I am just absolutely thrilled to welcome you back to the Ford School and to the Consumer Financial Protection Conference that we're having here today. It's my distinct honor to be able to introduce our next speaker, Rich Cordray. In this particular venue, and many others, Rich does not really need an introduction, but I'm going to do so anyway. Rich has many skills and talents. We'll start with the obvious one. He's a five-time Jepeter winner, which is really hard to pull off. He knows a lot of trivia. We were having dinner last night, and the restaurant owner came up and was chatting with us for a bit, and I can't even remember the question. But Rich knew not only the answer to the question, but the statistics behind the answer to the question involving some baseball player, and it was a good category. Rich is a former treasurer, a county and state treasurer in Ohio. He is the former attorney general of Ohio. Rich was one of the first people really in the country to call out the abuses that were happening on the ground in subprime mortgage lending. Mike was talking in the earlier panel about the voices from the field that were calling out what was going wrong. Mike was out talking about the subprime mortgage crisis with evidence from North Carolina. Rich was calling out the problems from Ohio. Really around the country, there are a lot of voices calling out these problems, and Rich not only called them out, but was working to try and correct those abuses on the ground in the lead-up to the financial crisis and after. Rich then came into the federal government, became the CFPB's first enforcement director, and then after a long involved process in the Senate, became the first director, the inaugural director of the CFPB. I should say the process was long and involved. It was very partisan at first in Rich's confirmation. But at the end of the day, overwhelmingly approved Rich on a bipartisan basis, having seen the work he did at the CFPB, and I think it's a real testament to Rich's even-keeled manner and ability to get stuff done to deliver results for American households. Rich did a phenomenal job with the handoff from Elizabeth Warren, building an incredibly strong and vibrant Consumer Financial Protection Bureau. It is not easy to build anything from scratch, not easy at all. It is really hard to build a new federal agency. And I think it's a real testament to Rich and to many people in this room who worked with Rich that that agency was not only built, but thrived. And I think you can see that in the way in which the CFPB acted under his leadership in enforcement and supervision and rule-writing.  Most of you know Rich left the CFPB and ran for governor in Ohio. I can say, I guess, that it's unfortunate that he didn't win. I think he would have been an outstanding governor. Rich is now able to reflect on his experiences at the CFPB and before, and I'm really deeply looking forward to his comments today and to the discussion that follows. I've used this phrase before, so my apologies, Rich, but I will say again, with pun intended, we are very much in your debt for all your work. With that, please join me in welcoming Rich Cordray. Thank you, Michael, and to everyone involved in organizing this conference. It has been peculiarly well done, and we all thank you. And I also appreciate very much the theme of the conference, which is consumer protection in an age of uncertainty, which I think is exactly right. And I'm honored to be here, too, with what seems to be a distinguished group of consumer law mavens and have some trepidation about the question-and-answer session, but we'll do the best we can. The notion of consumer protection in an age of uncertainty seems right to me most of all because right now we're in the middle of an administration whose commitment to consumer protection seems questionable at best. The primary subject of my talk will be how consumer financial protection is peculiarly affected by our dual-state federal system of federalism. But as the conference materials note, this is also an uncertain age because the rate of change in the financial marketplace is so swift right now that it's difficult for anyone to keep pace with it, let alone those notoriously plotting regulators. So with your indulgence, let me nod for a moment to recent technological developments before returning then to the shifting policy environment, which is the real focus of my remarks today. And then, of course, I'm happy to spend whatever time we have answering your questions about anything I have said or not said as you please. First, as to technology, there is no doubt that what has been quaintly regarded as a market for thousands of years, a physical place where buyers and sellers come together in person to transact their business in physical commodities, has been transformed in the past generation to something human beings would once have found unrecognizable. There are a lot of aspects of our lives today that human beings for thousands of years would have found unrecognizable. People have always craved speed, ease, and convenience. But for most of humanity not flushed with great wealth, the physical limitations of our world simply did not allow it. We thought we were reaching unprecedented new levels of human commerce in the past century or two with mass production, the automobile, and instantaneous communication by telegraph and telephone. But nothing before it can compare to life in the computer age, where our physical limitations are literally melding away, and online commerce built on the mysterious power of big data is solving the logistics and reducing the costs of speed, ease, and convenience. And the result is to make them increasingly available to the broad consumer public. It also presents a shampaterian moment when many moats and walls that previously protected stodgy rent seekers in the marketplace are starting to be torn down. So hip hip hooray, right? In many respects, yes, but not entirely. Along with its benefits, 21st century consumerism also presents new dangers. One danger is posed by the financialization of our economy, the mass availability of consumer credit, which creates both opportunities, but also risks for people who may get in over their heads and ruin their financial lives. Of course, even in the old days, people could do things that landed them in debtor's prison, but more types of credit and more complex credit products are now available to more consumers than ever before. And once again, I will stress that though this can be a very good thing, and in many ways is a very good thing, it also raises new and substantial concerns about people's ability to manage their credit and the effects on their financial health. Another danger comes from the very nature of speed, ease, and convenience. Many consumer choices are small and simple enough, but some are more complicated and can be quite consequential. For those consumers who don't understand all the ramifications, hasty decisions can lead to lasting regrets. Yet another danger stems from the nature of the online medium, where greater anonymity or sheer unfamiliarity with the other party can facilitate fraud and other forms of exploitation. Further encouraged by the evidently greater difficulties in effectively enforcing the law in a world of borderless commerce, where the enforcers are very much border constrained. And one last source of danger, though I hardly claim to have made a comprehensive effort to exhaust the subject, is the threat to our data security and our privacy in all the information that's being amassed about us, often without our full awareness of what may happen to us as a result. It's become fashionable for regulators to think and talk about all these technological developments in the financial marketplace, the so-called fintech companies, as something that might be best addressed by the concept of a regulatory sandbox. One thing that I recall about a sandbox, when our twins were little, is that nobody quite knows what exactly is going on in there. The same seems to me true of the regulators who bounce that term around rather casually in their conversations. Well, one thing it certainly should not be is a mindless regulation-free zone. There are many dangers in the post-modern abstract marketplace, and people can get hurt in a sandbox just as much as they can anywhere else. So that's as much as I'm planning to say in these brief remarks about technology, although if you want to return to that in the questions, I'm happy to talk some more. My main topic is what the conference organizers have euphemistically referred to as the shifting policy environment, namely the transition from the Obama administration to the Trump administration. I'm not going to try to speak to consumer protection across the board. I do not know for certain whether the new administration is trying to dismantle long-standing legal protections for consumers of food, drugs, household products, motor vehicles, aviation, and other tangible products. Many of those provisions go to protecting the public safety, and I cannot say whether it's currently being compromised. Though some of these areas, such as aviation, are under extreme stress right now, and the actions taken in response will help us understand more about the administration's posture on these issues. My focus here instead is on the area of consumer financial protection, based on my experience as the first director of the new CFPB for its first six years. In the area of consumer finance, there has been a definite turn of direction. That was especially the case during the transitional leadership of Mr Mulvaney, an adamant opponent who made no secret of his personal hostility to the consumer bureau. But the full extent of that turn is not yet entirely clear under the newly confirmed director. I've criticized some of her decisions thus far, such as the move to roll back the payday lending rule, and the claim that the bureau lacks authority to supervise companies for compliance with the Military Lending Act. But so far, the jury is still out on many other issues, and people need to be given a chance to settle in to a job. At a minimum, however, it seems clear that the Consumer Bureau has adopted a different stance in two key areas, enforcement and regulation. The number of enforcement actions, as was noted by the panel, the first panel today, has declined sharply in the past 16 months. And the pace of pro-consumer regulations appears to have slackened as well. There has been an avowed rebalancing away from the interest of the consumer public to a greater solicitude for the interest of the financial industry. To be clear, I think it's no mystery, I disagree with the main thrust of this shift toward federal inaction on consumer protection, which is very much out of step with the approach we took during the early days of the bureau and throughout my tenure. I think that aggressive policies for protecting consumers in the financial marketplace are needed and justified in the economy of the 21st century. The financial crisis of 2008, which did so much damage to this country, and was prompted by the massive meltdown in the mortgage market as exhibit A on that point, given that the mortgage market is the largest of the consumer finance markets. But a very interesting question now is, where does the shifting policy environment at the federal level leave the issue of consumer financial protection in the United States of America? In some Western countries, there would be no further basis for uncertainty about where we now stand. In countries like Great Britain, with a unitary system of government, which means they lack a system of federalism, a shift in policy at the center settles the issue for the entire nation. But that is not necessarily true here in the United States. As Justice Brandeis famously noted, and this is a quote, it is one of the happy incidents of the federal system that