stuart L. Hart, author of Capitalism at the Crossroads, is the Samuel C. Johnson Chair of Sustainable Global Enterprise and Professor of Management at Cornell University’s Johnson School of Management. Professor Hart is one of the world’s top authorities on the implications of sustainable development and environmentalism for business strategy. He has published over 50 papers and authored or edited five books. His article “Beyond Greening: Strategies for a Sustainable World” won the McKinsey Award for Best Article in the Harvard Business Review for 1997 and helped launch the movement for corporate sustainability. To read Stuart’s complete biography, click here.

Special Gift – Chat with the Experts™ Teleseminar with Jack Canfield, author of The Success Principles

On September 8, at 12:00 noon Central, America’s most sought-after workplace transformation expert, Roxanne Emmerich, will be interviewing Jack Canfield, America’s #1 Success Coach and co-creator of the bestselling series Chicken Soup for the Soul®. During the interview Roxanne and Jack will be discussing his book, The Success Principles: How to Get from Where You Are to Where You Want to Be. Co-authored with Janet Switzer, The Success Principles teaches you how to increase your confidence, tackle daily challenges, live with passion and purpose, and realize all your ambitions. Not merely a collection of good ideas, this book spells out the 64 timeless principles used by successful men and women throughout history. And the fundamentals are the same no matter what your profession or circumstances – even if you’re a student, stay-at-home mom or currently unemployed.

The Success Principles: How to Get from Where You Are to Where You Want to Be
by Jack Canfield
and Janet Switzer

 

The Success Principles is a roadmap for anyone-from marketing professionals to small business owners, and from teachers to students and parents — striving to achieve their professional and personal dreams and goals. Touching on every aspect of our lives, The Success Principles offers 64 practical and inspiring principles to get any aspiring person from where they are to where they want to be.

It’s an encyclopedia for mastering life… so you can achieve any dream, become who you want to be, and make your life exactly as you want it. This is one program you can’t leave out of your success library. The Success Principles contains all the key elements of a successful, happy life, together, in one place!

This is usually a private teleseminar for The Emmerich Group member clients. However, as a special gift to our audience, Roxanne is extending an invitation for StrategyDriven readers and listeners to participate in this information rich event. This is a great opportunity to bring your whole team together for a Lunch ‘n’ Learn or team learning opportunity.

Join Roxanne and Jack for the call on September 8, 2010 at 12:00 noon Central for one hour to discover:

  • How to get from where you are to where you want to be.
  • The biggest difference between people who are successful and those who aren’t.
  • How to change the outcome of any event, simply by changing your response to it.
  • Why you should drop out of the “Ain’t It Awful” Club and instead surround yourself with success, positive and nurturing people.
  • How to complete past projects, heal past relationships and process old hurts, so you can embrace the future.
  • How to ask for and get everything you want…from people who can give it to you.
  • How to deal with fear and uncertainty.

A teleseminar like this usually costs $500 – $1000 or more, depending on the size of your company. We are inviting you and your team for FREE as a special gift to prepare you for a better 2010 – regardless of the economy.

Registration is easy! To sign up, go to www.ThankGoditsMonday.com/jack-canfield.

Space is filling up quickly so be sure to sign up right away!

Clear your schedule and register TODAY!


About the Authors
 
Jack Canfield , originator of the Chicken Soup for the Soul® series and co-author of The Success Principles: How to Get from Where You Are to Where You Want to Be, has studied and reported on what makes successful people different. He knows what motivates them, what drives them, and what inspires them. Jack brings this critical insight to countless audiences internationally – sharing his success strategies in the media, with companies, universities and professional associations in over 20 countries around the world. To read Jack’s complete biography, click here.
 
Roxanne Emmerich, author of Thank God It’s Monday!, is President and CEO of the Emmerich Group. A member of the National Speakers Hall of Fame, she is listed by Sales and Marketing Management magazine as one of the 12 most requested speakers in the country for her ability to transform negative workplace performance and environments into “bring it on” results-oriented cultures. Roxanne has been featured hundreds of times in leading publications on topics such as leadership for results, employee engagement for bottom AND top-line improvement, profit-rich growth strategies, and a multitude of other workplace breakthrough issues. To read Roxanne’s full biography, click here.

The Secrets To Winning GSA Contracts

As a small business owner you may have heard of a General Services Administration Federal Supply Schedules contract, more commonly known as a “GSA contract”, but what is it exactly? How does it work? Is it difficult to obtain? Is it worth the time and effort to research, submit and manage?

[wcm_restrict]What is a “GSA Contract” anyway? Picture yourself on bended knee, proposing to the GSA. Tell them all about yourself….what you do, your terms and conditions, how the two of you will make a great team! As long as your proposal meets their standards they will award you a contract, as this is a non-competitive proposal. The GSA contract proves to a potential federal buyer that you are a responsible vendor.

