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I have another suggestion for the Systemic Bill. Someone should demand language, or file an amendment, that states:

‘Directors, Officers, senior management and consultants of any institution that draws on the industry funds created under this title or receives any relief or is subject to any other actions provided for under this Title shall, for a period of 5 years after such relief or support, be prohibited from becoming employed as Director, officer, senior manager or consultant at any regulated institution or an affiliated holding company or operating subsidiary’.

The Board should attest that they have no directors, employees, consultants in violation of this and regulators should issue a PCA letter if one is in violation.

Regulators should use PCA

1- it would cause greater focus and concentration on risk management and best practices.

2- it would cause whistle blower directors and silent objectors management to step down. This is a good thing and will drive investors to differentiate well managed firms from those who lose people and would force regulators to be aware of problem institutions.

3- Well run institutions to have a larger pool of potential quality officers and management to hire and those management would be rewarded with reputational advantage and renumenration.