Risk Rap

Rapping About a World at Risk

The Forth Estate Crosses Over

There is this program that runs on the WE Cable Network.  It’s called Crossing Over with Jonathan Edwards.   Jonathan Edwards is a psychic medium.  He stands in front of a live gathering of 75 people and tunes into psychic vibes emanating through the audience.  The vibes are messages from deceased loved ones who have crossed over the Acheron.  The dead are keen to communicate warnings, good wishes and assurances to assist living  loved ones on how to navigate the tricky vicissitudes of life.   During the show, Jonathan walks about the room picking up on celestial chatter and begins to relay and interpret a soliloquy of the dead like a macabre game of supernatural telephone. Jonathan Edwards asks his audience to suspend all disbelief as he bestrides the nexus of the metaphysical spirit world and the pedestrian reality that most earthlings inhabit.

The most common messages the dead channel through Jonathan seek to absolve the anxiety and guilt of the tormented living.  Crossing Over is popular because it offers its audience an  absolution, confirms personal cosmology and rationalizes the pursuit of desires by affirming the consequences of decisions as a self fulfilling prophecy.  It safely places its audience in a self validating cosmic echo chamber.  Its an ongoing morality tale with only happy endings and unfortunately only a tenuous connection to authenticity and objective truth.

The state of the news media industry is very much like Crossing Over.  The Forth Estate once thought of as an objective arbiter, information dispersant and truth seeking medium it is now chosen and consumed as a branded version of reality.

The devastating earthquake that buried Haitians in heaps of rubble unleashed global battalions of news teams to cover the event.  Many of the news crews from large established networks beat first responders to the scene.  In some cases the arrival of news teams actually held up the arrival of rescue teams and supplies because the airfield and crowed airspace could not accommodate all the traffic.  The news teams were forced to hole up at the airport because blocked roads prohibited them from going anywhere.  I recall Robin Roberts and the GMA News team dodging fork lifts and supply trucks left with nothing more to do then to urgently interview themselves.  Correspondents were reduced to ghoulishly opining about the tragedy while eagerly mugging for the cameras with contorted faces to portray the human tragedy unfolding beyond the range of their cameras.

GMA’s presence added nothing and in fact inhibited rescue efforts.  I thought of all the drinkable water these crews consumed could have been used to quench the thirst of Haitians dying from dehydration. Thankfully the GMA News team soon left after spending a self indulgent weekend at the airport. Their moral outrage registered and attempt at ratings grab accomplished.  Their contribution to shedding light on the scope of this tragedy and placing it in a larger context of its meaning to the global community of nations was lost in deference to the tragedy’s emotional impact on GMA reporters.  For GMA the subjective condition of the emotional distress of their media stars had become the story.   Their viewers must have figured that if GMA’s News celebrities were hurting this story must be big.

CNN’s Dr. Sanjay Gupta was an example of how a newsman became part of the story in a positive way.  I recall with great admiration watching a camera crew following Dr. Gupta as he walked amidst the rubble of Port-Au-Prince.  He learned of the location of a hospital and went to investigate how it was delivering services to the injured.  Upon his arrival Dr. Gupta discovered the make shift hospital was little more then injured people being placed in the hallway of a building.  The dead were being stacked outside by a wall surrounding the compound.  The hospital had no doctors, nurses, beds or supplies.  The facility lacked water to clean wounds or salve thirst.  What the hospital did have was a constant stream of wounded arriving in greater numbers desperate for any type of care.  The scale of the quake, the massive amounts of injured victims and the overwhelmed capacity of  the hospitals ability to respond was reported in stark clarity.

Dr. Gupta was overwhelmed by parents cradling their broken children.  Dr. Gupta a licensed medical doctor took off his correspondent hat and put on his stethoscope.  He honored his Hippocratic Oath and started treating babies and the wounded with whatever he could cobble together.  Dr. Gupta was no longer a journalist but was now a doctor.  He asked that the cameras stop rolling so he could perform his duties as a doctor.  I’ll never forget the look on Dr. Gupta’s face.  It spoke volumes about the desperate conditions he was confronting and the firm resolve that he would perform his duties as a trained physician under trying almost impossible circumstances.

We could understand Dr. Gupta’s crossover from journalist to doctor.  It was proper and correct response as a human being but as a journalist all objectivity had been lost and in many respects Dr. Gupta had become the story in a constellation of a million stories emanating from the epicenter of one of the great human tragedies of the past century.  This is a departure from the norm of real time documentary reportage.  I can’t tell you how many documentaries I came away from cursing the producers and cameramen for doing nothing to prevent the baby wildebeest from being  consumed by the lion pack or for failing to offer a family of refugees in Darfur a bottle of water or a ride on their jeep to escape the marauding  Janjaweed.

News Corps, network media division Fox News belies the myth of the monolithic liberal mainstream media and its claim of balance in its marketing handle.   Fox News may offer a fair presentment of the news to its conservative viewership but its claim of balance that suggests the inclusion of a liberal perspective in their news product is specious.

Fox News really came of age following 9/11 and the growing conservative drift of the nation. Its useless to posit weather Fox News created the conservative drift or developed programming to market to this political demographic; but the political inclinations of Roger Ailes and Rupert Murdoch have always been decidedly conservative.  At its founding in 1996, Fox News started differentiating itself from the liberal mainstream media by supporting the Republican impeachment drive of President Clinton, effectively  setting the stage for its partisan approach to reporting the news.  In many respects its unabashed partisanship was a game changer in how news and information was being packaged, positioned and delivered in the emerging narrow casting market paradigm.   Its sentiment not very different from the golden days of yellow journalism practiced by William Randolph Hearst.

Liberals and progressives have criticized News Corp for its lack of objectivity and  balance.  Many believe it to be the official party organ of the Republican Party and its compromised coverage is more akin to propaganda then news.  I believe this to be true as well.  Fox News has countered that it provides both news and opinion.  Fox News employs many of the leading conservative voices.  Karl Rove, Sarah Palin, Mike Huckabee are senior GOP members on the payroll of Fox News.  They regularly appear on shows hosted by Bill O’Reilly, Glenn Beck and Sean Hannity who are conservative celebrities in their own right.  The trick is discerning what is news and what constitutes opinion and editorial content.  The line that demarcates them is increasingly a fine one.  Even the innocuous news blurbs scrolling along the bottom of the TV screen seep in partisanship.  Some may report objective facts like the closing level of the Dow or the latest sports score. These little factoids appear alongside pieces that consistently reinforce the conservative credo of the network.  Its also a practice for commentators like Karl Rove to opine on stories covered on news segments.  The pundits impassioned analysis of the story leaves the listener little room to doubt the interpretation as a validation of the viewers conservative  political sentiments and ideological disposition.  The ability to distinguish fact from opinion becomes increasingly lost in these clouds of obfuscation.