Remember – a GSA contract is NO guarantee of sales. It has been compared to getting a hunting license – you still have to go out there and hunt for the sales, but now you have some legitimacy in the eyes of procurement officers. You have proven your willingness to dedicate time and resources to getting Approved Vendor status.

Minimum Sales Requirement: You will NOT be awarded a GSA Schedule contract unless the Contracting Officer estimates your sales will exceed $25,000 in the first 2 years and $25,000/year thereafter.

Patience and Perseverance: How long do you think it would take you to become a vendor of Wal-Mart or IBM or General Electric or any other Fortune 500 company? How hard would it be to get an appointment to make your sales pitch? How long would it take you to prepare the presentation? Fly to the corporate offices? How many more appointments would it take before you get any results?

The federal government is the biggest customer in the entire world for what you do. They have opened the door and asked you to make your presentation from the convenience of your office. They offer staff to assist you; they are fair and impartial; and you never have to take them to lunch!

Return on Investment (ROI). No doubt about it, a GSA Contract can be a wonderful opportunity, but you need to be aware of the investment of time and effort you need to make in order to submit, maintain and manage it. Remember, a GSA contract does NOT guarantee sales. If you make the effort to submit the proposal but do not subsequently work to market it, you risk making very few sales, and your time will have been wasted. Be prepared to do some initial research; find out if there is a demand for your products and services, and who your competition will be.[/wcm_restrict][wcm_nonmember]


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About the Author

Deborah Alston has worked for many years with small businesses, helping them with all aspects of federal government contracting. She has consulted with small businesses from many different industries, working closely with them to submit their GSA Schedule proposal; the Department of Defense’s ‘E-Mall’ proposal, and several other industry-specific federal procurement programs. In 2008, she co-authored the successful book Winning Government Contracts (Career Press 2008) with Malcolm Parvey. The book showed small businesses how to get involved in selling to the federal government, taking a step-by-step approach, and assuming no previous knowledge of this marketplace. In 2010, she partnered with Malcolm Parvey again to co-authored The Definitive Guide to Government Contracts (Career Press 2010) which included details on how to research, submit and maintain a GSA Schedule Contract award. Deborah can be reached at deborah.alston@dkagov.com.

Business Performance Assessment Program Warning Flag 3 – Conclusion Bias

Business performance assessments can be a powerful tool for determining the unknown drivers of performance; their effectiveness derived from the diverse knowledge and experience of the multidiscipline team and the vast amounts of information from causal evaluations, work performance observations, executive, manager, employee, and customer interviews, financial reports, independent analyst reports, performance measures, and condition reports leveraged to perform these assessments. So rich and robust are these assessments that their credibility often goes unchallenged, yet a single flaw in the business performance assessment’s initial execution can make this power tool for continuous improvement an instrument of disaster.[wcm_restrict plans=”47810, 25542, 25653″]

All too often, business performance assessments are used to prove the existence of a conclusion already reached by an organization’s leaders. Subsequently, they transform from a truly independent assessment into a fact gathering exercise. Assessment teams directed to evaluate the existence of a given condition often preferentially seek out those facts supporting such a conclusion; intentionally omitting or becoming unintentionally oblivious to those facts supporting a counter argument. Thus, the assessment’s outcome is known before it begins and the promise of a deep understanding of actual performance and drivers is forfeit. In these cases, if those commissioning the assessment are not fully correct in their understanding of the associated performance conditions then the assessment’s credibility may drive the organization in the wrong direction.

Intended or not, organization leaders specifically directing the performance of business performance assessments to validate a predefined position place at risk the realization of benefits derived from the knowledge of the organization’s actual performance and performance drivers. While not all inclusive, the four lists below, Process-Based Warning Flags, Process Execution Warning Flags – Behaviors, Potential, Observable Results, and Potential Causes, are designed to help organization leaders to recognize whether their self assessments focus on proving preconceived conclusions. Only after a problem is recognized and its causes identified can the needed actions be taken to move the organization toward improved performance.

Process-Based Warning Flags

  • Business performance assessment teams report directly to those organization leaders whose area of responsibility is being evaluated (lack of procedure directed independent oversight)
  • Business performance assessment process and/or forms call for the identification of conclusions to be focused on early in the process (Note: Identifying categorical areas of focus is acceptable.)