a single courageous state may, if its citizens choose, serve as a laboratory and try novel social and economic experiments without risk to the rest of the country. As with many famous judicial aphorisms, the mere statement of the principle is far from the whole story. It is not so clear that a single courageous state may act in the manner he suggests. If its citizens choose that it should serve as a laboratory to try novel social and economic experiments, there may be significant legal, political, and even practical obstacles in its path. Consider, for example, the current struggles over marijuana laws between our federal and state governments, and the uncertainty that currently reigns in their wake. Moreover, it's also far from clear that if one state chooses to try a novel experiment, that it can readily do so without risk to the rest of the country. Think, for example, about the way in which vaccinations currently are being handled in various states, whether it can be truly be said that those legislative experiments are being carried out without risk to the rest of the country. And we have the supremacy clause, which plainly states, this is a quote with omissions to improve comprehension, the Constitution and the laws of the United States, which will be made in pursuance thereof, shall be the supreme law of the land, anything in the Constitution or laws of any state, to the contrary, not withstanding. Thus, as I said a moment ago, Justice Brandeis' statement is not necessarily true. In fact, it was far from true at the time he said it. He wrote those words, after all, in a descending opinion, in a case where the Supreme Court held to the contrary. His dissent was joined by only one other member of the court. At the time he wrote, the court still held strongly to the locker doctrine that freedom of contract, as enshrined in the accepted understanding of the due process clause, trumped and thus invalidated any state law to the contrary. And for almost a century, the court had held that the law governing commercial relations for businesses and consumers at the state level could be controlled by federal common law in cases filed in the federal courts. Both approaches were ultimately overruled and abandoned in later decisions, but at the time Justice Brandeis wrote, the happy incidents of federalism were deeply clouded by prevailing interpretations of American law. Ironically, in fact, the court in that very case in which Justice Brandeis wrote, New State Ice Company versus Liebman, regarded itself as invoking the U.S. Constitution to knock down a state law as a means of serving the interests of consumers. The Oklahoma legislature had passed a law regulating the companies that could make or sell ice. Under the law, any company had to seek a license to engage in this business. The law had been passed at the behest of the large ice companies that exerted effective control over the legislature. Its practical tendency, as the district court had held, was to shut out new enterprises and protect the monopoly power of the existing businesses. As the court held, the law was not passed to protect the consumer public, but rather for the opposite purpose. Yet, Justice Brandeis's position would have blessed the law and allowed it to disserve consumers all in the name of state experimentation. Therefore, we need to recognize that the federal state relationship presents essentially a neutral spectrum in which either side at any time might be pursuing policies that either do or do not favor the interests of consumers. But let's get back now to 2019. Positing for the moment that there is a retreat in pursuing consumer financial protection at the federal level, what are the prospects for maintaining the same kind of protections for consumers at the state level? We have 50 additional sources of law to contemplate, and we have 50 distinct sets of public officials that we can encourage to enforce those laws vigorously. Certainly, at least some of these laws and some of these officials are inclined to carry forward the banner of consumer financial protection, even in conflict with contrary views embodied in federal law or adhered to by their federal counterparts. So what then? Can the states decide to exercise the happy incidents of our federalism to step into the breach and make up the difference? If they do, would their actions constitute a complete response, a partial response, or an ineffective response to the shifting policy environment? The answer depends on the particulars of the legal framework that controls a specific area of public policy, including economic policy. As noted earlier, the supremacy clause stipulates that any proper federal law is supreme and controlling, regardless of anything to the contrary embodied in state law. Does that mean any state law purporting to protect consumers in a way that's different from federal law would be rendered invalid, as contrary to the federal law? Does federal preemption thus negate state efforts to provide broader financial protections for consumers? Prior to the Dodd-Frank Act, it seems that the answer to that question might well have been yes, that even anemic federal laws would preempt stronger state laws to the contrary, because of the inconsistent rules of conduct they would pose for individuals and corporations. That is the doctrine of conflict preemption, which the Supreme Court has laid down to control any instance of a state law that would interfere with the intended objectives of federal law. As has been determined with such diverse commercial areas as medical devices, or cigarette labels, or airbags and motor vehicles, even so with consumer financial protection, if the federal law conflicts with state laws, even more protective state laws, then a court might well hold that federal preemption negates those conflicting state laws. That would be true, for instance, if the federal policy were that consumer protection should extend only so far and no farther as part of a uniform national policy on how to balance the interests of the consumer public against those of financial providers. And in the current administration, there's no doubt that some number of federal legislators and some other federal financial officials prefer this view. Another potential problem is that federal officials in a shifting policy environment might decide that they no longer have the same zeal to enforce the law as was shown previously. In the field of consumer financial protection, a shorthand phrasing of this view might be whether federal officials should push the envelope, that's a quote, in advancing consumer protections in the financial marketplace. Mr. Mulvaney stated explicitly that he believed I had done so, that such an approach was undesirable or even improper, and he made clear that he would not do so during his interim tenure. On traditional theories of dual federalism, it was up to federal officials to enforce federal law. State officials were authorized to enforce state law, and never the twain shall meet. Hence, a voluntary pullback in enforcement at the federal level was dispositive of the continued efficacy of federal law, at least while those federal officials remained in position to impose their views. And if federal officials could thus effectively undermine the force of the federal laws, while also claiming to preempt state laws protecting consumers, then the depressing result would appear to be checkmate. But interestingly, the Dodd-Frank Act imposed important changes in the federal state landscape that governs consumer financial protection in particular. And let me here take a moment as a point of personal privilege and say a number of the people who are involved in drafting the Dodd-Frank Act are in this room today, and I need to state publicly how much I am thankful to them for the excellent job they did in drafting that statute. People give us credit for having set up the CFPB and started a federal agency from scratch, and that was a big job, no question about it. But to conceive what the agency would be and to conceptualize that and implement it in legislation, to state and scope out the powers and authorities and how it would all fit together was a momentous task as well, and they did it very well. When people would ask me from time to time, what other powers and authorities we were lacking that we needed at the Consumer Bureau, there was little or nothing that we could say that we were missing from that statute. The one complaint I do have is the auto dealer but that was not the drafters of the legislation but rather the legislators themselves who imposed that due to political compromise. But what I wanna focus here on is not the drafting of the Dodd-Frank Act in terms of the CFPB's power authorities, but it's drafting as it affected the law in this broader context of federalism. So again, what are the changes that it made in the federal state landscape that govern consumer financial protection? What a way to understand the point is to conceive of these measures as default rules. Ultimately, the controlling view on federal preemption always lies with the Congress, at least within its proper rule of enacting legislation that does square with the U.S. Constitution. But the Constitution itself does not dictate whether a state law can or should run contrary to a federal law. That's a determination that Congress has the authority to make in the first place. Of course, the courts have a subordinate authority to determine preemption issues in any area where they must construe the congressional intent, but if the Congress speaks clearly, then that is the end of the matter. The Dodd-Frank Act changed the default rule on preemption in a crucial way. Section 1041A1 of Title 10, which addresses the legislative issue concerning sources of law, said as to the issue of federal preemption as follows. A little bit of bracketing here to make it readable. The Consumer Financial Protection Act may not be construed as annulling, altering, or effecting or exempting any person from complying with the statutes, regulations, orders, or interpretations in effect in any state, except to the extent that any such provisions of law is inconsistent with the provisions of this act. Thus far, this is just a restatement of federal preemption theory that if state laws are inconsistent with the federal law, they cannot be pursued. But subsection A2 works a distinct change by saying, quote, for purposes of this subsection, a statute, regulation, order, interpretation, and effect in any state is not inconsistent with the provisions of this act. If the protection that such statute, regulation, order, interpretation affords to consumers is greater than the protection provided under this act. This is a telltale provision, and it's notable because it effectively speaks in the language of rights. To explain this, let me make an analogy to doctrines of state constitutional law. That's a subject that I used to teach. It's been long established that the rights guaranteed under the US Constitution are distinct from the rights guaranteed under state constitutions. For more than a century prior to the incorporation of federal rights against the states under the due process clause of the 14th Amendment, this conceptual point was basically irrelevant because there could be no conflict between a right guaranteed against the federal government and a right guaranteed against the state government. That was the holding in Barron versus city of Baltimore in the early 19th century. The US Constitution created and constrained the federal government. State constitutions created and constrained the state governments. These sets of rights operated wholly independently and their intersection was a null set. But after the incorporation doctrine was broadly adopted in the middle of the last century, you could have the same types of rights protected against state officials. Free speech rights, religious rights, search