As the model of creating, packaging and marketing partisan news the advent of Glenn Beck as a political entertainer is symptomatic of the maturation of the industry.  Glenn Beck’s show is more of a political reeducation camp that tries to provide low information voters and political neophytes with a more robust framework to understand the history and philosophy of conservatism.  Beck extends the Fox News portfolio of infotainment products.

Beck’s role in encouraging the formation of the Tea Party expands the footprint of News Corp.  Some may consider this crosses the line into political activism but I believe it to be a highly developed form of call and response direct marketing.  Beck’s incessant rants about the imminent collapse of  American democracy, the downfall of free market capitalism and the advocacy of the purchase of gold to hedge against these terrible prospects has attracted  the sponsorship of gold marketers and other fear merchants living large and minting major coin in the time of terror.

Fox is not alone in this sin.  CNBC profited from the pre-crash market run-up and had a vested interest in fueling market speculation and excess.  The business channel owned and operated by NBC  took some heat on this issue in the wake of the market meltdown.  During the market run-ups and the creation of the numerous market bubbles CNBC was taken to task for its roll as a biased shill in creating a risk averse mania that fed into the speculative orgy.  The encouragement of reckless behavior would cost investors and Main Street citizens a good portion of their retirement savings.  Jon Stewart took on CNBC celebrity Jim Cramer for his role in stoking unhealthy speculation. The claim of caveat emptor is not a sufficient disclaimer to absolve CNBC of this perceived wrong doing.  Information and data is the fuel that powers the capital market engine and viewers perceived CNBC to be a critical channel for this type of decision support data and analysis.  As animated red bulls flashed across the TV screen screaming “buy buy buy” the speculative urge feeding the demon greed of Cramer’s viewers jumped at the prospect to secure easy profits and pushed the execute button to route a flood of orders to E-Trade.

Media outlets were not alone in profiting from the conflict of interest in their business model.  The rating agencies Moody’s, Standard and Poors and other issuers of financial health assessments were roundly criticized for a business model that accepted fees from companies  to determine their investment ratings investors use to judge safety and soundness of the companies securities.  Investment banking institutions like Goldman Sachs and Morgan Stanley ran into trouble for trading securities that they advised their clients to hold in investment portfolios.  Large commercial banks have also been called on the carpet for the inherent conflict of interest in their mortgage lending business that integrated mortgage underwriters, originators, servicers, securitizers and investors under a single roof.

Citizens United vs. Federal Election Commission has given corporations a megaphone to direct enormous amounts of capital and influence on Americas political culture.  The exponential growth of the political industrial complex places media companies on the cusp of an emerging market.  News Corp occupies a well defined franchise in the vortex of this growth industry.  News Corp will be the predominant media channel attracting politically sponsored advertising from 527 corporations to advocate issues central to the conservative agenda.  The market for political theater is strong and growing and News Corp has one of the hottest theatrical properties in celebrities like Sarah Palin and Glenn Beck.

If Fox News bends and packages information with selected editing in support of political narrative; Andrew “NAACP” Breitbart and James “ACORN” O’Keefe edits news to create a false narrative to affirm ideology.  The omnipresent  multi-channel digital world and the need for consistent real time affirmation justifies entrapment and libel as fair game in the political narrative. The specious political ethics of radical entitlement, means justify ends, medium is the message and relativistic ethics is the next step of  an ideologically mature ,technologically enabled infotainment industry.  The self affirming echo chamber that verifies fact and swears to any truth is blessed with selective amnesia and a self correcting mechanism of  a highly refined subjective fact checker informed by extreme prejudice.

Jon Stewart  use of satire and exaggeration to make a lager point of clarified and reified truth is old school stuff.  In the Age of the Avatar,  the real, the imagined, the intended and the manifested get confused in the digital clouds of form, delivery and content. The medium is the message, the network is the computer and Jon Stewart’s Rally to Restore Sanity was a marketing event to stake a claim on the market of moderation.  No doubt a highly educated discerning market segment with lots of disposable income.  Its only downside its getting a little long in the tooth.

The Forth Estate is rapidly evolving due the dramatic changes in technology, market structure, business model and consumer consciousness.  The role of the free press and the constitutional protections it enjoys in a democratic society is under siege and on the verge of bankruptcy.  The New York Times, Chicago Tribune and LA Times are old media institutions struggling to stay financially solvent and culturally pertinent.  Time will tell of their ability to evolve and create a sustainable business model  that will be validated by a market economy.  We have learned that truth, disclosure and transparency are not priceless assets but virtues that must support a sufficient  p/e ratio to to survive in a capitalist economy.

The past few weeks we’ve had a few First Amendment martyrs.  Rick Sanchez, Juan Williams and Keith Olbermann learned that the sword was more powerful then the pen.  The more important lesson that managers could remove them on the whim of executive fiat if they failed to demonstrate restraint of pen and tongue.  In actuality the  removal of these gentlemen from the news desk was more of a business decision then a violation of  their right of Free Speech.

As we enter the second decade of our two wars on terrorism even the embedded journalists rolling through the distressed hamlets of Iraq and Afghanistan are getting a bit war weary.  Like a captive hostage the embeds could not help but to identify with their chauffeurs.  The brave soldiers driving the Humvees’ were always in control of what the embeds saw, was responsible for their safety and quickly became the reporters best friend born of dependency, admiration and the comradeship that develops during war.  Objective reportage was the first causality in this  type of arrangement.

We need to take a cue from Jonathan Edwards.  He is the real shaman of our time.  Blessed with unique skills to help his audience to realize that self affirming connection is only possible by crossing over and taking suggestions from the well placed authorities residing in an unseen mysterious supernatural world.

You Tube Music Video: Tom Waits, Lie to Me

Risk: First Amendment, free speech

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November 12, 2010 Posted by | 9/11, banking, branding, business, Clinton, commercial, commodities, culture, democracy, democrats, economics, elections, government, history, investments, marketing, media, news, philosophy, politics, product, regulatory, sustainability, Tea Party, war | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Toward A New Iconoclasm

Its good to be the King.  When King James ruled England at the dawn of the 17th Century he authored a doctrine of the Divine Right of Kings.  He likened his position as “little Gods on Earth”, who were chosen by Divine Providence to rule and to make the rules.

