Morningstar's Russ Kinnel has posted a very good overview of how fund fees work in the mutual fund industry.
While he is alittle soft on the industry's fees--he says the fund industry "has developed a rather odd fee setup over the decades"--his overall explanation is good.
The fund's fee setup is more than "rather odd"; it is intentionally vague and misleading and has been intentionally convoluted by some very expensive lawyers over the decades. That's one reason why corporate 401(k) plan sponsors cannot get a straight answer to their straightforward question: How much does my plan cost to administer?
Kinnel and I note that the fund industry is not competitive. I contend that most fund companies are culturally unable to compete if their artificial protection (in the form of fixed fees) is ever removed. As a result, any fee reform could result in a significant consolidation in the fund business.
Kinnel also points out that fund supermarkets, such as Charles Schwab, artifically inflates all shareholder fees because any fund which wants to be listed on a supermarket's fund platform cannot offer lower fees to shareholders who want to buy directly from the fund company itself. To a non-lawyer, that sounds like price fixing.
There is certainly more in Kinnel's article which is worth reaading, but the most welcome news is that 12b-1 fee reform is gradually going to gecome front-page business news. Unfortunately for millions of mutual fund shareholders, this critical issue took a few decades to get noticed.
Monday, July 26, 2010
Thursday, July 22, 2010
At Long Last: SEC Fee Reform Proposal Finally Arrives
After decades of wrangling, false starts, and back room intrigues, it looks like the SEC is finally addressing the long-over due, critical issue of mutual fund fees.
Today, these fees charged to fund shareholders amount to $12 billion, according to the SEC. Yet, despite this huge amount, shareholders have no idea what they are paying for.
Also known as 12b-1 fees in the fund industry, SEC Chairwoman Mary Schapiro said in a July 21 release:
"Despite paying billions of dollars, many investors do not understand what 12b-1 fees are, and it's likely that some don't even know that these fees are being deducted from their funds or who they are ultimately compensating. Our proposals would replace rule 12b-1 with new rules designed to enhance clarity, fairness and competition when investors buy mutual funds."
What the Fees Pay For
Ostensibly, these fees were introduced in the late-1970s to pay for fund marketing expenses to help funds gather more assets. The cover story at the time was that as funds grew in size (gathered more assets under management), they could reach a scale of economy and reduce their overall fund expense. As a result, shareholders would pay less in expenses and have more money in their fund accounts.
That was the theory.
In the intervening years, however, fund expense ratios generally have risen, but fee reductions have not been reduced proportionately. Instead, these fees support very differnt activities. On the negative side, they promote bloated marketing operations, pay near-unlimited expenses for fund wholesalers, support top-heavy sales organizations. But they also pay for beneficial activities, such as a basic level of shareholder communications, redemption processing, and account servicing departments.
The problem is that the needed and extravagant services are bundled together, so it impossible for shareholders to separate the two. Another problem is that fund expenses have not been reduced proportionately as fund assets have increased. As a result, the bottom line is that shareholders are paying for a fund company's growth, yet they are not receiving the benefits of this growth in the form of reduced total expenses.
It's Just a Proposal
While this problem is well-defined and has been well known within the fund industry for decades, it has now just reached the proposal stage. The powerful fund lobbying organization (the Investment Company Institute) will certainly work against any significant fee reform.
But given the climate in Washington and the passage of the financial reform bill, the SEC's actions are a beginning.
Here is what the SEC would like to accomplish:
--Protect investors by limiting fund sales charges.
--Improve transparency of fees for investors.
--Encourage retail price competition.
--Revise fund director oversight duties.
Of these, the most important goal is price competition. As a matter of fact, any form of competition in the mutual fund industry will be a welcome change from the vast commoditization among look-alike funds with index-like returns which exist today.
If funds compete, it will revolutionize the entire fund industry. However, for those funds which seek to make the change into a new, competitive environment, it will be a wrenching experience. It will require the entire revamping of many fund marketing departments, and possibly a fund company's entire culture.
This is because too many fund companies do not have a competitive mentality. As it stands today, many fund marketing professionals and wholesalers think they are competing when they show an ad touting their fund's latest change in a Morningstar or Lipper ranking. That may constitute sales literature, but it in not competing.