and seizure rights, so on, under both the federal and state constitutions. Often the language of the two documents is precisely or essentially the same. Yet it has been settled for many decades that there could be independent construction of the same substantive constitutional rights and where they clash, the resolution of that clash is governed by a one-way ratchet. Wherever federal rights are interpreted one way and state rights are interpreted some other way, the state rights can protect individuals beyond the scope of the federal rights but they cannot operate to undercut the scope of federal rights. Put differently and more simply, as was stated on the panel this morning, the federal constitutional rights are a floor but not a ceiling of constitutional protection against the actions of state officials in that setting. And for example, that would be true even if state law contains UDAP provisions, unfair deceptive practices, acts or practices, and federal law contains similar provisions or even almost identical provisions, unfair deceptive and abusive acts or practices. Those could be interpreted differently at the state level and at the federal level and they could be more protective even though the underlying language was the same. That is exactly what this language in the Dodd-Frank Act provides as well, yet without the confusion of having two different sovereign governments. Consumer laws of course protect against private individuals and corporations, not governments. If states wish to convert broader consumer financial protections against private individuals and corporations, they can now do so because of Dodd-Frank. Regardless of whether the U.S. Congress or federal officials have done so. That is the new baseline of fairness that Congress has created under federal law in this special realm of consumer finance. The decision by state officials to confer broader protections on consumers as a matter of state law is not inconsistent with and is not contrary to federal law. Meaning that the default rule is there is no conflict preemption of such more generous state laws. So one might ask and maybe I would ask some of the drafters who are here, why should this be the new baseline? Why should we have a one-way ratchet favoring consumer financial protections? To put it bluntly, this language reflects the notion that consumers deserve certain rights and where state officials choose to recognize and protect those rights, they should have latitude to do so. In other words, the default rule now is that more consumer protection conferred by states is considered a good thing and thus is legally permissible despite the text of the supremacy clause. And since this language appears in statute in the Dodd-Frank Act itself, explicitly declared by the Congress itself, it would seem to control any efforts by regulators to act to the contrary by trying to preempt such state laws on their own authority unless they have countervailing statutory language they can cite in support. Now the second major change embodied in the Dodd-Frank Act has to do with the issues of executive power concerning the enforcement of the federal consumer laws. Section 1042A essentially says, and I'm paraphrasing some complicated language here, that in any state, either the top legal official or the top financial regulator can take action in a federal or state venue to enforce the provisions of the Consumer Financial Protection Act and its implementing regulations against anyone who violates the act or such regulations and to secure remedies for any such violations provided by law. The lone exception is for nationally chartered banks, but even they can be subject to an action by the state's top legal official for violating not the act itself, but its implementing regulations. This was the Congress's considered response, or maybe something of a political compromise, to the Supreme Court's surprisingly pro-state holding in the Cuomo v. Clearinghouse case. Now that's a bit complicated and it merits several observations. First, this seems like a fairly novel form of federalism, apparently it's not unprecedented, but novel which authorizes state officials to take the initiative to enforce federal law directly. Why would Congress do that? I would submit it was a farsighted response to precisely the shifting policy environment we now have where the federal government itself may now be disinclined for one reason or another to engage in robust enforcement of federal consumer law. Those reasons might include adherence to free market ideology, or an anti-government bias, or a desire to support the financial industry, or agency capture, or resource limitations, or perhaps some other reason, or perhaps all of those reasons. Whatever the reasoning may be, the Congress that enacted the Dodd-Frank Act spoke clearly to say that it was not willing to put all of its enforcement eggs in the federal basket. It made the express determination to authorize 50 other sovereign entities to enforce federal law as well, at least for the most part. This is a departure from strict notions of dual federalism where federal officials enforce federal law and state officials enforce state law. Yet it seems natural enough to me that Congress would want to see more robust enforcement of the laws that it has enacted, not just in this area, but in any area. It disrespects Congress when the executive branch hollows out valid laws on the books through mere inaction, as though the federal officials had not taken a constitutional oath to faithfully execute those laws. Indeed, this provision suggests that Congress was concerned that the consumer financial laws would be systematically under enforced, and so they sought to expand and strengthen the team of officials engaged in giving them teeth. Perhaps all federal law is systematically under enforced, since crossing the line is subject to judicial correction and sanctions, which may prompt caution about treading into gray areas close to the line. Anybody who's dealt with in-house government attorneys knows this mindset. Or because limited resources and unlimited problems simply lead to an inevitably feudal game of catch-up where regulators and law enforcement officers never quite feel that they're winning. However, all of that may be, what we now have is an enhanced system of federalism applicable to consumer financial protection under the Dodd-Frank Act. State officials now have more tools and more resources than ever before. This reflects Congress's embrace of the importance of protecting consumer rights in the financial marketplace. Now, one or more of you consumer law experts might wanna ask me, what about section 1044 of the Dodd-Frank Act? I'm cutting you off, I'm not giving you the chance. Which further governs preemption issues involving the OCC under the National Bank Act. And which by itself contains no fewer than seven subsections and nine sub-subsections. This is the point at which I might throw up my hands and say that these are issues for the courts to decide. Indeed, Congress may even have executed a classic punt here after what I recall was a fierce fight about whether to incorporate the murky preemption holding in the Barnett Bank case about when state laws substantially interfere with federal law, a debate in which we might say that perhaps not a single member of Congress would have clearly understood what the final resting point was and what the meaning of section 1044 actually was for national bank preemption. But I will say a couple things here even about this obscure section. First, it does not apply to any of the non-bank financial companies, thousands and thousands of companies who are treated under the pro-consumer default rules laid out earlier. Second, it only applies to nationally chartered banks themselves to find very narrowly to exclude even their affiliates and subsidiaries which is no doubt creating a bit of reorganization in some of those entities. Third, putting the Barnett Bank case holding aside for the moment the only other ground on which state consumer financial laws are preempted even against nationally chartered banks is where they would quote have a discriminatory effect on national banks in comparison with the effect of the law on a bank chartered by that state. This subsection again presents a relatively spare basis for federal preemption which perhaps should inform judicial interpretation of the next subsection which is the one incorporating the preemption test from Barnett Bank. Enough of all that. But stepping back from the weedy marshes of federal preemption and its intricacies the bottom line is this. Even if the federal government is temporarily sounding some manner of retreat from the battlefield we can salute the Congress and those who assisted the Congress for ensuring that even in this shifting policy environment consumer financial protection remains alive and well in the United States. It has done so in the Dodd-Frank Act by creating what we might call a framework of competitive federalism. Competitive federalism empowers the states and their officials to expand and protect the rights of consumers in the financial marketplace by expanding state law and by enforcing federal law. I see faces in the crowd here today who are eagerly and proudly carrying that mantle. To them I say press forward, test the boundaries. Don't shy away from some of the uncertainties in the law. Do what you believe is right to protect consumers against fraud and abuses. And I urge the same to our federal colleagues to whatever extent you are permitted to do so. Remember the words of President Kennedy in his 1962 speech to Congress calling for a consumer bill of rights. He said then, consumers by definition include us all. They're the largest economic group in the economy affecting and affected by almost every public and private economic decision. Two thirds of all spending in the economy is by consumers, but they are the only important group in the economy who are not effectively organized, whose views are often not heard. The same is still true today. So you must listen for their voices and you must act to protect them through sound laws that are vigorously enforced. Please know that every day, not only I, but millions of Americans are fervently rooting you on. Thank you. There's always one. Okay. Good afternoon. My name is Teri Freedline. I'm in a school of social work here. And my question has to do with federalism and much of what I know about federalism comes from a book by Jamila Melchner on the fragmented democracy. And one of her points in the book is that federalism with regard to Medicaid undermines people's economic lives and potentially suppresses their political voice. And so given that the CFPB, particularly under your leadership, had been active in soliciting consumers' voice, how do you see kind of the CFPB in the context of federalism and related to consumers' economic lives and their voice on issues related to consumer protections? So this is a point I tried to make about Justice Brandeis and his dissent in the New State ICE case, which is that federalism itself is a framework and it is a structure and it is therefore sort of neutral as to whether we're achieving good or bad ends. A lot of people would say that federalism in the United States for years was detrimental in the sense that it was holding back the whole civil rights movement in this country and there's no question that that was true. And what it does is it presents and provides for competing sources of authority, competing sources of power, and power can be used for good or for ill. And the same is true in consumer protection and the same is true in every other area of law. The other point that I would try to make is federalism is itself a concept that has very complicated and diverse applications in different areas of law and different areas of practical experience and can look very different from one place