The current incarnation of King James, in the form of Lebron James also assumes the form of a Little God.  Since the announcement of his free agency status, His Highness has captured the imagination of sports fans, entertainment moguls, broadcast network executives, local businessmen, political leaders and product marketing pros keen to see how the hottest entertainment property in sports maximizes its value by casting his bread upon the waters of free market capitalism.

This marketing juggernaut held the hopes of major metropolitan areas hostage to the idea that King James may anoint their humble cities by moving his throne to one of  their majestic sports palaces.  The hope is that King James and supporting cast will bring an NBA crown to the impoverished masses starved to eat the championship crumbs that fall from His Highness’s banquet table.  It is believed that the Court of King James will establish a home court dynasty, erecting the preeminent Kingdom that will rule over all the lesser fiefdoms of the NBA.

Five cities planned coronation ceremonies for King James but only one city would be able to taste the bread of champions his rule would surely bring to his new kingdom.  That would leave four other cities wanting; condemning them to suffer the hunger of unfulfilled championship dreams they believe only King James can bring to their metropolis.  King James commanded an hour of air time on ESPN to make his royal decree that he would accept Miami’s urgent petition and join The Heat.   King James’ former kingdom, Cleveland suffered the worst of it.  The abdication of their beloved King has shocked this secondary market hamlet into a deep examination of self worth, prompting the fear of deepening economic malaise and a self loathing brought to the surface by the painful rejection by their home town deity.

In a broader sense we should all learn from Cleveland’s experience.  The connection between a human commodity and its consumer is always a tenuous and short lived relationship.  If the consumer can afford the price,  a human commodity will bestow its attention with fealty and reciprocated affection.  America is a highly developed market of  culture consumers.  We invest a great amount of economic and  psychological capital into relationships with media stars, entertainment products and sports heroes.  We confer a royal status upon them.  Our veneration is measured in dollars spent and emotional capital invested.  We believe them to be sacred icons.  Our gleeful consumption of these identity product brands contort and warp our souls.  We begin to believe that they are part of us and construct an existential fantasy that these product brands are actually connected to us.  The sex appeal of Lady GaGa’s consumer fetishism, the nobility of  Sarah Palin’s political opportunism and the dominating machismo of LeBron James supra athleticism are powerful branding conventions.   This radical branding, the brainchild of  handlers and marketing professionals is solely employed to maximize brand value and to move the goods of Me Inc. into the heads and hands of frenzied consumers desperate for an existential connection with something greater then themselves.  The fickleness of consumer capitalism is wholly agnostic.  It never really loves you back.  As a matter of fact it doesn’t love you at all.  Its a cold calculated manufactured creature designed to suggest that its sore purpose in life is to return the love that its user abundantly confers to it. Yet it lasts only until the money runs out.  Its pimp requires these deft street walkers to move on to a new corner where the tricks are more plentiful and bucks much greener.  Ironically free agency begets another type of slavery.  The free agent is shackled to the ball and chain of transactional capitalism.  The soul of the person becomes indistinguishable from that of a soulless corporate entity.  This coalesces perfectly with the Supreme Courts decision to confer the same rights and privileges to corporate entities to finance political candidates.  More and more creeping corporatism is rationalized throughout the body politic as the real bodies and persona’s of persons morph into corporate entities.

The disease is growing too.  In the 3D digital age we deepen these faux connections to our heroes with homey Tweets, real time TMZ coverage, and a befriended status on Facebook.  We get full access to the royal court.  A total submersion within the gone viral digital version of our hero’s carefully constructed virtual world.  We are knighted by the King’s courtesans and receive special discount coupons redeemable at our icon of choice company store.   This special befriended status is good as gold as long as the balance on our credit card doesn’t exceed it limit.

A few years ago Bishop Mark Beckwith delivered a homily on the meaning of icons.   Bishop Beckwith stated that icons were intended to be a prayer aid.  A type of tool constructed of transparent materials so light can filter through them.  This light would reveal an immutable truth  conveyed by the icons subject.  It would remind the prayerful person to emulate the qualities of the figure depicted in the icon.   But that purpose changed and icons came to be understood as objects of  veneration that are endowed with special powers.  Kings and Czars commissioned their finest artisans to create beautiful iconic objects depicting the monarch in communion with saints or apostles to reinforce the idea that divine providence has anointed them to rule the realm.  The common folk and the peasantry would prostrate themselves before the venerated object as the very real presence of a divine sovereign and dutifully pray to it.  A radical transformation occurred and we venerated the object and not the meaning the object was meant to convey.

Thirteen Hundred years ago in Byzantine Constantinople, iconoclasts rose up to smash the graven images of icons within their places of worship.  The icons became venerated objects of debilitating dogma used to control and manipulate people.  We  need to destroy the icons that manipulate and control us.  We must claim back our lives and begin to live more richly and freely by understanding ourselves not as a consumer of things but as a participating person fully engaged in a life that affirms self and service to others.

You Tube Music: Def Jam Icon : Redman vs. Ludacris

Risk; consumer capitalism, alienation, hero worship

 

 

July 11, 2010 Posted by | branding, commodities, culture, marketing, product, psychology, reputation, sports | , , , , , , , , , , , , , , , , | 1 Comment

Healing the Breach: An Essay on Sound Practices for Fund Managers

…“the “money-management business” (with its plethora of mutual funds, investment counseling firms, and hedge funds) has so many practitioners who’ve grown up in an era where it’s all been about marketing and not risk management,…” “If 2004 goes bad, it will go really bad “ Bill Fleckenstein Contrarian Chronicle

This candid remark is an astonishing observation. The assertion that money management is more about marketing then risk management is a bit disconcerting. The most recent Security Exchange Commission’s (SEC) announcement concerning its investigations of brokerage firms for receiving commission payment premium’s by asset management firms for directing investors into purchases of preferred mutual funds is the latest example of how this statement is a tragic reality for investment product consumers.

We live in the era of radical capitalism. It is characterized by fierce political pronouncements of the sanctity of laissez-faire principles and the ultra aggressive pursuit of free markets, resulting in the increased rationalization of the market mechanism into our culture and daily lives. For many readers this statement is not surprising or profound. Marketing is king, and if you have any doubts about it, try locating a music station in New York City that is not wed to a Top 40 play list or Talk Radio format.