On the plus side, competition has come from ETFs (Exchange Traded Funds) which are index products which have specific benefits in terms of trading (they are continuously priced) and fees (they are invariably cheaper than mutual funds.) This explains why ETFs are now more popular than mutual funds.
While the ETF choice benefits many investors, millions of other investors cannot access ETFs via their 401(k) plans. This puts them at a disadvantage not only in terms of restricting their access to more specific sectors of the markets (both equities and fixed), but also in terms of gaining the benefits of long-term costs savings from paying lower expenses.
Long Overdue
In an earlier report, Ms. Schapiro said 12b-1 fee reform would be done by the end of 2008, so we can assume the SEC has had many tense meetings over this issue. While the end result remains uncertain, it's clear that any fee reform which puts more money into the hands of shareholders is decades overdue.
Today, these fees charged to fund shareholders amount to $12 billion, according to the SEC. Yet, despite this huge amount, shareholders have no idea what they are paying for.
Also known as 12b-1 fees in the fund industry, SEC Chairwoman Mary Schapiro said in a July 21 release:
"Despite paying billions of dollars, many investors do not understand what 12b-1 fees are, and it's likely that some don't even know that these fees are being deducted from their funds or who they are ultimately compensating. Our proposals would replace rule 12b-1 with new rules designed to enhance clarity, fairness and competition when investors buy mutual funds."
What the Fees Pay For
Ostensibly, these fees were introduced in the late-1970s to pay for fund marketing expenses to help funds gather more assets. The cover story at the time was that as funds grew in size (gathered more assets under management), they could reach a scale of economy and reduce their overall fund expense. As a result, shareholders would pay less in expenses and have more money in their fund accounts.
That was the theory.
In the intervening years, however, fund expense ratios generally have risen, but fee reductions have not been reduced proportionately. Instead, these fees support very differnt activities. On the negative side, they promote bloated marketing operations, pay near-unlimited expenses for fund wholesalers, support top-heavy sales organizations. But they also pay for beneficial activities, such as a basic level of shareholder communications, redemption processing, and account servicing departments.
The problem is that the needed and extravagant services are bundled together, so it impossible for shareholders to separate the two. Another problem is that fund expenses have not been reduced proportionately as fund assets have increased. As a result, the bottom line is that shareholders are paying for a fund company's growth, yet they are not receiving the benefits of this growth in the form of reduced total expenses.
It's Just a Proposal
While this problem is well-defined and has been well known within the fund industry for decades, it has now just reached the proposal stage. The powerful fund lobbying organization (the Investment Company Institute) will certainly work against any significant fee reform.
But given the climate in Washington and the passage of the financial reform bill, the SEC's actions are a beginning.
Here is what the SEC would like to accomplish:
--Protect investors by limiting fund sales charges.
--Improve transparency of fees for investors.
--Encourage retail price competition.
--Revise fund director oversight duties.
Of these, the most important goal is price competition. As a matter of fact, any form of competition in the mutual fund industry will be a welcome change from the vast commoditization among look-alike funds with index-like returns which exist today.
If funds compete, it will revolutionize the entire fund industry. However, for those funds which seek to make the change into a new, competitive environment, it will be a wrenching experience. It will require the entire revamping of many fund marketing departments, and possibly a fund company's entire culture.
This is because too many fund companies do not have a competitive mentality. As it stands today, many fund marketing professionals and wholesalers think they are competing when they show an ad touting their fund's latest change in a Morningstar or Lipper ranking. That may constitute sales literature, but it in not competing.
On the plus side, competition has come from ETFs (Exchange Traded Funds) which are index products which have specific benefits in terms of trading (they are continuously priced) and fees (they are invariably cheaper than mutual funds.) This explains why ETFs are now more popular than mutual funds.
While the ETF choice benefits many investors, millions of other investors cannot access ETFs via their 401(k) plans. This puts them at a disadvantage not only in terms of restricting their access to more specific sectors of the markets (both equities and fixed), but also in terms of gaining the benefits of long-term costs savings from paying lower expenses.
Long Overdue
In an earlier report, Ms. Schapiro said 12b-1 fee reform would be done by the end of 2008, so we can assume the SEC has had many tense meetings over this issue. While the end result remains uncertain, it's clear that any fee reform which puts more money into the hands of shareholders is decades overdue.