to another, depending on, again, situations on the ground, what the legal framework is, it can differ from one area to another. As I said, it's quite favorable to protecting rights in state constitutional law. It's quite favorable to protecting rights now into the Dodd-Frank Act in consumer financial protection. May not be so true of consumer protection generally in the more tangible realms and certainly is not necessarily true in other areas of the law such as you mentioned. So, again, where Congress is willing to speak up and speak clearly and say that states should be able to go beyond and be more protective, Congress has the ability to do so, it is rarely done so. I'm gonna make you talk about section 1044. So, as you noted in Dodd-Frank, we made a number of moves to try and open up space for states to act when the federal government was misbehaving in some way or not acting. One of those ways was by changing the rules or what we thought was changing the rules for preemption with respect to national banks. For the reasons that others have said today that you can create, if the federal government steps in with strong preemption, you can create in a state a real race to the bottom in legal rules and then in practices. Mike Calhoun was talking earlier about the race to the bottom in North Carolina we certainly saw there and in other states that tried to act aggressively in this space. The provision among other things required the OCC to take a fresh look at all of its old preemption decisions and to figure out whether they were in fact justified under this new legal standard. The OCC stepped in before your appointment and before really the creation of the CFPB itself to avoid a provision that required them to consult with the CFPB and blanketly reissued all their old preemption orders. So I'm wondering if you could comment on that and on the effect that may or may not have had in your view of how the states can act in this field. Yeah, the first thing I will say is when the CFPB was parachuted into the existing system of federal regulators, there was one the OTS mentioned infamously by the panel earlier that was extinguished but otherwise you're still in a complicated world of multiple regulators and for the most part I think the other regulators natural reaction wasn't a universal reaction and natural reaction was to be very resentful and hostile to the CFPB. Among other things because the mere creation of a CFPB was not so implicit, pretty explicit rebuke of those agents for not having sufficiently attended to these issues. And there was some rearguard action and some efforts made to resist us under leadership at the time at the OCC. That was one of them but it was not the only one. And soon thereafter, happy occasion was change of leadership at the OCC. Tom Curry became the new Comptroller and Tom had a background of being a state banking regulator himself and different views on these issues and over time the cooperation increased enormously between the two agencies. And other situations were not as fraught and worked themselves out over time as well. In terms of where we stand right now in terms of National Bank Act preemption of the states, my guess is as good as yours, maybe not as good as yours. It seems very cloudy to me what the OCC has said may or may not entirely square with the new provisions of the Dodd-Frank Act. And I'm not aware that they've been tested in court at this point and whether they will be or won't be, I couldn't say. What I would add is that I don't believe any of the National Bank Act preemption provisions and 1044 have yet been tested in court. And it's possible we'll have some preemption battles shaping up because as I say, there's a push and pull here with the federal government seeming to be retreating in this area and the state government's having the opportunity to move in and they are doing so. And by the way, some of it is not moving in. They've always been there, but they're now sort of reinvigorated, I would say. There will be potentially preemption battles that will be coming up and some of them are looming right now and we will see what happens with those. But it matters enormously that Congress at the juncture where it could actually legislate in this area and right now we're seeing little or no legislation in this area, pretty much in the years since Dodd-Frank laid out these default rules and they would have to be undone by statute and I don't anticipate that happening anytime in the foreseeable future. So I don't know that I had much of an answer to your question, but it's the best I can do. Director Cordray, thank you so much for that wonderful talk. It reminded me of being back in law school, actually. Is that a good thing or bad? Yes. If I may shift you back to technology, which you mentioned at the beginning of your discussion, the exploitation of big data using artificial intelligence by financial firms potentially poses several risks to consumers and their participation in the financial markets. Do you have some thoughts about that and if you were still at the agency, what would you be telling staff to look into? Yeah, and this is not just in the computer age, although it's especially in the computer age. I mean, certainly the nature of information about consumers, about individual consumers, each one of us has been progressing rapidly for many decades, even before the computer age. I mean, you went from local credit reporting bureaus to a nationalization of that market pretty much completely unsupervised, unattended by anyone. It just kind of grew up on its own within the private sector and it gave rise to a number of problems. This was all before big data and artificial intelligence. And when the CFPB first came into its authority to supervise the credit reporting companies the three biggest ones have about 200 million files on Americans of greater or lesser completeness and accuracy for that point. It was quite a remarkable experience because they had virtually no systems in place to manage their own compliance with the law and that became evident very quickly to them and to us. And it's been a big, big job to try to sort of push them into some sort of sensible shape in terms of being able to manage their own operations in a way that can take account of and account for themselves for their interests, the interests of consumers. In terms of big data and artificial intelligence and all of the information about us, you know it is simplistic to say but it's a plus and a minus. It's giving us access to credit that we would not have had if companies could not really understand much about us. It is also potentially cutting off access to credit in situations where it would not seem to be justified. It is amassing information that can be used or misused for various other purposes that we may or may not know or understand or intend. It is a very prominent conspicuous example of the opportunity but also the dangers of this modern economy and maybe one of the most conspicuous examples. I don't have much more to say beyond that I don't think at this point. Hi Mr. Cordray, first of all thank you so much for being here, really appreciate your time. My name is Averal Prakash, I'm a dual MBA and PP student and I appreciate your focus on the federalism lens but I was hoping to kind of expand for you to talk maybe about some best practices that we could learn from other settings from other international firms and situations that could probably add to the process. I'm in Professor Adrian Harris's class on fintech and today we're talking about how the US system or at least our laws are quite negative. They try to restrict and create like boundaries versus in the Europe you see more positive legal framework so I was hoping you could talk about some best practices in other regions that maybe we could glean here that could enhance hopefully the situation. It's a really good question and it's something that we posit over quite a lot at the Consumer Bureau and I'm sure they still do. The nature of compliance with the law is that it is a sort of negative enterprise there's a threshold below which you cannot sink. If you do sink below that threshold you are in violation of the law. You're subject to sanctions, you're subject to penalties, you're subject to actions and so everybody should be, not everybody is conscientious and people think they can get away with things but people generally try to make an effort to raise themselves at least above the very low threshold of compliance with the law. Now there's much that we'd like to see out of companies and much that consumers would like that would go well above that standard. I mean nothing in the law says you have to have excellent or even decent customer service but consumers want that. This is the way in which the marketplace itself competes companies against one another to raise their game well above just the mandatory minimum legal threshold and one of the puzzles that we worked on with incomplete results is what can an agency, a federal agency do to try to encourage companies to get well above the bare minimum? I mean, at a first step you're trying to encourage them to get out of the gray area right around the threshold of bare legal compliance because they could fall below the line. So any sensible company will try to push itself a ways above the very bottom baseline but beyond that it is, and this is where we puzzled over the one of the objectives in the Dodd-Frank Act for us. One of the purposes was that we were supposed to foster work to foster innovation in financial services. How do you do that as a government agency? Isn't that something that's done in the private sector? Companies compete against each other and if they have built a better mousetrap they collect many or most of the consumers in their market and gain market share. What on earth do we have to do with any of that other than trying to stay out of the way? And that was one of the things that we thought a lot about and we worked with a lot of the fintech providers to, one of the things we recognized over time was that there's an overhang of lack of clarity about the law that can discourage and cause people to be very cautious about trying new things, even things that might be very pro-consumer if they aren't sure that those things will be looked upon as potentially violating the law. And where we could try to provide that clarity we did try to inevitably any issue like that as a very hard issue, often a very complicated issue and you wanna be cautious about working it through as the regulator, because you don't wanna suddenly bless something and then find that you missed something significant about it and you're blessing something that's actually harming consumers. But then again, there's a tendency to not wanna give any guidance at all, which is not very helpful to people either. So this is something we struggled with. And we were very interested and remain interested to see what's happening overseas on this. The UK has the financial sandbox. We were actually ahead of them and doing some work on this, but they have gone into this in a big way. There's no question in my mind that in London they see this as an effort toward economic development. They're trying to bring more fintech to England so they're trying to lower them. This is one of the dangers of a competitive policy of this type is you can lower people by lowering your standards or you can lower people by providing them with better service yourself. And there's some of both going on, I think, around the world and I'm concerned about what the CFPB is proposing because it's not clear to me that it will be sufficiently appreciative of the risks to consumers in this segment. But it's a difficult chicken egg problem of how much emphasis do you put on either side of that equation? And again, as a factual matter, are you getting it right or getting it wrong? And I don't have answers to the