Process Execution Warning Flags – Behaviors

  • Executives and senior managers assign business performance assessments to provide the existence of a given condition
  • Business performance assessment leaders and teams actively seek to provide a palatable or desired answer to the organization’s leadership team
  • Business performance assessment interviews and fact finding activities tend to be narrowly focused on a those individuals and facts supporting a desired conclusion
  • Business performance assessment team members omit reviewing even significant occurrences that would counter a desired point of view deeming them irrelevant or an anomaly

Potential, Observable Results

  • Sustained poor performance when the true root causes of such performance goes unidentified
  • A failure to identify and transfer good performance practices from one part of the organization to another resulting in pockets of superior performance and the inability of other workgroups to achieve the same results
  • Overall forfeiture of performance potential; maintaining of the status quo and a lack of continuous improvement

Potential Causes

  • The organization has a ‘shoot the messenger’ culture when undesired performance outcomes are identified
  • The organization is highly leader driven such that the workforce to often seeks to please leaders; providing them with the information and conclusions they believe the leaders want to receive
  • A lack of training and understanding of the business performance assessment process and the principles behind performance of high quality, insightful assessments
  • Desire on the part of the leader commissioning the business performance assessment to use this tool as a method of mitigation or, in extreme cases, cover up personal performance shortfalls
  • An inappropriate expression of a leader’s desire to move the organization in a particular direction

Final Thought…

Business performance assessments seeking to prove a predetermined conclusion, particularly on that is negative, will appear to those whose performance evaluated as being grossly unfair. Subsequently, these individuals tend to resist the assessment’s conclusions even if they are based on solid facts and sound reasoning. This lack of buy-in results in a lack of support for the identified improvement initiatives. Worse still, the feelings of unfairness create disenfranchisement that drives lower productivity and possible attrition.[/wcm_restrict][wcm_nonmember plans=”47810, 25542, 25653″]


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StrategyDriven Editorial Perspective – Expanding Uncertainty in the U.S. Financial Sector, part 3

Major changes in any established regulation cause great uncertainty and the recent revisions made to the financial industry’s governance are no exception. Indeed, the law firm of Davis Polk & Wardwell estimates that 243 new rules will be developed by 11 different government agencies as a part of the Dodd-Frank Wall Street Reform and Consumer Protection Act.1 What is misleading, however, is the notion that the act focuses only on the financial services industry. In reality, this ‘financial reform’ represents a Washington power grab that extends far beyond the confines of Wall Street and will undoubtedly affect almost all Americans.

StrategyDriven questions whether these intrusions into non-financial sector areas will really help prevent future meltdowns like that which took place in 2008. The fact that other sectors are included simply broadens the span of government control and scope of market uncertainty which will further hinder economic recovery and growth as these other sectors must now also come to grips with the regulatory changes; changes that are not likely to be defined for years to come.

Service Providers

While StrategyDriven has already spoken out against the quota system enacted under Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, we have not yet discussed the breadth of organizations covered by this rule. Under this provision, Congress and the President extended the regulation not only to financial institutions but to the many organizations providing services to these institutions. Service organizations named within this section of the regulation include accountants and providers of legal services.2

The Dodd-Frank Wall Street Reform and Consumer Protection Act also increases the legal liability of service providers; assigning them vicarious liability for the legal wrongdoings of their regulated financial institution customers. Specifically, the act:

  • imposes vicarious liability on any service provider processing consumer financial transactions as ‘aiders and abettors’ for operational support in some cases
  • encourages employees of shared service centers and outsourcers to file claims of violation so that they can reap a bounty in an enforcement case
  • makes mere ‘recklessness’ the equivalent of a ‘knowing’ violation of 1) the Securities and Exchange Act of 1934, 2) the Investment Company Act, and 3) the Investment Advisers Act of 1940
  • extends the extraterritorial jurisdiction of U.S. courts in enforcement of U.S. securities laws3

Non-Depository Institutions

In its attempt to be all inclusive in financial matters, Congress and the President provided the Bureau of Consumer Financial Protection regulatory authority over non-depository organizations such as payday lenders, debt collectors, and consumer reporting agencies. In these cases, the Bureau is provided the authority to prevent unfair, deceptive, or abusive acts or practices although the Dodd-Frank Act is vague about what this actually means. The Bureau also has the authority to “require reports, conduct examinations, require certain record-keeping requirements, prescribe other rules to ensure that such entities are legitimate entities and are able to perform their obligations to consumers.”4

It is of particular interest to note that several non-depository institutions and activities having at least an equally significant financial impact to consumers were expressly excluded from this regulatory oversight including real estate brokerage activities, accountants, and tax preparers.5

Publicly Traded Companies

Congress and the President reached far beyond the financial sector with the executive compensation regulations contained within the Dodd-Frank Wall Street Reform and Consumer Protection Act. Many of these provisions appear to continue the Obama Administration’s challenge to the fairness of executive compensation. New rules regarding executive compensation include:

  • Say-on-Pay
  • Compensation Committee Adviser Independence
  • Compensation Committee Member Independence
  • Pay Disparity Disclosure
  • Pay versus Performance
  • Clawback6

It goes without saying that greater transparency contributes to greater accountability and that is a good thing. However, StrategyDriven questions whether employees in general or members of Congress and the President would themselves be willing to be held to these standards; particularly the say-on-pay, pay versus performance, and clawback provisions. It is also worth noting that no provisions of the Dodd-Frank Act directly address the awarding of large ‘golden parachute’ payouts to failed executives upon their departure.