Friday, July 16, 2010
Get Your Own Money Back from Undisclosed Revenue Sharing Deals
This site has detailed the need for mutual fund financial reform, so it was naturally interested in what is now known as the 2,319-page long Dodd-Frank Wall Street Reform and Consumer Protection Act.
We also did not expect anything significant when it came to changing the way mutual funds are sols. That is why there has not been a change in revenue sharing deals, fee disclosures, the adoption of fiduciary responsibilities, and reductions in 12b-1 fees.
This Bill does not address any of these issues. That’s a shame since it means millions of Americans will remain in a dangerous position when it comes to planning and living in retirement.
But individual investors have some great options to level the playing field, especially in regard to recovering some of the fee money which mutual fund companies pay to financial advisors and investment reps.
In many cases, especially when money has been invested in a fund for many years, these fees translate into thousands of dollars paid to brokers. The worst part is that you, the individual mutual fund investor, have no idea that it was your money which generated the fees in the first place.
While this entire revenue sharing arrangement should be regulated, it is not. As a result, this is strictly an ethical situation. The beauty of this is that any individual investor can ask some simple questions and determine if they are dealing with an ethical financial rep. If not, you should take action. Read on to find out more.
Here’s how this works:
1. You go to your investment professional for some “objective” advice about which of the thousands of mutual funds is “best” for you.
2. 2. Since there are so many look-alike funds in any fund category (such as large-cap growth or small-cap value), your investment rep can get paid by some fund companies to promote a certain fund over another. If you buy the fund he “objectively” recommends to you, the investment rep gets paid for as long as you own the fund. This gives him or her a monetary incentive to keep you invested in that individual fund or an entire fund family through bad markets. He or she can keep you in that fund even if there is another which is better suited to your needs or has a lower expense ratio.
3. The worst part is that 90% of the time, you are never told about these “revenue sharing” deals. In some cases, these deals have been known to pay from 50 basis points to150 basis points per account per quarter paid to financial reps for decades. Shareholders never receive a penny of these fees, which commonly range into thousands of dollars per year paid to reps.
Don’t forget: It is your money which is generating this fee in the first place.
Get Your Own Money Back
This article started by noting that the financial reform act has nothing to do with revenue sharing. But you can still call your rep, or better yet, go in person with a friend or relative, and ask these questions:
1. Did you ever receive revenue sharing money from any mutual fund company for my investments in certain mutual funds?
2. If so, how much did you receive?
3. Why do you think you deserve this money?
4. Now here is the clincher: Tell them you would like all, or some, of this money paid back to you.
This Will Be Life Lesson For You
This short discussion will tell you a lot about the person you are dealing with. It can mean the end or the start of a relationship.
Listen carefully to hear if they can justify why your money earned them a large fee over the years. Ask if they consider this is a conflict of interest? How can they balance your needs for “objective” advice against receiving revenue sharing? Ask when you can expect to receive your money?
If you don’t get exceptionally acceptable answers which put your financial interests ahead of the need to receive revenue sharing, it is time to act. Find a new rep or transfer your assets to a new no-load fund company. Do not remain with a rep who does not put your interests first.
Note that even independent financial planners take revenue sharing money, so do not assume that your rep is ”objective” unless you specifically ask about revenue sharing deals.
We also did not expect anything significant when it came to changing the way mutual funds are sols. That is why there has not been a change in revenue sharing deals, fee disclosures, the adoption of fiduciary responsibilities, and reductions in 12b-1 fees.
This Bill does not address any of these issues. That’s a shame since it means millions of Americans will remain in a dangerous position when it comes to planning and living in retirement.
But individual investors have some great options to level the playing field, especially in regard to recovering some of the fee money which mutual fund companies pay to financial advisors and investment reps.
In many cases, especially when money has been invested in a fund for many years, these fees translate into thousands of dollars paid to brokers. The worst part is that you, the individual mutual fund investor, have no idea that it was your money which generated the fees in the first place.
While this entire revenue sharing arrangement should be regulated, it is not. As a result, this is strictly an ethical situation. The beauty of this is that any individual investor can ask some simple questions and determine if they are dealing with an ethical financial rep. If not, you should take action. Read on to find out more.
Here’s how this works:
1. You go to your investment professional for some “objective” advice about which of the thousands of mutual funds is “best” for you.