financial sandbox other than to say that I'm a little concerned about a blunderbuss approach that simply says companies can do whatever they want because they have the label fintech. That's very evidently in my mind not the right answer. And I think we don't know exactly what risks that will create, but they'll be significant. And I also don't, I have my doubts as to whether that will be a legally permissible result if that's the result that people are seeking to reach. I've noticed that Bayer Corporation is having a big problem with their weed killer and the lawsuits that are gonna result from that. And you get these huge settlements of $79 million and more for just one incidence of cancer. How do you guys see yourselves as far as impact is concerned vis-a-vis the legal system that offers remedy for being preyed upon or causing bad things to happen? Yeah, it's a good question. It gets into a difficult area, which is some statues have private rights of action and private liability that can be imposed in lawsuits by citizens directly. Some do not. If you're an enforcer enforcing the law in an area, should you take account of private enforcement? Should that somehow affect what you do? I don't think it should. I saw ourselves as neither backing away from seeking a remedy or relief in light of potential pending private actions, nor did I see us as necessarily facilitating private actions, although there's no question if the Bureau resolved an issue and found a violation of law, that could provide a basis for follow-on private lawsuits. And then so the question is, what's the total enforcement in the system, not just the enforcement by the CFPB, not even just the enforcement by the federal regulators, not even just the enforcement by the federal regulators in the states together, but including private liability, where do you all come out? One of the interesting aspects of that has been the whole Wells Fargo mess. We started with an enforcement action in which we faced a difficult problem because there was not a great deal of individual consumer financial harm to consumers, but there was outrageous conduct by the bank. So we ended up imposing a very high penalty relative to the compensatory damages in that case, one that arguably would be constitutionally suspect if you applied the punitive damage constitutional law to this, but in the end, the follow-up liability for Wells Fargo out of that whole mess has been so enormous. I don't even know what levels it's reached at this point, and of course there's been other conduct that violated the law that some of it was no doubt, some of it was turfed up by investigations we had ongoing at the time, some of it likely has been turfed up by the remarkable amount of attention paid to Wells Fargo in the wake of that enforcement action and where it all will end is hard to say, but it's a good question, it's a hard question, but I think that what we simply tried to do was take each matter before us on its merits and address it in light of the facts and the law that we had and didn't otherwise trouble ourselves too much with what else was going on in the universe. Now we did try to work together with others so that we could try to create a coherent package of enforcement, for example, we worked constantly with the states and with multi-states and we would strategize together even if we weren't acting together in the litigation, try to strategize together about what we were doing and why and I think that that can be helpful, but there's no doubt a fair amount of uncoordination in our system if you look at total law enforcement as a whole including private actions which the government of course can't control other than by Congress deciding whether to allow them or not allow them and the stipulations for how those lawsuits can proceed. Just, thank you, just to shift gears for a little bit and this is really relevant more to consumer protection with regard to investments and retirement and lending and other, sure. A question that really focuses on the investment side of consumer protection and saving side rather than lending and predatory practices. One of the potentially hopeful signs in the financial markets over the past few years has been some would say the Vanguard effect, that the message that the most important thing is to keep fees low and understand that very few people can beat the market and very few people can pick the people who can beat the market. That message has gone out to an ever increasing number of savers and hence a race to the bottom in terms of fees. What could be done from a regulatory point of view to strip the mystique from the swollen parts of the investment business which may be much of it so that, I mean for example, if the fiduciary duty rule were revived or as you envisioned it being originally implemented, would it be dangerous for a financial advisor to recommend any mutual fund other than an index fund? Might it be dangerous for a retirement plan to ever have a fund that had more than a .05% annual fee? How could this, what I think is this hopeful use of the market and of knowledge be harnessed through regulation or at least be encouraged so that that part of the financial market shrinks? Well that was kind of the subject for the last panel. Not so much for me but let me say a couple of things. First of all, you use the phrase race to the bottom in a somewhat unusual way because you were talking about what you consider to be a good outcome of lower fees. Usually we say race to the bottom is toward conduct that violates the law and exploits consumers. It's almost a race to the top. You're getting right now in terms of low fees and reasonable service. In terms of whether this could disincentivize investment advisors to charge fees, certainly could. I don't really have something insightful to say to you there. Any kind of regulation can have intended and unintended consequences. We don't always know what the unintended consequences by definition we don't know. And then we have to be ready to understand, comprehend and make adjustments accordingly. That was something that we very much was part of our view of our mission at the Bureau as we were dealing with pretty complex mortgage regulations. We very much didn't want to upset the market in some unexpected way and those markets are complicated. So we monitored that very religiously month in, month out and we often several times we ended up adjusting those rules even though it ate up bandwidth that we could have gone on and done other things and gotten some of the other rule makings done earlier but we thought that was important to do. I guess I'm just gonna leave it. I'm not an expert on the investor market but I was a fan of the fiduciary rule and it's sorry to see it set aside at this point but these things will come and go. There'll be further legislation on these issues. It was mentioned earlier the arbitration rule that we adopted that was overturned by Congress. There will come a time when the Congress will legislate on that issue and they'll legislate a lot more broadly than just consumer financial protection would be my guess on that. Thank you. Thank you again for coming in for the whole presentation. My question is based on your experience as a regulator with a regime that accorded lots of discretion assuming the will to enact a regulation for consumer protection over the comparative efficacy of broader standards and content specific rules. Which works when? Do you wanna say ability repay or do you wanna say 25% of your after income, et cetera, et cetera? What's your experience with that? Yeah, that's one of the perpetual issues in regulation. I remember when I first met with the new comtroller Tom Curry, he gave me a certificate that I kept in my office which was the very first set of standards that the original first control of the currency during the Civil War had laid down for national banks and it was on one rather large but one sheet of paper essentially and it was very general rules. You should do this, you should consider that very much along the lines of I think like Kahoon said earlier, you should not charge unreasonable fees, that kind of generality. And then of course the downside of that kind of regulation is that it leads it to someone else to fill in a lot of details. It could be an examiner, it could be a court if there's a court case over it. It could be people at the bank making their own judgments which might control the bank's behavior for an awful long time without any attention from the regulators. We found that and maybe it was due to the fact that we were considered an aggressive regulator, people wanted very, very specific rules from us. They wanted specificity on lots of detailed issues because they wanted to be able to know exactly what they were going to do. And for large financial companies that automate compliance, the more exactitude they can have, they can just automate all of that and then they can feel sure that they don't have a problem. They don't really want a discretion being exercised. It was said earlier, I thought it was ironic. They might like to have discretion exercised by someone favorable to them, but if they aren't entirely sure that you're favorable to them, they don't really want the discretion. And in the end you have these long, dense, prolix, very specific consumer financial regulations. I remember Senator Angus King at one point in one of my interviews when I was trying to get confirmed, he had his aid come in and dump on the table several of the big consumer finance regulations. It was a pile so high you could hardly see over the top of it. He was making his point. On the other hand, industry often wants that and asks for that and is happy to have it. Now, big companies can automate their compliance. Small companies have a hard time waiting through all this so it creates something of a differential impact within the industry itself. But I would say that where we were sure of ourself, we were happy to provide specificity. Often you're not entirely sure of yourself and so you don't want to set that foot. As is said, sometimes if umpires often in error never in doubt, you don't want to be that type of regulator either. But it is a very fact specific issue and something that you can't generalize about. But I'll give one more analogy which is in debt collection. Debt collection is a very unusual marketplace because at the federal level, there was a statute passed in 1977 that provides the Fair Debt Collection Practices Act and it never provided any authority for anybody to write any regulations underneath it until Dodd-Frank which the Bureau now has that authority in their working on rules on this subject. What that's meant is for 40 years, what was said in that statute which is at some level of generality has been interpreted by courts in private litigations again and again and again and the only guidance companies have as to what they should do on a lot of these very tricky particular issues is whatever courts have told them and the trouble is a lot of courts have said very different things on the same issues and so they really have no good guidance at all other than making a judgment which is not made in uniform fashion within the industry. So they actually have been kind of begging the Bureau for several years now to formulate and adopt rules so they can have more of that certainty let alone have a clear rule on a subject rather than murky conflicting rules. So there is a place for regulation and industry knows that and once they get used to it and the rules are sensible enough that tends to be a good marketplace and I think the mortgage and credit card markets have become good marketplaces in the last 10 years and they were not before, no question about it, reasonably good marketplaces till we find the next problem that leads to a meltdown which I don't know what it is right now but if we did we'd be heading it off, okay?