However, as this Milton Friedman vision of utopia continues its inexorable march of rationalization, a strange alchemy is taking place. As businesses damn the torpedoes to pursue markets, ethical business practices and sound corporate governance principles are being sacrificed at the alter of EBITDA, ROE, P/E’s and the Holy of Holies those sacred stock options. The ironic twist to all this is that these aggressive business practices defended on the grounds that they enhance shareholders value are actually seriously eroding the values of brands, profit margins and market capitalizations. Ask a shareholder of Enron, Parmalat or WorldCom about the clever corporate stewardship of these company’s former management teams and you’ll get a resounding thumbs down.

But there is something deeper going on here. When investors entrust their money to an investment manager, they may be attracted to the sizzle (remember past performance is not indicative of anything) but what they want is still the steak. Investors want an investment manager that can understand their investment goals and risk tolerance and provide them with an investment vehicle that can balance that risk tolerance with the capability of realizing an expected return. The act of giving a manager discretionary power over an individuals retirement fund, a union’s pension portfolio, a family office or child’s educational financing vehicle is a tremendous act of faith that requires an extraordinary degree of confidence in the manager’s ability to provide an acceptable return, but to also be a trusted fiduciary that has the requisite operational support and controls in place that will safeguard and honestly seek to grow and protect an investors capital.

Mr. Fleckenstein’s assertion that risk management has taken a back seat to marketing and product placement is unfortunately an accurate assertion. The financial services industry is unique in the sense that it is the loam of all capitalist constructs. Yet as a business, financial services companies are no different from any other economic enterprise. All companies create products and differentiate themselves through the value proposition incorporated into their product. Intrinsic to the product creation process is a determination of the type of materials that will form its composition. A conscious decision is made as to how the product will be positioned and marketed, its performance metrics determined, customer service resources required to support the product as consumers use it and how it will be distributed. Once those variables have been determined, a profit margin is added and a value proposition to potential customers is conveyed. The value proposition that is communicated to consumers comes to be known and identified as the product brand. An investment product is designed to essentially address current and future financing requirements and the risk profile of the consumer are central to the design and purpose of the product. That is why this bifurcation is so dangerous. It undermines the inherent purpose of the investment product and should more truthfully be marketed as a product that enriches the commission merchant that may over a specified period of time garner a return for the investor. Think about all the Enron employees who had their 401k’s invested entirely in Enron stock.

This is probably the most significant point and primal differentiator of companies that manufacture financial products with that of companies that manufacture consumer durables. Financial products facilitate the flow of capital through the markets. It feeds the invisible hand that guides and directs all economic activity. If the flow of financial products is impeded, or abates due to consumers lack of confidence, a consumer driven economy like that of the United States will suffer greatly. Foreign governments and institutions buy US Government bills, bonds and notes because of the well-earned confidence they have in Uncle Sam’s stable currency and it’s ability to pay it’s debt and provide a fair return to all note holders. However if that confidence goes away, Uncle Sam will have to curtail its deficit spending, raise taxes on its people and enter into other messy measures to remain economically viable. Confidence is a lovely thing both for nations and companies and once that confidence is lost it is a difficult, if not an impossible thing to regain. Confidence is the basis of risk management. Credit risk and rates of return, the key variables of risk management, all start with the certainty of confidence.

Yes, from an investment performance point of view 2003 was a terrific year. All major equity indices were up. Thanks in large part to a federal tax rebate program the US economy grew by 8% during the 3rd quarter, prompting Mr. Greenspan to proclaim with a certain degree of confidence that the recession had ended. Yet from corporate governance, business confidence point of view, 2003 business news makes the turn of the century robber barons look like acolytes of Mother Teresa. To restore confidence investment managers need to develop a Sound Practice program that will repair the breech and bridge the bifurcation of marketing and risk management within the investment management enterprise. Lets turn our focus on how and why this bifurcation must be bridged.

Sound Practices Builds Confidence

The explosive growth of the global hedge fund industry and the important role it plays in providing market liquidity and as an alternative asset class for high net worth investors and institutions is increasingly placing the industry in the global spotlight and many regulators, interest groups and institutional consumers are demanding greater transparency and advocating increased oversight and government regulation.

The Long Term Capital Management debacle, George Soros’s unilateral assault on and profitable dismantling of the Pre-Euro Exchange Rate Mechanism, numerous hedge fund blow-ups through poor management controls or outright fraud, and the most recent disclosure of the widespread collusion of hedge fund arbitrageurs and mutual fund managers to conduct market timing trading, is seriously eroding investor confidence in financial institutions. This is creating a political climate favorable to enhanced regulation and oversight of financial institutions. The recent investigative actions of New York State Attorney General Elliot Spitzer, and the appointment of William H. Donaldson to head the SEC are clearly political responses to the crisis in corporate governance and regulatory malfeasance.

At last count, there are approximately 20,000 companies engaged in investment management within the United States. Some investment companies are regulated by the SEC, some by the Commodities Futures Trading Commission (CFTC), some by the National Association of Securities Dealers (NASD), some conform to best practices required by custodial counter-parties, and some are guided solely by the good conscience of the fund manager.

In this rapidly expanding market, managers are seeking to differentiate themselves and attract investors assets through slick marketing campaigns, presentations, road shows, and shameless boasts about a mangers progeny, experience and past performance. Attestations of operational readiness and management’s commitment to ethical corporate governance is usually covered with a statement that lists the prime broker, the accounting firm for auditing and the administrator for transfer agency and shareholder communications. The manager believes that by listing the service providers (corporate brands) they convey a message to the investor that they are operationally sound and have the operational controls in place to satisfy all contingencies. Unfortunately, these service providers are retained for a very specific purpose and taken in aggregate do not amount to the implementation of a unified sound risk management program. Indeed, Arthur Anderson was a leading provider of services to the alternative investment management market and reliance on this brand to infer regulatory compliance or adherence to sound operational practices was clearly a miscalculation.

In the day-to-day operation of the business the tension between regulatory compliance and entrepreneurial zeal is usually resolved in favor of doing the transaction. When we asked an executing broker working a large sale transaction for a first time hedge fund customer if the hedge fund identity had been properly documented and verified in conformance with the rules of the USA PATRIOT Act he stated, “They’ll never answer these questions and if we ask they’ll simply go to another broker to work the order. We’ll take the hit to do the deal.” Yes this broker made a calculated decision based on the potential that the hedge fund was not entering into this transaction to launder money through the capital market system or was a front for terrorist financing. He was probably right, and earned his firm a nice commission for working the 100,000-share block at $.05 per share. But what if he was wrong? Was the premium commission rate a fair return for a ruined reputation, a million dollar fine, the revocation of your industry license, a lifelong ban from the industry, or even a prison sentence?