2. 2. Since there are so many look-alike funds in any fund category (such as large-cap growth or small-cap value), your investment rep can get paid by some fund companies to promote a certain fund over another. If you buy the fund he “objectively” recommends to you, the investment rep gets paid for as long as you own the fund. This gives him or her a monetary incentive to keep you invested in that individual fund or an entire fund family through bad markets. He or she can keep you in that fund even if there is another which is better suited to your needs or has a lower expense ratio.
3. The worst part is that 90% of the time, you are never told about these “revenue sharing” deals. In some cases, these deals have been known to pay from 50 basis points to150 basis points per account per quarter paid to financial reps for decades. Shareholders never receive a penny of these fees, which commonly range into thousands of dollars per year paid to reps.
Don’t forget: It is your money which is generating this fee in the first place.
Get Your Own Money Back
This article started by noting that the financial reform act has nothing to do with revenue sharing. But you can still call your rep, or better yet, go in person with a friend or relative, and ask these questions:
1. Did you ever receive revenue sharing money from any mutual fund company for my investments in certain mutual funds?
2. If so, how much did you receive?
3. Why do you think you deserve this money?
4. Now here is the clincher: Tell them you would like all, or some, of this money paid back to you.
This Will Be Life Lesson For You
This short discussion will tell you a lot about the person you are dealing with. It can mean the end or the start of a relationship.
Listen carefully to hear if they can justify why your money earned them a large fee over the years. Ask if they consider this is a conflict of interest? How can they balance your needs for “objective” advice against receiving revenue sharing? Ask when you can expect to receive your money?
If you don’t get exceptionally acceptable answers which put your financial interests ahead of the need to receive revenue sharing, it is time to act. Find a new rep or transfer your assets to a new no-load fund company. Do not remain with a rep who does not put your interests first.
Note that even independent financial planners take revenue sharing money, so do not assume that your rep is ”objective” unless you specifically ask about revenue sharing deals.
Monday, June 28, 2010
Breaking the Myth of Wholesaler Storytelling
Every financial professional is told they need a great "story" about their mutual fund inorder to build a relationship with a financial professional.
In turn, this same story-telling fetish is supposed to become the holy grail when a financial professional meets with a client.
The problem is that the validity of these stories always hinges on the credibility of the storyteller.
As seen in this video , the storyteller must establish their credibility based on what they tell the prospect.
This video is part of the multi-million dollar mutual fund wholesaler entertainment industry. Shareholders have no idea that this industry even exists, but they are paying for it on a weekly basis as part of the education-entertainment process which fund companies think is needed to keep their sales force interested in their jobs.
Of course, this is nonsense. Fund wholesalers are exceptionally well-paid. But since the fund industry is so commoditized, wholesalers basically have little to talk about with the investment advisers they call on, aside from some data, which is fleeting and boring. Hence the need for motivational sales presentations by former jet pilots, retired athletes, and seasoned mountain climbers.
But in all of these expensive presentations, the key thing which is missing is information about the storyteller. More importantly what are the storyteller's real motives?
Hidden Motives
This gets us to the issue of fiduciary responsibility. The recent financial reform debate killed this key issue--fiduciary responsibility--because it would essentially mean the storyteller (the wholesaler or financial professional) would have to disclose their financial motivation for promoting a certain fund over another.
In too many cases, the storyteller would have to admit they are getting an extra fee to both sign up the investor and then they would collect that fee for as long as the investor owned the fund. This fee would be paid whether the fund made or lost money. In good times and bad, the storyteller would make money.
Caveat Emptor
If you were an investor, how would you react to this news?
From the investor's point of view, it's basically "heads you win, tails I lose."
This does not make for a great story, regardless of how convincing the storyteller in this video can become.
It is also the reason why the mutual fund industry killed the fiduciary standard.
But if you are a fee-only financial planner or an investment professional which wants to tell a very different story, you now have the opportunity to differentiate yourself from your competition.
If you tell a story which excludes any reference to 12b-1 fees or revenue sharing deals, you can tell a story with has a better chance of concluding with a happy ending.
In turn, this same story-telling fetish is supposed to become the holy grail when a financial professional meets with a client.
The problem is that the validity of these stories always hinges on the credibility of the storyteller.
As seen in this video , the storyteller must establish their credibility based on what they tell the prospect.
