North Carolina Adopts Customary And Reasonable Fee Guidance Document

[Michigan CG]

Many smaller and mid-size AMC's may do that due to the expertise and expense involved in documented compliance under presumption 1. However, I will bet that the big AMC's will use presumption 1 because they will make a higher profit and be more competitive that way, which will put the smaller to mid-AMC's under more pressure. Like is often the case, regulation helps the big boys at the expense of their smaller competition and will likely lead to more consolidation within the AMC space.

And that is that typical result of people trying (and succeeding) to pass laws to manipulate the free market. The unintended results are typically just the opposite of the intentions.

 

[Meandering]

And that is that typical result of people trying (and succeeding) to pass laws to manipulate the free market. The unintended results are typically just the opposite of the intentions.

What TimD refers to are not laws,
They are federal rules,
which were written by the joint agencies,
Not Congress.

So,
the only "people trying" are
wannabe's like Joan,
and other lobbyists.

"The people" have no input, other than responding to a request for comments as published in the Federal Registry.


,

 

[timd354]

What TimD refers to are not laws,
They are federal rules,
which were written by the joint agencies,
Not Congress.

So,
the only "people trying" are
wannabe's like Joan,
and other lobbyists.

"The people" have no input, other than responding to a request for comments as published in the Federal Registry.


,

Marion, I know that you don't like Joan, but Joan has complained to everyone (including the regulators) that she thinks that presumption 1 is an incorrect interpretation of the law and does not comply with the statute. Instead of lobbying for presumption 1, Joan has actually lobbied against it despite having many AMC's who are a member of her CRN organization.

 

[Amy Perkins]

"guidance," what a joke!

 

[Eli]

Many smaller and mid-size AMC's may do that due to the expertise and expense involved in documenting compliance under presumption 1. However, I will bet that the big AMC's will use presumption 1 because they will make a higher profit and be more competitive that way, which will put the smaller to mid-AMC's under more pressure. Like is often the case, regulation helps the big boys at the expense of their smaller competition and will likely lead to more consolidation within the AMC space.

Yeah and where are the AMCs going to pull stuff for presumption 1? Out of their ***? Lol

 

[Meandering]

Marion, I know that you don't like Joan, but Joan has complained to everyone (including the regulators) that she thinks that presumption 1 is an incorrect interpretation of the law and does not comply with the statute. Instead of lobbying for presumption 1, Joan has actually lobbied against it despite having many AMC's who are a member of her CRN organization.

When did I say I don't like Joan?

I was referring to her Ex Parte communications with the cfpb that are posted on line.

And that was a valid response to Mich's comment that people were trying to pass laws.

Don't blame me if no one explained to Mich that the profession exists because of laws, and not because of the free market,
and don't blame me that Joan has put forth Ex Parte communications after the comment periods.

And I have been very nice to Joan for well over a year now.

.

.

 

[Meandering]

And I was nice to Joan for longer than that.


.

 

[Meandering]

Yeah and where are the AMCs going to pull stuff for presumption 1? Out of their ***? Lol

Well that's their problem, isn't it?

.

 

[EddieB]

When did I say I don't like Joan?

And I have been very nice to Joan for well over a year now.

Love it

It really should not be difficult to change presumption 1. But we all know, including Tim and Joan, why it hasn't

 

[timd354]

Love it

It really should not be difficult to change presumption 1. But we all know, including Tim and Joan, why it hasn't

Well now that presumption 1 it has been written into the regulations for several years and is part of the IFR, it would be extremely, extremely difficult difficult to change. I doubt that it will ever change unless the underlying statute is re-written or abolished.