What are Sound Practices?

Sound Practices are a set of standards and operational controls that mitigate numerous risk factors in the investment management enterprise. Sound Practices address the investment process, its decision and operational support functions, capital introduction, compliance requirements, business continuity, fund strategies and investor communications within a set of defined expense ratios.

What’s the difference between Sound Practices and Regulatory Compliance?

If we accept the definition that compliance is a set of externally imposed rules required to insure that counter-parties of a transaction and the rules governing the transaction meet acceptable minimum standards to facilitate an ethical and efficient exchange of value; I think we come pretty close to the meaning and nature of compliance and the purpose of the functions required to support it.

In the United States, depending upon the type of products a financial services firm offers, there may be or may not be a governmental agency or Special Regulatory Organization (SRO) that is charged with compliance oversight and enforcement of its business practices. The Office of the Comptroller of the Currency (OCC) is charged with the responsibility to oversee compliance with regulatory statutes for savings and loans, thrifts and banks. For broker/dealers the NASD is the SRO oversight body. For mutual fund companies and publicly listed companies, the SEC is the regulator. Future Commission Merchants are regulated by the CFTC; and hedge funds, -sometimes referred to as an Unregistered Investment Company (UIC)- at present escape any formalized regulatory oversight body.

Each regulatory body has its own set of compliance rules, guidelines and enforcement mandates. One can imagine the overlap and confusion that occurs when a bank owns a broker dealer, which owns an asset management firm, that offers mutual funds and off shore hedge fund products to institutional, retail and high net worth investors. The maze of regulators and the differing and sometimes contradictory regulatory requirements creates a reactionary and possibly antagonistic response to regulatory examinations and demands. At the very least, compliance is a significant cost of doing business and adds little to the intrinsic value of the product offered by the institution. The added expense of compliance deals with the structural aspects of the market, not the intrinsic value of the product. This is a dangerous bifurcation in its own right. A financial product, (specie for the capital markets) requires a denigration of value to assure a controlled velocity through a regulated market structure.

For companies that view regulatory compliance as a necessary evil that tempers entrepreneurial pursuits and whose function is an added cost of doing business; these organizations will develop a best practice culture that is inherently restrictive. This type of corporate response to regulatory or best practices initiatives will always be overwhelmingly reactive and places the enterprise at great operational and regulatory risk.

Sound Practices are different. Sound practices are a set of internally (organically) developed operating principles that inform the values of ethical corporate governance, is enforced by internal management and seeks to become invisible as it ingrains itself into the operational and business culture of the firm. Sound practices must be viewed as fundamental to a firm’s value proposition, organically grown and endemic to the corporate culture and proactively conveyed to the market as a premium brand.

The internal development or organic growth of best practices as a central desire and objective of the corporate enterprise is revealed as central to product brand and the value proposition offered in the market. This positions the firm and its products as a premium brand. The business benefits of a sound practice program are enhanced margins, product performance and the attraction of quality clients and vendor relationships. More importantly it differentiates the firm in a crowded market because its quality brand is perceived by the market as endemic to the firm’s corporate culture and as such is inherently superior to something that is externally imposed by some governmental or regulatory body. On a macro-economic level the socialist or state capitalist experiments in highly regulated planned economies are the logical extreme and true antithesis of a sound practice culture.

Within the hedge fund industry in the United States the concept of Sound Practices first surfaced in an industry study entitled Sound Practices for Hedge Funds. The study was an industry response to the Clinton Administration’s request to examine the lessons learned from the Long Term Capital Management implosion and recommend basic guidelines to avoid similar disastrous occurrences in the future. The paper was a breakthrough on a number of fronts, placing the science of risk management and the utilization of risk measurement tools at the center of the investment management enterprise. Though the study was a political response to a catastrophic market event, the real purpose of the study was to temper the drive to regulate the hedge fund industry. In essence, the authors of the study asserted that regulatory oversight is not needed if hedge funds implement and maintain a sound practices program. Sound practices will allow investment companies to remain unregulated and will assure that the industry is fully capable of self-policing through the creation of practice standards. Indeed, any regulation or governmental oversight will further drive the industry offshore to more discreet and tax friendly domiciles and could potentially drain capital and liquidity from the US capital markets.

Operational Risk Mitigation

As previously stated, developing and adhering to a set of best practices principals and guidelines will add intrinsic value to product and corporate brand. The purveyors of Business Performance Management (BPM) solutions routinely boast the claim that publicly listed companies that practice BPM have P/E ratios that trade at a 15% premium to industry peers who have not implemented a BPM strategy. The question whether BPM is a silver bullet to enhance market value or whether BPM practitioners are leading companies dedicated to implementing programs and mechanisms to build shareholder value are irrelevant. What is important is that BPM practitioners are implementing processes and tools to understand and isolate operational risk to create product delivery and decision support mechanisms that build intrinsic product and corporate brand value. Thus at its heart, BPM practitioners seek to heal the bifurcation of marketing and operational risk management and firmly establish and display the synthesis as central to the value proposition a company delivers to its clients.

Operational risk factors in the investment management complex are numerous. They include valuation practices, system infrastructure, business continuity contingencies, vendor and service provider dependencies, risk management tools, risk management function segregation and asset gathering or capital introduction and investment acceptance principles. All of these risk factors are significant and each one on its own could threaten the ongoing viability of the enterprise. Each risk factor must be addressed in detail with a comprehensive programmatic approach to develop and implement processes and controls to enhance best practices to support the function and mitigate the risk factor associated with the business process. The Basel Capital Accord (Basel ll) proposes the introduction of a capital charge related to the operational risks of financial institutions. Basel II defines operational risk as “the risk of direct or indirect loss resulting from inadequate or failed internal processes, people and systems or from external events.”

As an example, poor record keeping or an honest miscalculation on a corporate action treatment or security valuation can be forgiven. After all, the restatement of earnings -even during the Sarbanes Oxley Era- in corporate America is common. Laundering money for criminal enterprises, or heaven forbid, financing terrorism goes way past lax controls. In the eyes of the law it is criminal, in the eye’s of regulatory authorities it’s a serious offence, and a heavy fine and asset forfeiture is possible. If this occurs, in the mind of the consumer the fund manager is guilty of two counts of treason. The first count of treason the fund manger is guilty of is against his country. The second count the fund manager is guilty of is the betrayal of a sacred fiduciary duty. A hedge fund manager would probably never recover from this type of avoidable catastrophic risk event.