This video is part of the multi-million dollar mutual fund wholesaler entertainment industry. Shareholders have no idea that this industry even exists, but they are paying for it on a weekly basis as part of the education-entertainment process which fund companies think is needed to keep their sales force interested in their jobs.
Of course, this is nonsense. Fund wholesalers are exceptionally well-paid. But since the fund industry is so commoditized, wholesalers basically have little to talk about with the investment advisers they call on, aside from some data, which is fleeting and boring. Hence the need for motivational sales presentations by former jet pilots, retired athletes, and seasoned mountain climbers.
But in all of these expensive presentations, the key thing which is missing is information about the storyteller. More importantly what are the storyteller's real motives?
Hidden Motives
This gets us to the issue of fiduciary responsibility. The recent financial reform debate killed this key issue--fiduciary responsibility--because it would essentially mean the storyteller (the wholesaler or financial professional) would have to disclose their financial motivation for promoting a certain fund over another.
In too many cases, the storyteller would have to admit they are getting an extra fee to both sign up the investor and then they would collect that fee for as long as the investor owned the fund. This fee would be paid whether the fund made or lost money. In good times and bad, the storyteller would make money.
Caveat Emptor
If you were an investor, how would you react to this news?
From the investor's point of view, it's basically "heads you win, tails I lose."
This does not make for a great story, regardless of how convincing the storyteller in this video can become.
It is also the reason why the mutual fund industry killed the fiduciary standard.
But if you are a fee-only financial planner or an investment professional which wants to tell a very different story, you now have the opportunity to differentiate yourself from your competition.
If you tell a story which excludes any reference to 12b-1 fees or revenue sharing deals, you can tell a story with has a better chance of concluding with a happy ending.
Retirement Becomes an Issue Worldwide
Retirement is again front page news.
In the past week, two major stories have developed over the issue of delayed retirement.
The first story concerns the renewed clamor for delaying the retirement age in America. This story addresses why some states are pushing to increase the retirement age for state workers as a means of reducing skyrocketing pension obligations as a means of reducing huge deficits.
The second story puts an international spin on this same problematic issue. As part of its austerity moves, France is pushing to make mandatory retirement age from 60 to 62, which is still among the lowest in Europe.
While this is only a two year difference, about one million French students hit the streets in protest and cited some key issues which relate to their national culture, quality of life and workers' rights.
While these stories are a continent apart, they are clearly linked around a few basic questions:
--The nature of work;
--The quality of life;
--The limitations of investment strategies alone to provide a secure financial future, and;
--What people should rightfully expect after committing to a lifetime of work.
These are profound social issues which have yet to be addressed on a national scale in the U.S. The mutual fund industry, which claims it is concerned with retirement, finds this issue too hot to handle. Instead, they escape into discussions about fund performance and portfolio diversification, which are important, but neglect the ultimate goal of retirement investing.
The fund industry is too distracted or is intentionally avoiding these issues, but it cannot avoid them forever. The challenge of Exchange Traded Funds (ETFs), for instance, focus attention on the benefits of indexed, lower-cost investments. Then there are the entire issues about whether shareholders are benefiting from active management, or paying high fees.
These are sensitive issues, but can be put into better context if fund marketing executives look at retirement from a larger perspective to include the issues raised above, as well as the impact of declining housing wealth, rising medical costs, the danger of inflation, lower equity-risk premiums, and rising market volatility.
While some financial tools are helpful, others, such as Monte Carlo simulations, often raise more questions than answers. After all, who knows what tomorrow will bring in terms of such defining issues as health and job loss?
Then, there is the hard reality that new investment strategies and vehicles cannot compensate for an investment shortfall. Pension funds are increasing their exposures to hedge funds, according to Greenwich Associates, but at commensurate risks. And even if leveraged or non-traditional strategies delivered on their promises to provide alpha, most individual investors do not have the luxury of being qualified investors.
A select few companies in the fund industry can re-invent themselves by beginning to address these larger issues with their shareholders. These also are the companies which can differentiate themselves from the pack and best serve their shareholders.
Story Source: "French youths protest over higher retirement age," Yahoo! News, June 27, 2010
In the past week, two major stories have developed over the issue of delayed retirement.
The first story concerns the renewed clamor for delaying the retirement age in America. This story addresses why some states are pushing to increase the retirement age for state workers as a means of reducing skyrocketing pension obligations as a means of reducing huge deficits.