Why is a drama alert nation? I'm your host killer keemstar. Let's get right Into this interview first on Twitter. I see this from mr. Golden sports.    Golden sports that come on here on Skype to find out exactly What's going on? So mr. Golden sports this kind of started with you Why why are you this big wings fan, but no longer one? Well, I mean I've been supporting him for a while, you know I actually use one of the first few people I started watching on YouTube and I was a big fan of his commentaries in You know, I looked up to him I always thought he was a good person and I always thought that his you know content was was good and I always supported him and Randomly we're in a baseball stream.   None of that not not a single time in countless times. It had to be at least 20 different variations of me, you know Pretty much praising them that I had supported him so much and everything He said was nothing but negative and how often do people do is troll him and I'm thinking of myself, okay People troll you why don't you show support for the people that are actually showing you love? There's 20 people in the stream everybody flipped out that we said everybody was showing them love and he just completely Was very disrespectful to all of us. So it's a very small stream. There's 20 people there He comes in baseball is being streamed.   He said how's it feel that your mom's a whore something along those lines That's how we respond it wow That's how he responded there's we don't have the exact screen shot because he was banned from the twitch chat But he did admit it on Twitter with a screenshot.  You know randomly he starts coming in being egotistical, you know wings of redemption is is The god of gaming and that right there is everybody was like whoa like is he is he being is he being serious right now? And then he has the nerve the the moderator who said to ask him the legit question Wings thinks he's the god of everything. He tells us Ban him y'all need to ban like ban him right now like being Cameron. We're thinking like wings This this is not your stream. You don't tell us to ban our moderator So wait, he was in your stream telling you who to ban He had straight said just like that. I need Cameron ban and all of us like this is not your stream wings You don't tell us to ban a moderator. We just do it because your wings of redemption This is unbelievable. All right, so this happened a couple hours ago, right things have died down wings obviously apologized to you guys No, not at all. Not at all nothing, but excuses. I had said on Twitter, you know I defended you there were so many people that were telling me, you know that the person that Is brought, you know woody and all the stories that are being said about you is true and I'm like listen I've been watching wings for years man. I believe he's a good down-to-earth guy people don't understand him And it's true. That's why I said on Twitter like dude I've had so much respect for you and when you came in I couldn't believe it and to find out that somebody you have so much Respect for doesn't even acknowledge the fact that we support him We make it so that he can stay home and video game for a living It's because of us and you can't say a simple. Thanks. He's very disrespectful and I lost our respect for him So will you continue to be a wings fan?  You have like a hundred thousand subscribers and stuff Will you continue to watch wings? Never again unsubscribed and I would never give him the time of day I was a viewer of him on his twitch when he streamed. I watched his His live stream like I said, I watched his YouTube, but to him it doesn't even matter because you know He's just saying how people really don't matter It's just he's just on YouTube to make as little money as he can and that's it Like he has no acknowledge of the people of like you make people's day better wings Like people come home watch your video. You make people happy. There's so many people that hate you But look in the comments you make somebody's day happy and as a commentator I love when somebody says you make my day better like acknowledge that acknowledge us Loving the content that you put out But no all he wants to do is be negative and think about the trolls and say I'm only on YouTube to take as little much money as I can and then I'm gone It's like really is that all we do for you? Like I would never support him again. Never. All right Well, thank you guys very much for coming on I just want to let everyone know out there that we did invite wings to get his side of the story here He said something that he's willing to have a debate or whatever He didn't want to come on or he hasn't responded yet So thank you guys very much. Also, you guys are probably wondering what happened to the drama alert channel We explained all of it in the newest bad kid cast and the link to the newest bad kid cast explaining about the channel video games and the amazing and crazy Conmen that are behind it is in the description. So make sure you check that out. Thank you guys and Until we get drummler back the drummler videos will be here on youtube comm slash freedom. Thank you What happened to being doctors and teachers what happened to being your brothers keep


Welcome learners, this is the second video lecture of unit 1 that is Introduction to Research. So, in this video lecture I will be discussing two points, one is your process of research and another one is features of a good research study. So, as in my earlier video lectures, I have highlighted the process of research, basically the process of research consists of six steps, first is your defining the problem, then developing an approach to the problem and then formulating a research design. Then after formulation of the research design, we will collect the data and then next step is your analyzing the data and last stage of this research process is preparation of the report. So, let us start these steps one by one, first are like defining the problem, so in defining the problem, the researchers should take into account the purpose of the study, the relevant background information, the information needed for this study and how it will be used by managers in making decisions, so first they will identify what is the problem which they are going to study. Then the second is, second step is development of an approach to the problem, it consists of formulating an analytical framework and models and research questions and hypothesis and identifying the information needed. So, once like we have defined a problem, next we will try to prepare the analytical framework for this problem, like how we are going to solve this problem, what will be our hypothesis, what models we are going to use, all these decisions we will take in the step two. Then step three is formulating a research design, generally we call this formulation of research design as a blueprint of a study or blueprint of a research, that means here we will give a formal structure to the research, so its purpose is to design a study that will test the hypothesis of interest, then determine possible answers to the research questions and provide the information needed by managers for making decisions. Then determining the types of research to be conducted, defining the variables precisely and designing appropriate scales to measure them are also part of this research design. The issues of how the data should be obtained are from the respondents, all these things we will discuss under formulation of research design. So, in formulation of research design we can either decide whether we will go for qualitative research or whether we are going for quantitative research, so both these qualitative and quantitative research has got advantages and disadvantages, so we need to check with which one will be more convenient for us. Suppose like we want to do survey for our research, then the researcher can use variety of survey methods, suppose they can use telephonic survey, mail intercept survey or may be like internet, nowadays through whatsapp, every like there are many devices through which they can do survey, so suppose you have decided one of particular survey methods, then your next step will be questionnaire design, so what type of questionnaire you are going to design, generally we use some demographic information, then we use like in our questionnaire whatever like product or services related questions will be there that we put in our questionnaire, always remember like the simpler the questions are, it will be more clearer for the respondent to reply, so questions should be very easy to understand and most of the questions we need to put in closed ended, like people do not have much time, so instead of explaining all the answers what they will prefer to do, just take it, like yes, no or like strongly agree, disagree in different 5.7 point all this lack of scales, so questionnaire designing is again another important factor for like preparing the research design, next we need to decide sampling design, like what type of sampling method we are going to use for our study, so all these things we will get in later units of your book, when I will be explaining again all these things in detail, so here under formulation of research design, we need to decide what type of research we are going to do, whether qualitative or quantitative, then what survey methods we are going to use, then we need to design the questionnaire and then we need to decide what type of sampling design we are going to do for this study, then the fourth step is doing the field work or collecting the data, field work or data collection involves a field force or a staff, like which will go to the field and collect the information from the respondents, so nowadays instead of going physically to the field, we also collect data through with the help of internet, like through email or maybe Google form or maybe like through WhatsApp or any kind of form we can collect the data, so once suppose we have collected the data, then what will be the next step, the step 5 is analyzing the data, so data preparation involves adequately preparing the data for analysis, each questionnaire or observation form is inspected or edited and if necessary corrected for any errors, number of later codes are assigned to represent each response to its sections, so under analyzing the data what we will do, whatever information we have collected from the field we will edit it, like some respondents they may not fill all the questionnaires, maybe 30% of the questionnaire they have filled up and 70% they left blank, so what we will do, we will just delete those informations like those respondents, so we need to under editing we need to check whether the respondents have properly filled up the questionnaire or not, which responses we can collect or like where there are many errors, those responses we will just neglect, then what we will do, we will check the validity and reliability of this data and if these data are like valid and reliable for our study, then we will analyze the data with the help of different statistical tools, and then the last step is preparing and presentation of the report, the entire project should be documented in a written report that addresses the research questions, described the approach, the research design, data collection and the data analysis procedure, and present the result and the major findings, so the data findings should be represented in a comprehensive format and like we put different tables, figures, graphs etc, whichever is necessary for this particular study, so let me explain these steps in the other gist, first what we will do, we will define the research problem, then we will develop an approach to the problem, after that we will design a research we will formulate a research design, then once everything is specific, then we will go to the field for data collection and once data is collected, we will check for the reliability and validity of the data and then based on that we will analyze the data and once data analysis is completed, we will prepare a report for our study, then we will go to the second part of this video lecture, that is whether the features of a good research study, when we talk about research, research means like searching for the facts, searching for like replies to the various queries and also for the solutions to the various problems, so while we are going to searching for the facts and figures, so we need to be ethical, like some researcher what they do instead of going to the field, they will manipulate the data, so instead of doing such things, when we are going to do a good research, we need to be ethical towards our research, then research should be in a systematic nature, systematic nature means whatever steps I have said, like we should not skip any of the step, we should go from one step to another, then it should be logical, so when I say it should be logical, that means like whatever study we are going to conduct, like any organization is going to conduct, it should be within the capacity of the organization, so suppose instead of going for census, the organizations prefer to go for the survey, sample survey, why? Because census will be much more costlier compared to the sample survey, then it should be empirical and replicable in nature, so suppose someone has already done a study in a particular field, so instead of doing same study in the same field, we need to do different study in different field, then it should be according to the plan, then it should be according to the rules and assumptions, should not be based on the false basis or judgment, and this study should be free from biasness, and it should be relevant to what is required for our study, so that's all about these features of a good research study, hope you have understood this video lecture, and I have put here some of the references, you can go through it, thank you.