Fund managers need not look at compliance with the USA Patriot Act as another cumbersome compliance requirement that will be expensive to address. The belief that compliance will antagonize or annoy potential clients and may in fact drive them to a competitor whose controls are not as stringent and whose compliance laxity facilitates transactions by making it easier for investors to place assets with the competitor may hold some truth. But shouldn’t a fund manager avoid those types of clients anyway?

Compliance with The USA Patriot Act requires that investment companies conduct due diligence and maintain and administer a Customer Identification Program (CIP). Investment companies should view compliance with the Act as an opportunity to develop a Know Your Customer (KYC) capability that enhances and enriches the client relationship with the firm. When fund managers make KYC the cornerstone of their product development initiatives marketing will then truly serve the risk management requirements of clients.

The process of conducting the KYC due diligence exercise results in a more in-depth understanding of the customer. As managers are verifying customer identification information they will routinely uncover residential, employment and family histories that give them a better perspective on the client’s needs, their appetite for risk, other fiduciary relationships the client has and the source of the clients wealth. The regulatory objective of the KYC process is to verify the clients identity and to make sure they are not a money launderer or terrorist. The sound practice objective of the KYC process is to cover the regulatory requirements and more importantly to gain insights and understandings into their personal and business motivations. Armed with this understanding the manager can design or offer an investment product that will address the client’s risk management requirement. Client’s will appreciate the fact that managers are conducting this due diligence to insure that their funds will not be commingled with money launderers or terrorists, and that the firm is taking appropriate steps to insure that they transact business with reputable clients whose ethical and moral standards are similar to their own high standards.

As clients experience the KYC discovery process, they will begin to understand that the firm is committed to delivering a qualitatively superior value proposition. The client experience will help them to understand that the marketing focus of the firm is to acquire trusted customers and the depth and quality of client relationships are established to understand client needs and requirements. The client will also gain the assurance that regulatory risk and the potential for large fines and asset forfeitures are minimized due to the care the firm has exercised in determining that its clients are the right type of clientele and that the firm’s management has created operational controls and processes to prevent the risk of money laundering within the investment management enterprise.

Furthermore, subscription and redemption releases are facilitated due to proper controls in place with administrators and custodial institutions. This places enhanced liquidity at a fund manager’s disposal allowing the manager to practice effective cash management techniques that position the manager to take advantage of investment opportunities that may arise. This raises the possibility of developing a more effective collateral management capability that will tighten spreads on haircuts and dramatically reduce financing expenses. The credit rating of the firm would improve allowing lenders to further reduce financing rates to capture the funds business in a competitive credit and financing market. The reduction in the cost of capital can dramatically affect investment performance and the marketers can truly boast of a source of alpha that is directly attributable to operational sound practice processes.

Having proper procedures and business processes in place with administrators and custodian institutions will also facilitate the transfer of shareholder data to accountants for tax and audit purposes. This will expedite the delivery of tax and performance information to shareholders, generating savings in preparation fees and lessening the possibility of costly restatements. This will reduce and maintain fund expense ratios to absolute minimums. Marketers can clearly demonstrate that the fund managers are good stewards and are as concerned with minimization of business expenses as well as investment performance and high watermarks.

Increased transparency and the opportunity to dramatically enhance shareholder communications and reporting will be a strong attraction to many investors. Indeed, many institutional investors demand a level of transparency, communication protocols, and reporting tools that would have been unthinkable only a short while ago. As sophisticated institutional participation grows within the industry, the implementation of a sound practice program will be the only way hedge fund products can incorporate the necessary value proposition that addresses their risk management profiles and requirements. Sound practices and the compliance function become significant differentiators and powerful marketing tools. At last, the bifurcation is healed.

James Wolfensohn, President of the World Bank has been quoted as saying, “Corporate governance is about promoting corporate fairness, transparency and accountability.” Sound Practices is a necessary prerequisite for effective and ethical corporate governance. Fund managers must accept it’s precepts and sell side institutions and other industry participants and service providers must demand compliance, disclosure, ethical trading principals, honest research, operational integrity and a full commitment to its implementation and adherence. Effective corporate governance practices will restore the faith of the investing public in the global financial services industry and maintain the rationality of the world’s capital markets. It will also please investors to see realized enhanced returns on investment portfolios and help fund managers to fully participate and enjoy the benefits of a thriving hedge fund practice.

Originally written January 5, 2004, the article is significant because it raises concerns about financial services product marketing practices that still need to be addressed six and half years later.

You Tube Music Video: Mike Oldfield, Tubular Bells

Risk: regulatory, consumer confidence, sound practices

June 7, 2010 Posted by | AML, banking, Basel II, credit crisis, hedge funds, investments, marketing, operations, private equity, product, product liability, regulatory, reputational risk, risk management, sound practices | , , , , , , , , , , , , , , , , , , , , | 1 Comment

St. Michael Save Us!

Michael_Jackson_an_angel_by_Ice_BeatMichael Jackson is now one with the ages. MJ’s passage from this earth marks the death of an American hero and the birth of an angel or possibly a saint. MJ now joins Elvis and Princess Di to complete a divine celestial trinity.

First there was Elvis, The King. The American dream and the innocence of an age dies way too young. No worries, Col. Parker transforms it into the tragic legend of an unsullied Americana that refuses to die even as its mummified corpse lying in state at Graceland continues to twitch from all the amphetamines old Elvis consumed during his historic run in Vegas.

Elvis, the everyman saint. Rising from the humble estate of a Mississippi delta dirt farmer. Elvis would conquer the hearts of his countrymen with sweet southern charm, an impish smile and an untamable shock of hair that flipped when his hips rocked. His love me tender silky voice had the power to weaken every woman’s knees. Countless men would also be curiously drawn to emulate his persona by adopting the vain King’s more frilly affectations. It was a curious example of socially acceptable homo eroticism in a don’t ask don’t tell and certainly don’t show society.