StrategyDriven Recommended Practices

The significant marketplace uncertainty created by the Dodd-Frank Wall Street Reform and Consumer Protection Act will not end anytime soon – the need to define 243 new rules will see to that. It is clear the impact of this law extends well beyond the boundaries of Wall Street and that it is important for all company leaders to understand how their organization may be affected. In addition to our previously recommended actions, StrategyDriven suggests organization leaders:

  • Assess the new and heightened liabilities and administrative costs associated with their financial industry work against the rewards resulting from this work, particularly if they are service providers to the financial services industry; making adjustments to their businesses as appropriate.
  • Consider how the new executive compensation provisions will impact the organization’s ability to attract and retain top executive talent.
  • Evaluate the need to adjust the compensation structure of the entire executive team and potentially that of all employees in order to maintain overall equity and balance given the new executive compensation rules.

Final Thoughts…

While the purpose of this editorial was to focus on the non-financial sector institutions included in the so-called ‘financial reform’ act we would be remiss for not identifying the unconscionable absence of Fannie Mae and Freddie Mac from this legislation. These two institutions played such a significant role in the financial collapse of 2008 that it is unreasonable to think Washington politicians wouldn’t conclude that some change in the regulation of these mortgage giants was needed. The fact that payday lenders and debt collectors are included in the Dodd-Frank Act and Fannie and Freddie excluded from meaningful regulatory change (Fannie and Freddie received two minor mentions in the 1,500 page Dodd-Frank Act)7 suggests Congress and the President are either not serious about preventing a future financial system meltdown or had their interests better served by the omission. Either way, the American public lost in this deal – $135 billion in outstanding debt to the American taxpayer as of this editorial’s publication.8

In the coming editions of the StrategyDriven Editorial Perspective, we’ll look at the potential impacts of several provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act including:

  • impacts of ‘too large to fail’ provisions on market risk
  • proportionately larger burden of the new law on small companies

As always, we’ll provide our thoughts on how business leaders can best prepare for the implementation of the financial reform law and weather the storm in the long-term. We also hope you’ll share your thoughts, lessons learned, and recommended resources with us and the StrategyDriven audience.

Final Request…

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Sources

  1. “Summary of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Enacted into Law on July 21, 2010,” Davis Polk & Wardwell LLP, July 21, 2010 (http://www.davispolk.com/files/Publication/efb94428-9911-4472-b5dd-006e9c6185bb/Presentation/PublicationAttachment/efd835f6-2014-4a48-832d-00aa2a4e3fdd/070910_Financial_Reform_Summary.pdf)
  2. “Racial quotas as financial services reform?,” Horace Cooper, The Washington Times, July 15, 2010 (http://www.washingtontimes.com/blog/watercooler/2010/jul/15/racial-quotas-financial-services-reform/)
  3. “Dodd-Frank Financial Reform: New “Systemic Risks” for the BPO Industry,” Bierce & Kenerson, P.C., Outsourcing Law, July 30, 2010 (http://www.outsourcing-law.com/2010/07/dodd-frank-new-risks-for-bpo/)
  4. “Dodd-Frank Wall Street Reform and Consumer Protection Act – Scope of Coverage of the Bureau of Consumer Financial Protection,” Kilpatrick Stockton LLP, August 6, 2010 (http://www.kilpatrickstockton.com/en/Knowledge%20Center/Alerts%20and%20Podcasts/Legal%20Alerts/2010/08/Dodd%20Frank%20Wall%20Street%20Reform%20and%20Consumer%20Protection%20Act%20Scope%20of%20Coverage.aspx)
  5. ibid
  6. “Some Dodd-Frank Executive Compensation Action Items,” Jeremy L. Goldstein, Wachtell, Lipton, Rosen & Katz, The Harvard Law School Forum on Corporate Governance and Financial Regulation, August 12, 2010 (http://blogs.law.harvard.edu/corpgov/2010/08/12/some-dodd-frank-executive-compensation-action-items/)
  7. “Housing Policy’s Third Rail,” Gretchen Morgenson, The New York Times, August 7, 2010 (http://www.nytimes.com/2010/08/08/business/08gret.html?_r=1)
  8. “Bailout Recipients,” ProPublica, August 22, 2010 (http://bailout.propublica.org/list/index)

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