What is up everybody, Jason here for JasperJasperCaseBase.com 2023, Top's five-star baseball just sold out an eight-box case PYT number six, guys. Number six. Here we go, guys. Got a 12-team R&B. Everybody else, of course, bought in straight up. There's a team for the R&B there. All right, first one we got is a Michael Toglaev for Colorado, which is part of the R&B. So that means everybody will get a shot at this as it is unnumbered. So put that to the side. And how about a little Julio Rodriguez, number to 25, 20 out of 25. Golden grass for the Mariners going to Lonnie. Eric, you literally just seen the first two cards right here. We just started the break. You're the first two right there. See you later, man. Go Kings. Yep. Good luck in the second half. Great timing, I know, yeah. Perfect timing. You got Byron Buxton for the Minnesota Twins. Also for the R&B, wow, okay. Two non-numbered cards. And how about a Bo Jackson White Sox? Two out of 10. That one's also for the R&B, but this one actually is numbered. Two. Two is going to Joe. Very nice, man. We got CJ Abrams for the Nationals going all over. Said, oh man. I don't know why I said, oh man. You just got something right now, man. Oh, look at that for the Rangers. Nolan Ryan, 10 out of 20. Rangers. Andy, there you go. All right, after this, halfway through, guys. We got Nick Pirato, Kansas City going ahead.  One out of 25. Did the Yoshida not sign or something? Cause I feel like I haven't pulled in yet. A Langaliers that is going to Oakland, which is also part of the R&B, not number. So three non-numbered R&Bs. And whoo, how about a little Mo? Mariano Rivera. Sean got the Yankee straight up and got rewarded. 14 out of 50. We'll take that, we'll take that. Oh, it's usually redemption. Signing everything for Panini though, Jonathan. What's up with that? Can't sign for top five star? Probably got tired of being in every single flawless case we did. All right, we got Nolan Gorman for St. Louis. Glen and Raymond. And yep, there you go. One Bobby Whip per case. This dude is also all over Panini products too. 12 out of 25. Five to a Phenom. Ed with the Kansas City Royals. We got Reed Demmers for the Angels. 62 out of 75. Angels. R&B two, going to Joe. Both numbers have been spot twos. And I'm a little Chipper Jones. Atlanta Braves going to Rob. All right, last one here guys, good luck. Extra Carter, a book. Jose Canseco. Six out of 20. Six. Oakland, R&B. Going to Ryan H. We got George Springer, nine out of 75. Blue Jays, R&B spot nine. Going to Steve Berry. The last one here is a Grayson Rodriguez for the Orioles, bought by Joe straight up. All right, pretty nice case. Pretty nice case. Got that Chipper Jones, the Bobby Whip, the Gorman, the Moe, the Casas, the Nolan Ryan, Julio. We had quite a few hits actually for the R&B. Springer, Canseco, Detmer, Bo Jackson. And of course we had three non-numbered cards here. So what we'll do is the Michael Togalea was the first hit. That's going to go to number one. This was the second hit that goes to number two. And this is the third hit that goes to number three. So one, two, three in the randomizer for the R&B. We'll evenly give those away. So let's grab that. And let's put your guys' names in. Let's roll. Four to four, eight. One, two, three, four, five, six, seven, eight. Boom, eight times. Eight, four to four, eight. Andy, Matthew, and Ryan. Congratulations, top three. So you guys will each get one of those. Number one, Andy gets Togalea. Number two, gets Bucks, then Matthew. Then Ryan gets Langlears. Thank you guys, of course. Another case is in the store. If you guys want to run it back at some points tonight, down to 24 already. Like I said, we have more baseball, definitive R&B. If you guys want to try a little higher end right there. Obviously Prism's on the 13 and a filler. We'd love to do that. You can pre-order unpackable football for tomorrow. Still a lot of things we can do today, guys. Thank you, jaspyscasebreaks.com.


like we come through life with all these failures right or I don't want to say that we come through life with all this ambition how about that the pursuit of making ourselves better and in that it is surrounded by failure and a lot of the times we're so covered with you know darkness or whatever we you know seeing the light is like fuck that man I'll go I'll go backwards you know so I guess you know what I want to do is ask you about a bunch of different scenarios in your life where that that had happened but in that weight loss that's no I mean yeah well I I attributed to the thing I talked before which is your social circle the guys that you spend the most time with I heard a great quote in a video a while back I forgot who it was but he it's the really common term or common sort of message which is if you surround yourself with nine guys who are really successful they're in really great shape and they do great with women you'll become the 10th and if you hang out with nine guys who are fat broke and dorky you'll also become the 10th no matter what you're like and you know I see it with guys all the time they're they were in shape and like high school college maybe they're athletes you know and after college they move back to wherever they're from maybe albuquerque new Mexico all their friends you know marry some girl around 25 they're all a good 20 30 pounds overweight by 28 with a couple kids and this guy finds himself single what is he going to do well he's going to find you know some 20 to 30 pound overweight girl pop out a couple kids and continue working his corporate job that he hates right and it's not because he's a loser or or anything it's just because that's his world that's who he surrounds himself with so I'd say the biggest key to my success and what I see other guys succeeding it's just surrounding yourself with the right group of people that are going to pull you out of whatever funk you're in and push you towards where you want to go so I've always done a really good job of finding whether it's mentors or friends that are just more successful than I am to basically pull me along and the one thing that I tell guys to do is you have to be able to offer value right if if I want to befriend a guy that's a total beast with chicks and I suck but I'm really good at like programming for example well I'm not going to offer him any value hanging out in a social situation right I'm just going to cock block him with my terrible social skills I probably don't have a lot of like money to offer him but maybe he's in a business where he could use my marketing services or my internet wizardry so you offer value you know you say all right well let me do some programming with you in exchange hang out with me take me out you know take me under your wings show me I hit on girls and I've seen a lot of guys go that route and get a lot better so you have to have some value to offer you know I'll talk to potential clients they'll be like no man I'm broke but uh can we just like hang out and like chill and this may sound harsh this may sound harsh but I'm like dude like why would I hang out with you like you're not going to bring me girls you're not going to bring me money and you're just going to hinder me from you know getting getting more girls or make more money so where's the value so I always looked at it as how can I bring value to other people that I wanted to connect with and have relationships with and that's how I've kind of moved up the social hierarchy and it's been a big key to success so how let me ask you this like because everybody has different values what are the root values that drive your masculinity I mean for me I guess it's always been like the one thing I knew that I could bring to any to any relationship with another guy with some guy that I wanted to be friend was I knew that I had no fear of hitting on girls all night long so guys love going out with me because I will literally talk to every girl who you know is halfway decent looking as a you know two legs two arms and a pulse in an attempt to uh to have a fun night and um you know that if you're just a regular guy who you haven't hung out with a lot of guys that do that like it opens up tons of opportunities you're like all right usually I just go out and have a few beers with my buddies and chit chat but I've talked to 20 girls tonight just because this this guy Robbie has just pulled me out and introduced me to all these people and it's a different experience and they love it so you know that's kind of what I did um you know a few years back to surround myself with guys that I felt were uh you know that I could learn a lot from and so so you can always do that yeah yeah well so what are those things you know like what is it what are the values you surround yourself with so you know when I was uh I was like just getting into this business um I was 25 at the time maybe 26 and um I didn't really have any experience being an entrepreneur had no idea about like marketing I was pretty lazy um you know I played golf in college and then I became like professional online poker player so I just roll out of bed you know get in front of my laptop and crush the poker rooms but then online poker went away in 2007 so I needed a new way to yep yep need a new way to make money um so I was essentially looking for guys that were both very social and had something I could learn from from a money making standpoint and that's how I that's how I kind of targeted these people that I would meet and um I'm a pretty likeable guy that was one of the the things that came natural to me like I listen more than I talk most of the time and people tend to like that if you just take an interest in them yeah um and that wasn't because that was kind of by accident most most of the time I did that just because I didn't really know what to say but I would just listen and ask questions and and then I'd go hit on a lot of girls so we'd have fun together and that fun would create the bond and that would create like a lasting friendship so I guess the the moral of the story is you know find guys that you want to emulate and find a way to add that value whatever way you can't it's not going to be everybody but you only need one or two


The Department of the Navy, and the City of Chattanooga, Tennessee, held a memorial in memory of the four Marines and Sailor, killed at the Navy Operational Support Center shooting July 16th. The service members were honored with military traditions, and Vice President Joe Biden spoke about the devotion each service member had to their country. I didn't have the privilege of knowing any one of them personally, but oh, I knew them. Confident, committed, determined, trustworthy, passionate, and always, always loyal. I knew them. They were my son, and so many other sons I know. The ceremony closed with eco-taps as a final solemn salute. To watch the ceremony, visit navy.new.