Princess Di, The Lady of the Lake, would follow Elvis. Her story genuinely tragic because her violent demise was not her doing. Her story truly the stuff out of a very Grimm fairy tale. A more gorgeous Cinderella could not be found. Yet her unprincely prince yearning to free himself from under the shadow of a perpetual queen would flummox his princess bride. It would doom this marriage and force the affection starved Princess into the arms of another. This fairy tale did not end well for the defrocked Princess. Her loyal subjects refused to let this very contemporary aristocrat descend to the pedestrian status of commoner. Her minions jealously guarded the memory of this royal icon. They sought to affirm personal fantasies that attaining royal status, though remote, is a possibility; and that beautiful benevolent monarchs are real people like them who deeply love and identify with their daily trials. Devoted Britoners make pilgrimages to her final resting place that is worthy of Queen Guenevere. Pricess Di is entombed on an island in an ornamental lake known as The Round Oval. The lake is located in Althorp Park’s gardens the ancestral home of Princess Di’s family. The Round Oval is surrounded by a path with thirty-six oak trees, marking each year of her life. Princess Di’s constant sentinels are four black swans that swim the lake amidst water lilies, which, in addition to white roses, were Diana’s favorite flowers.

MJ’s beatification will proceed abetted by fawning fans, a complicit family and entertainment media moguls eager to do large licensing deals to insure that royalties continue to accrue to the King of Pop estate and its agents. His veneration will address the American peoples deep seated need and unending capacity for hero worship. This need is only exceeded by our driving compulsion for instant gratification through gluttonous consumption. For many, this is the principal freedom promised to any and all Americans; an inalienable right to satiate any whim or whimsy money can buy. Nowhere in recent memory do these character deficiencies coalescence so neatly as they do with MJ.

The voracious consumption of culture knows no bounds. Like every other aspect of American life, culture as a commodity is the only culture we know. Radical capitalism has so thoroughly reified itself into the fabric of our everyday life that we find it increasingly difficult to imagine or experience human relations or interactions outside of a commercial transactional exchange. MJ significant buying power purportedly allowed him to bleach his skin, remove a negroid nose, purchase a triptych of white kids, fiance a voracious prescription drug addition and allegedly engage and cover up pedophilia activities.

MJ’s life was the triumph of consumer capitalism. Marketing changed and created MJ and the idea of MJ. From his very first appearance on the cover of Tiger Beat magazine as a member of the Jackson 5, to the ghastly image of his corpse filled body bag being offloaded from a helicopter on its way to the city morgue; MJ was a commercial vehicle, a marketing juggernaut that enriched a multitude of people, fattened his bank account and tormented and robbed his soul.

Yes MJ could have anything and everything money could buy yet he found no peace. This mythic figure created, manufactured and marketed by immutable corporate institutions seeking to seamlessly bind our mind and soul to an existential dream of material opulence in reality is much more the nightmare. It is more akin to imprisonment in a gulag of Walmarts; then the elusive personal liberation tantalizingly dangled by the broken promises of consumer capitalism. MJ’s death truly signals a hair on fire moment for our culture and no metaphor could be more powerful then his Pepsi commercial shoot gone bad.

Our myths instruct us to hold on to our Valium and amphetamine addicted lifestyles. Its the price we must pay to work and acquire the things that hold the illusory promise of freedom. We need heroes to emulate. It fuels our Viagra driven power surges in a queer transference. Its how we escape our daily pedestrian dread. It is how we live to converse with the God’s if only for a few fleeting infrequent moments allowed by the running meters of consumer rapture.

Here we are led to believe that after a heavy day of fighting the power, misogynistic rappers guzzling Christal and lighting Cuban spliffs with hundred dollar bills are the just rewards for speaking truth to power and taking on the man. Madison Avenue business is the creation of virtual mythology.

MJ’s career trajectory perfectly captured the arch of American culture since the Viet Nam war. The perfect antidote to The Black Panthers and Malcolm X, the cutesy Jackson 5 were acceptable Negroes welcomed in all white American living rooms as they stomped on Ed Sullivan’s TV Show. To the final funereal spectacle complete with a homily by Rev. Al Sharpton offering MJ apologetics and the Afro American Hollywood bourgeoisie rolling up to the Staple Center in a caravan of Black Danalis perfectly captured a peculiar resonance of Barack Obama’s America. MJ always at its epicenter. Placed their by the power of Madison Avenue media mavens and blockbuster Tinsel Town agents.

CNN was crowing how this event was about the common folk. Not the stars or glittering sequined gloves worn by MJ pallbearers. Elvis was a Horatio Alger type story. Princess Di let us fantasize about our royalty as we sat in our personal castles of over mortgaged homes cluttered with Rubbermaid artifacts. MJ was evidence of the triumph of marketing and the divinity of packaged consumer capitalism. Look again at the man in the mirror. Let it reveal how consumer fantasy makes every man King and each day a coronation through the availability of fast and easy credit.

Joseph Campbell wrote in The Hero Has a Thousand Faces “Wherever the poetry of myth is interpreted as biography, history, or science, it is killed. The living images become only remote facts of a distant time or sky. Furthermore, it is never difficult to demonstrate that as science and history mythology is absurd. When a civilization begins to reinterpret its mythology in this way, the life goes out of it, temples become museums, and the link between the two perspectives becomes dissolved.

As the world begins its frantic search of Travelocity for deals for a Hajj to the Neverland Ranch, some might recall St. Michael the Arch Angel who cast Lucifer out of heaven. MJ will be St. Michael the Second. It may be an ironic twist of fate that MJ will hold second billing for eternity to an Arch Angel portrayed by John Travolta in the film Micheal. I’m sure his publicists are busy planning a PR campaign to rearrange the celestial order of things.

You Tube Music Video: Gil Scott-Heron and Brian Jackson: Madison Avenue

Risk: culture, capitalism, marketing,

July 30, 2009 Posted by | branding, commerce, commodities, culture, democracy, institutional, manufacturing, marketing, media, movie, pop, product, reputation | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Hannah Montana Won’t Leave it to Beaver

I believe she might have said that she didn’t mean to do it. Or she may have apologized for a misinterpreted Annie Leibovitz artistic shoot of Girls Gone Wild. But clearly her deft handlers, publicists and other spinmeisters have shifted to overdrive to protect and maximize the equity value of Miley Cyrus Incorporated.

This is a classic study of taking a calculated risk and managing its effects. There is no damage control here. Ms. Cyrus and her management team made a calculated assessment and decided it was time to reposition the Miley Cyrus brand.At 15 years of age, Ms. Cyrus had a limited shelf life as the much beloved Hannah Montana. As she grew and matured into young adulthood her ability and believability of portraying a challenged 8th grader was straining credulity and the character was living on borrowed time. So her managers made the decision to begin transitioning the product to parallel the maturation of her target demographic market. Yes her fans will soon be putting away their Hannah Montana lunch boxes and dress up dolls. As they grow and require trainer bras, tampons and Clearasil she might as well continue as chief pitchman for these products as well.