The second story puts an international spin on this same problematic issue. As part of its austerity moves, France is pushing to make mandatory retirement age from 60 to 62, which is still among the lowest in Europe.
While this is only a two year difference, about one million French students hit the streets in protest and cited some key issues which relate to their national culture, quality of life and workers' rights.
While these stories are a continent apart, they are clearly linked around a few basic questions:
--The nature of work;
--The quality of life;
--The limitations of investment strategies alone to provide a secure financial future, and;
--What people should rightfully expect after committing to a lifetime of work.
These are profound social issues which have yet to be addressed on a national scale in the U.S. The mutual fund industry, which claims it is concerned with retirement, finds this issue too hot to handle. Instead, they escape into discussions about fund performance and portfolio diversification, which are important, but neglect the ultimate goal of retirement investing.
The fund industry is too distracted or is intentionally avoiding these issues, but it cannot avoid them forever. The challenge of Exchange Traded Funds (ETFs), for instance, focus attention on the benefits of indexed, lower-cost investments. Then there are the entire issues about whether shareholders are benefiting from active management, or paying high fees.
These are sensitive issues, but can be put into better context if fund marketing executives look at retirement from a larger perspective to include the issues raised above, as well as the impact of declining housing wealth, rising medical costs, the danger of inflation, lower equity-risk premiums, and rising market volatility.
While some financial tools are helpful, others, such as Monte Carlo simulations, often raise more questions than answers. After all, who knows what tomorrow will bring in terms of such defining issues as health and job loss?
Then, there is the hard reality that new investment strategies and vehicles cannot compensate for an investment shortfall. Pension funds are increasing their exposures to hedge funds, according to Greenwich Associates, but at commensurate risks. And even if leveraged or non-traditional strategies delivered on their promises to provide alpha, most individual investors do not have the luxury of being qualified investors.
A select few companies in the fund industry can re-invent themselves by beginning to address these larger issues with their shareholders. These also are the companies which can differentiate themselves from the pack and best serve their shareholders.
Story Source: "French youths protest over higher retirement age," Yahoo! News, June 27, 2010
Friday, June 25, 2010
Modified Consumer Reform Bill Passes
After monumental debate and lobbying expenses which ranged up to a few hundred thousand dollaors a day, the financial services industry reform bill has passed some key hurdle. It now goes to Congres and the President for final passage, but it remains to be seen how it will benefit individual mutual fund shareholders.
The key provision of this bill which would concern sharholders had to do with fiduciary responsibilities, specifically how investment porfessionals would work with their clients. The fiduciary standard would mandate that advisers provide objective, direct advice, devoid of any distractions caused by 12b-1 fee and other incentives,
This article explains the qualified benefits to investors.
The reality is that investors still must be vigilant if they want a secure retirement and investments which have low fees.
For most people, this will still be an elusive goal. The financial reform bill did not even come close to addressing the issue of a secure retirement.
The key provision of this bill which would concern sharholders had to do with fiduciary responsibilities, specifically how investment porfessionals would work with their clients. The fiduciary standard would mandate that advisers provide objective, direct advice, devoid of any distractions caused by 12b-1 fee and other incentives,
This article explains the qualified benefits to investors.
The reality is that investors still must be vigilant if they want a secure retirement and investments which have low fees.
For most people, this will still be an elusive goal. The financial reform bill did not even come close to addressing the issue of a secure retirement.
Thursday, May 20, 2010
New Financial Consumer Legislation Ahead
After a contentious battle, the Senate has agreed to move ahead with debate on new protections for individual investors. The proposed new legislation passed by a vote of 60-40 and ended over three weeks of debate on the measure.
While details are still pending, the new legislation would curtail some derivatives trading and stop banks from trading against positions held by their clients. Large mutual fund companies would be exempt from the trading limits contained in this provision, the Wall Street Journal reported.
In addition, the bill would create a new regulator, which would be part of the Federal Reserve, to protect consumers from any abusive financial practices, ranging from home mortgages to credit cards.
While details are still pending, the new legislation would curtail some derivatives trading and stop banks from trading against positions held by their clients. Large mutual fund companies would be exempt from the trading limits contained in this provision, the Wall Street Journal reported.
In addition, the bill would create a new regulator, which would be part of the Federal Reserve, to protect consumers from any abusive financial practices, ranging from home mortgages to credit cards.
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