The Comet is excited to have this new partnership with the City of Columbia, Blue Bike, Blue Cross Blue Shield of South Carolina, and BWegan to help show multimodal connections between our transit passengers and the city's bike share system. This new partnership that has been entered into allows for the Comet to construct ten new bike share stations over the course of the next several months throughout downtown Columbia, and in addition Comet riders will now be able to utilize the Blue Bike System free of charge by simply getting a code from the bus operator and inputting the code into the bicycles. The nice thing about our buses is that we do have bike racks on the front of all of our buses. They can hold three bicycles, and the Blue Bikes also fit on our bike racks. And we're hoping that this partnership will provide that first mile, last mile extension for those that are coming off the transit system and want to continue to their ultimate destination in downtown Columbia. And we're one of the few transit agencies in the country to actually have such a partnership of this nature. I'd like to introduce Chairman Ron Anderson, who is on the Comet Board of Directors to say a few words. Good morning. I'm Ron Anderson, the Chair of the Comet or the Central Midlands Regional Transit Authority. Thrilled to be here today to inaugurate this joint effort to expand transportation options in the Columbia region. Transportation is not only buses, it's also walking, riding, ride sharing, and private transit. The more mobility options we can provide to the public, the more likely they are to avoid driving, making our air cleaner and our community healthier. Thank you to the political leadership, Blue Cross Blue Shield, and the staff of the city and the bike coalition for allowing the Comet to be part of this great enhancement to our community. Thank you. I'd like to invite Council Member Sam Davis from the City of Columbia to say a few words. Thank you, John. Well, this is one of those days where the progress is continuing. The city is, as you know, very pleased to be in partnership with the Comet and its Board and whose partnership, you know, will not only provide additional stations to the system, but will expand the ridership in the system through offering Comet riders access to the Blue Bike system. Bike share is relatively inexpensive and it's a quick infrastructure extension to the city's public transportation system, allowing it to serve as a convenient last mile connector and function as transit by bike, which is why the partnership with the Comet is so valuable to us. The bike share system is an important component of the bike system. The plan to have bike share stations in many locations in the city is an option to set up temporary stations to support special events taking place throughout the city. And we'd like to really thank and recognize our partners who have helped us get to this point. First and foremost, our title sponsor, Blue Cross Blue Shield of South Carolina, City Bike and Pedestrian Advisory Committee, BPAC, currently chaired by Scott Thorpe and Christina Gallardi, the Palmetto Conservation Coalition and specifically Natalie Britt, who initially and was the first chair of the BPAC as well as Ms. Mary Rowe, Central Midlands Council of Government, the University of South Carolina and Benedict College. So we appreciate the partnership. I'd like to invite Elizabeth Niuoco from Blue Cross Blue Shield. Did I say your last name properly? Unquo? I apologize. How are you? Good morning, everybody. I'm Elizabeth Unquo-Johnson, Director of Community Relations with Blue Cross Blue Shield of South Carolina. I'm pleased to be here today representing Blue Cross for the partnership of Blue Bike SC with the Comet. Blue Cross has a long history of investing in the communities in which it serves, where South Carolina based dedicated to helping our members make good decisions about their health care coverage, their health and their well-being. Blue Bike SC in Columbia is a great example of our corporate citizenship and our desire to contribute to improving the health of our members and our communities. We'd like to support the mayor and his vision for a more walkable and bikeable city because we believed in this effort. The increasing use of Blue Bike SC demonstrates that there are unmet needs. Today, we're pleased to see bike share becoming more accessible to a large number of residents in our community, many who are using the system to get to work, for others who are simply using the bikes for recreation. Riding a bike is a healthy activity that we support and we're excited to play a role in bringing the mayor's vision of a walkable and bikeable city to life. Again, we're so glad to be part of this movement and moving Columbia forward and we're looking forward to seeing more Blue Bikes around our community. Thank you. And lastly, I would like to invite a Shauna Young Pierre from Blue Bike to say a few words. Good morning, everyone. We're just really excited to be working with the comment and excited about expanding our system so soon. And we just invite everyone in Columbia to come out this spring and summer and try us out, especially our e-bikes. They're a lot of fun. You can follow us on Twitter, Instagram, and Facebook at Blue Bike SC. Thank you very much. Again, I want to thank you for joining us. I'm John Ando, the new executive director of the Comet. We're very ecstatic to be doing these innovative mobility ideas to help move the central midlands in the most efficient manner and we'll be happy to answer any questions. I'd also encourage folks that are interested in the Comet Blue Bike Partnership to visit us on our website at thecometsc.gov or contact us at<PHONE_NUMBER>. Thank you very much for joining us. As part of the city's bike master plan, what we're doing is we're converting five of what are called virtual stations to actual docking stations that look like what's behind us. So one of them is in the Bull Street district by Segra Park. Another one will be at Sumter and Divine by USC. I believe there's one closer to the riverfront. And then we're also going to be adding three expansion stations, which one of them will be at the transit center at Laurel and Sumter and then two other locations that I don't have with me at this time. It's still going to remain at 135 bicycles for the time being. And the city does have in their master plan a phase two potential expansion and that's going to require additional funding to expand, to add the additional bicycles in those stations. Which the common will be monitoring and if we see an increase in ridership, we can use some of our federal funds to help continue to build those stations. So what happens is a comment rider would, in essence, start at their home and they would, let's say, walk to a bus stop, ride a comment bus to downtown. And then let's say if their job is at the statehouse, instead of waiting for another comment bus route, they can, in essence, get a bicycle, ride the bicycle to the statehouse, drop it off at one of the docking stations nearby and then they'll be able to have basically that last mile extension to get them to where they need to go. So our goal was to find ways to increase mobility in the central midlands and we were trying to look at ways that we could think beyond the bus and move people that, and also move people and attract people that have never considered public transit before. And we know that we want to have a livable, healthy community and a lot of millennials, for instance, are interested in these innovative ways of getting around. So that's where this bicycle partnership came into play. And public transit is starting to become more multimodal and beyond the bus. So by having partnerships with Bluebike, Uber and Lyft and our van pool program is helping us expand beyond the realm of just moving people with buses and vans. Every year we're supposed to spend 1% of our federal fund for what is called associate transit enhancements and bicycle amenities is treated as an associate transit enhancement. So this allows us to meet FTA's requirements by spending on a bicycle projects. We're spending 250,000 to construct the 10 stations and 70,000 to allow comment users to access the system and helping with those operational costs to support this program.


If you're in the market for a thin and light notebook, chances are high you're going to look at the new ZenBook S13 OLED with the codename UM5302. This device is an amazing sidekick, delivering exceptional performance and efficiency thanks to its Ryzen 6000 series CPUs while the OLED panel is unmatched when it comes to colors. The S13 gets all of this while being incredibly lightweight, weighing only a kilo and having a profile of 14.9 millimeters. The aluminum magnesium alloy helps a lot to achieve such a low weight, leaving an anodized finish. The notebook complies with the MIL-STD-810H certification tests, so you can rest assured that the device is well built and won't break down on you anytime soon. The base and palm rest area are also treated with a Seuss' antibacterial guard, which inhibits the growth of bacteria by 99% over a 24-hour period. It's made to last for up to three years, so we hope there won't be another virus outbreak, like COVID-27 or something. Anyway, the lid can be opened with one hand, showing off a well-organized base. It also lifts up the back slightly for better cooling and ergonomics. We've got a fingerprint reader inside the power button, along with a great keyboard with long key travel and clicky feedback. The keycaps are made to be more comfortable, with a dish design that matches the shape of your fingertips. We also can't forget the number pad, which allows for even the smallest of devices to have an alternative to a touchpad. The I.O. includes two USB Type-C 3.2 Gen2 ports and an audio jack on the right, while a third Type-C port is found on the left. The ports do have support for power delivery and display port 1.4. There's also a Type-A to Type-C dongle in the box. The laptop's most striking feature is the 2.8K OLED panel, which is super crisp at 13.3 inches. It comes with a 16 by 10 aspect ratio, which results in a taller display that's able to fit more pixels in the same form factor. It also supports the ASUS pen, which has to be purchased separately. The screen has a peak brightness of 400 nits in SDR, but can go up to 550 nits in HDR content, so it's bright enough for working outside. The ZenBook S13 OLED covers 100% of the DCI-P3 gamut, also known as the Digital Cinema Standard, and it has excellent color accuracy. There is some PWM usage below 92 nits, however the MyASUS app includes a flicker-free dimming option, which eliminates the pulsations completely, while still keeping the colors fairly accurate with a DE value of 2.1. Considering that with the PWM on, you get a DE value of 1.8, we think it's worth the sacrifice. There's a competent sound setup with two bottom-firing speakers on the bottom, which do have Dolby Atmos support. The unit has been tuned and approved by Harman Kardon, showing no noticeable deviations from clarity across the entire frequency range. Only 2 per 100 people watching this video are subscribers. If you decide to just start following us, we'll be able to reinvest more in our laboratory, thus making even more helpful videos for you. Thank you, you're awesome! The 67W hour battery is enough to sustain the Ryzen 6000U series chips for a while. In our tests with the Ryzen 7 6800U, the unit lasts for 11 hours and 40 minutes of web browsing, or 15 hours and 56 minutes of video playback. That's a lot! There's also fast charging, so you can get up to 60% in just 49 minutes. With the Ryzen 5 6600U, you can expect even longer battery life, as there would be too fewer cores to power up. Going back to the Ryzen 7, it's a great performer inside the ZenBook S13. Considering the size of the machine, it's able to trade blows with many competitors on the market. The RDNA 2 IGPU is also nothing to scoff at, bringing encoding support that can be used for video editing. You can also take breaks and play some games, but you should probably stick to lighter games and esports titles. Cooling inside small laptops can be tricky, as it's important to strike a balance between performing well and keeping temps within reasonable levels. This laptop comes with one heat pipe and one fan, which are enough to sustain the Ryzen 7. To do that, Asus needs to lower the wattage a bit, which does lead to less performance overall. However, it means the laptop runs cooler and is quieter in the long run. The 14-inch Yoga 7 from Lenovo squeezes out higher clock speeds from the CPU while running cooler, but it also has more space to work with, so you'd have to judge for yourself what you value more. The ZenBook S13 OLED is offered with up to 16GB of soldered dual-channel LPDDR5 memory. While for storage, you get one M.2 slot for Gen4 SSDs. Our teardown video shows how to get to the SSD, so we'll link it below. Leading the charge when it comes to performance per gram, the ZenBook S13 OLED is more than a compact machine. It can be a fully-fledged video editing rig that you can carry everywhere with you or a premium daily driver that has style and class. For a better look at the laptop, why don't you swing by our website and read the full in-depth review.