In TV news coverage of this shocking incident, photos of Ms. Cyrus sitting on the lap of her strong protective father Billy Ray preceded the Annie Leibovitz shots. I felt the pain of his achy breaky heart as he symbolically gave his daughter away to an adoring public. Clearly Ms. Cyrus has fully entered the public domain of commoditization and she is now wedded to the fickle fancy of consumer markets. I believe Puff Daddy, Tommy Hilfiger and The Rockstar Formally Known as Prince also sold their names as a consumer market brand and have ever since continue a quest to discover who they truly are.

Unlike Jerry Mathers who was unable to transition his career from childhood star, the management team at Miley Cyrus Incorporated has no intention of mismanaging this valuable corporate brand. They see an opportunity. Ms. Cyrus has established a large brand following within a market demographic of young girls who will be consumers of products for the next 70 years. Miley Cyrus Incorporated (MCI) is moving with her market and her product life cycle is staggering.  When MCI goes public, her market cap will be impressive. As Ms. Cyrus’s target market enters retirement she’ll be well positioned to sell them an extensive line of rocking chairs to lull her fan’s to a well deserved sleep.

Risk: Reputational, Market, Demographics, Brand Marketing, Family Values, Art, Product Life Cycle

April 29, 2008 Posted by | branding, commodities, marketing, media, psychology | , , , , , , , , , | Leave a comment

Awkward Juxtapositions

Narcissus Falls in Love

We are committed to a blog entry every day. It’s a tough assignment trying to fit it in with everything else that is necessary to sustain our business and our lives but we think it important. Like Narcissus we too have fallen in love with our own reflections.

We do believe that consistency is its own reward and that the joy is truly in the journey. We are blessed to have come to the realization that the process of blogging helps us to understand and discover ourselves as much as it helps you understand and discover us. In this journey of discovery we hope we don’t scare you away.

That brings us back to the purpose of this blog, Risk Rap. Our goal to examine risk and its impact on our culture and lives presents a broad enough pallet that pretty much gives us carte blanche to opine on all matters concerning politics, economics, arts, religion and social issues.

The good news is that we can do whatever we want. The bad news is we can do whatever we want. Herein lays our risk tale for today. Before each entry I feel compelled to offer a warning to readers that this blog has a secret agenda. That agenda is to support the narrow commercial interests, marketing strategy and the facilitation of transactions in the products of our company, Sum2.

Yes there was a Sum1 (isn’t there always a someone?). So we must ask ourselves, what does the Pope, The Rice Crisis, the Iraq War, Hank Paulson and the banking crisis have to do with the promotion of our products and our new e-commerce platform?

Clearly these macro risk factors impact the broad commercial interests of our clients and our potential clients. But the interconnection of commerce, politics, culture and religion more often creates awkward juxtapositions that are alien to the common language of commercial promotion and product marketing. Sadly we are at risk of erecting barriers to our goal of effecting commercial transactions. This alone produces some interesting psycho graphic clues about the author of this blog. Perhaps we should offer a warning to ourselves.

We’ll continue to do the math and try to offer measured sober assessments of our world at risk and how we can offer solutions to temper the potentially negative aspects of risk while enhancing the positive results and benefits of taking calculated risks. That is what Risk Rap is all about.

We’ll remain hopeful that readers will recognize the role our products play in helping them assess risk in their world while we continue to assess and weigh the power of the pen with the restraint of the pen and tongue to support our narrow commercial interests.

You Tube Music Video: Ella Fitzgerald, A Tisket A Tasket


Risk: Personal, Commercial


April 19, 2008 Posted by | commerce, marketing, politics | , , | Leave a comment

Flying Unfriendly Skies

It’s hard to make sense of the mass grounding of American Airline jets this past week. The decision by AA management to implement an immediate review of its MD 80 aircraft caused great hardship to thousands of its customers, lost tens of millions of dollars in revenue, damaged customer loyalty and put a dent in the company’s brand. Readily apparent are two interpretive perspectives on the American Airlines grounding.

One interpretation is of a public company taking dramatic risk mitigation action to protect its brand and franchise through a rapid deployment of a full coverage compliance initiative. The other perspective is the growing political tension between commercial markets and the perception of regulatory incursion by a Federal Government Agency the FAA.

Some may argue that the thrust in the scope and enforcement power of Federal regulatory agencies have eroded over the past two decades. American Airlines failure to follow FAA compliance guidelines is an example of company’s dismissive approach to regulatory compliance. Further, the political zeal of regulators was tempered by a republican administrations Laissez Faire ideology and commitment to free markets. The AA grounding was a regulatory over correction by the FAA due to its lax standards when it failed to detect cracked fuselages on some Southwest Airlines jets.

The dance of regulating markets and the political will and apparatus to do so are issues of growing prominence due to the sub-prime mortgage debacle and the banking crisis. But we must give AA management credit for realizing the risk that non-compliance posed to the reputation of its brand. Some companies never recover from brand damage caused by a reputational risk event. This is particularly damaging when the risk event threatens a core value or perception associated with the brand.

Consider the accounting firm Arthur Anderson. Anderson’s could not recover from its lack of sound judgment and objectivity in signing off on fraudulent financial statements of Enron and Waste Management. The damage led to the extinction of a trusted and venerated brand. Trust, sound judgment and objectivity were core values associated with the Arthur Anderson brand and once those values were compromised the brand lost its value.

Same goes for American Airlines. As a premium provider of air travel services, clients expect the brand to offer enhanced assurance of safe travel due to superior operational expertise and resource devoted to service delivery. American Airlines admission of laxity in compliance practices with FAA inspection and wiring safety standards and the actions it took to rectify compliance deficiencies is a dramatic affirmation of the company’s desire to protect brand value.

Last weeks travails need to be incorporated into the branding story of AA. Its marketing message will convey its uncompromising commitment to the safety of its clients. In so doing AA’s management made a wise investment decision to protect the long term equity value of the company.

Risk: reputation; compliance; market, regulatory

You Tube Video: Eastern Airlines Commercial, Wings of Man

April 15, 2008 Posted by | marketing, regulatory | , , , , , , , , , , , | Leave a comment