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- 投稿者: ゲスト 投稿日時: 2015/7/3 16:08:24
- "The insufficient coordination between government agencies has also been a cause of concern for IPAs."While global and regional competition for FDI share has presented problems, it has also improved servicing and decreased bureaucracy. Other issues surrounding funding and coordination with agencies, however, need to be actively tackled. Remedial measures taken thus far include increased collaboration with local FDI players to reduce costs, and efforts to involve IPAs in all strategic government economic engagements."IPAs must consistently act as one stop shops, providing all forms of pre to post investment assistance to the investor," concludes Strategic Partnerships Director Iain Jawad.Federal preemption, lack of oversightAs outlined in my testimony, the states have been aggressive in their pursuit of predatory lenders in the lead up to the crisis and beyond. But our efforts increasingly placed us at odds with our counterparts in Washington. The dual forces of federal preemption and a lack of oversight at the federal level have progressively hamstrung state enforcement actions. In the last decade the OCC, which regulates the nation's largest banks, issued a series of rules that sought to prohibit states from enforcing a number of laws including predatory lending statutes against nationally chartered banks and even their non bank subsidiaries. The OCC's push came at a time when robust consumer protection, on both the state and federal levels, was needed more than ever: Subprime lending was growing at an exponential rate, and riskier and riskier loan products were beginning to flood the marketplace. What may seem like a case of unfortunate timing was no coincidence at all. The expansion of federal preemption was the product of a symbiotic relationship that benefited regulators and lenders alike. The OCC even emphasized preemption as an appealing reason for lenders to convert to a national charter. By attracting more fee paying lenders, the OCC generated more revenues for their operating budget.