Another of the "Comments on OFR Study on Asset Management Issues" is from James J. Angel, Ph.D., CFA, Visiting Associate Professor, University of Pennsylvania, The Wharton School. He writes, "Here are my comments on the Office of Financial Research (“OFR”) study on Asset Management and Financial Stability. First, I would like to commend the SEC for soliciting comments, while the OFR itself did not. Soliciting comments on all major staff studies is a good idea. I suggest that the SEC continue this practice not only for OFR studies, but for all future major SEC studies as well.... It is just as important for OFR to identify areas that do not threaten the financial stability of the United States as it is to identify those that do. Our regulators need to focus their limited resources on the most important areas. It is thus important for such a study to identify the sections of the asset management industry that present no threat as well as to identify firms and practices that do represent a threat. Unfortunately, this study does little to assist regulators in making such a distinction. The study is incomplete. As one who studies and teaches about regulation and financial crises, I was looking forward to a serious analysis that would provide objective and sound criteria for making a section 113 designation. Alas, I was disappointed in the result. The study provides a brief overview of the asset management industry, comparable to a chapter in an introductory textbook, along with a generic list of things that could go wrong. Indeed, the 34 page document uses the word "could" 66 time, the word "can" 72 times, and the word "may" 72 times."
