On his fourth trip to the U.S. as Indian Prime Minister, Narendra Modi will spend some quality time on Capitol Hill on Wednesday, where he'll address a joint meeting of the U.S. Congress. House Speaker Paul Ryan will also host the Indian premier for a lunch, which will be followed by a reception hosted jointly by the House and Senate Foreign Relations Committees and the India Caucus. What's the significance of this Congressional engagement and what might be Modi's message? 

Given that all the most-recent Indian leaders who've held five-year terms have addressed such joint meetings of Congress, some have asked whether Ryan's invitation to Modi is a big deal. The answer is, yes, it is an honour and not one extended all that often. Since 1934, there have been only 117 such speeches. Leaders from France, Israel and the United Kingdom have addressed joint meetings the most times (8 each), followed by Mexico (7), and Ireland, Italy and South Korea (6 each). With this speech, India will join Germany on the list with leaders having addressed 5 joint meetings of Congress: Rajiv Gandhi in 1985, P.V. Narashima Rao in 1994, Atal Bihari Vajpayee in 2000 and Manmohan Singh in 2005. India's first premier, Jawaharlal Nehru, spoke to the House and Senate in separate back-to-back sessions in 1949 as well. 

Congress is a key stakeholder in the U.S.-India relationship and can play a significant supportive or spoiler role. While American presidents have a lot more lee-way on foreign policy than domestic policy, Congress is not without influence on U.S. foreign relations, and shapes the context for American engagement abroad. Moreover, the breadth and depth of the U.S.-India relationship, as well as the blurring of the line between what constitutes domestic and foreign policy these days means that India's options can be affected by American legislative decisions or the political mood on a range of issues from trade to immigration, energy to defense. 

The Indian Foreign Secretary recently said that the U.S. legislature was at "very much at the heart" of the relationship today. He noted it has been "very supportive" and "even in some more difficult days where actually the Congress has been the part of the US polity which has been very sympathetic to India." But India's had rocky experiences on the Hill as well--which only heightens the need to engage members of Congress at the highest levels. 

The speech and the other interactions offer Modi an opportunity to acknowledge the role of Congress in building bilateral relations, highlight shared interests and values, outline his vision for India and the relationship, as well as tackle some Congressional concerns and note some of India's own. He'll be speaking to multiple audiences in Congress, with members there either because of the strategic imperative for the relationship, others because of the economic potential, yet others because of the values imperative--and then there are those who'll be there because it is important to their constituents, whether business or the Indian diaspora. There is also the audience outside Congress, including in India, where the speech will play in primetime. What will Modi's message be? A glimpse at previous speeches might offer some clues, though Modi is likely also to want to emphasize change. 

The speeches that came before

The speeches of previous prime ministers have addressed some common themes. They've acknowledged shared democratic values. They've mentioned the two-way flow of inspiration and ideas with individuals like Henry David Thoreau, Mahatma Gandhi, Martin Luther King getting multiple mentions. They've noted the influence of American founding documents or fathers on the Indian constitution. They've highlighted India's achievements, while stressing that much remains to be done. 

They've noted their country's diversity, and the almost-unique task Indian leaders have had--to achieve development for hundreds of millions in a democratic context. Since Gandhi, each has mentioned the Indian diaspora, noting its contributions to the U.S. Each prime minister has also expressed gratitude for American support or the contribution the U.S. partnership has made to India's development and security. They've acknowledged differences, without dwelling on them. They've addressed contemporary Congressional concerns that existed about Indian policy--in some cases offering a defense of them, in others' explaining the reason behind the policy.

Many of the premiers called for Congress to understand that India, while a democracy like the U.S. and sharing many common interests, would not necessarily achieve its objectives the same way as the U.S. And each subtly has asked for time and space, accommodation and support to achieve their goals--and argued it's in American interests to see a strong, stable, prosperous, democratic India.

In terms of subjects, each previous speech has mentioned economic growth and development as a key government priority, highlighting what policymakers were doing to achieve them. Since Gandhi, all have mentioned nuclear weapons though with different emphases: he spoke of disarmament; Rao of de-nuclearization and concerns about proliferation; two years after India's nuclear test, Vajpayee noted India's voluntary moratorium on testing and tried to reassure Congress about Indian intentions; and speaking in the context of the U.S.-India civil nuclear talks, Singh noted the importance of civil nuclear energy and defended India's track record on nuclear non-proliferation.

Since Rao, every prime minister has mentioned the challenge that terrorism posed for both the U.S. and India, with Vajpayee and Singh implicitly noting the challenge that a neighboring country poses in this regard from India's perspective. And Rao and Singh made the case for India to get a permanent seat on the U. N. Security Council.

The style of the speeches has changed, as has the tone. Earlier speeches were littered with quotes from sources like Christopher Columbus, Swami Vivekananda, Abraham Lincoln, Lala Lajpat Rai and the Rig Veda. Perhaps that was reflective of the style of speechwriting in those eras, but perhaps it was also because there were fewer concrete issues in the bilateral relationship to address. The evolution in the areas of cooperation is evident in the speeches. 

Rao's speech about two decades ago, for instance, listed U.S.-India common interests as peacekeeping, environmental crises, and combating international terrorism and international narcotics trafficking. Compare that to Singh's address which talked of cooperation on a range of issues from counterterrorism, the economy, agriculture, energy security, healthy policy, humanitarian assistance and disaster relief (HADR), democracy promotion, and global governance.

The speech yet to come

Modi will likely strike some similar themes, acknowledging the role that the U.S. Congress has played in shaping the relationship and expressing gratitude for its support. Like Vajpayee, particularly in a U.S. election year, Modi might note the bipartisan support the relationship has enjoyed in recent years. He'll undoubtedly talk about shared democratic values in America's "temple of democracy"--a phrase he used for the Indian parliament when he first entered it after his 2014 election victory. Modi will not necessarily mention the concerns about human rights, trade and investment policies, non-proliferation or India's Iran policy that have arisen on the Hill, but he will likely address them indirectly. 

For example, by emphasizing India's pluralism and diversity and the protection its Constitution gives to minorities, or the constructive role the country could play regionally (he might give examples such as the recently inaugurated dam in Afghanistan). Given the issues on the bilateral agenda, he'll likely mention the strategic convergence, his economic policy plans, terrorism, India's non-proliferation record, defense and security cooperation, and perhaps--like Vajpayee--the Asia-Pacific (without directly mentioning China). And like Vajpayee, he might be more upfront about Indian concerns and the need to accommodate them. 

While he might strike some similar themes as his predecessors and highlight aspects of continuity, Modi will also want to emphasize that it's not business as usual. He'll likely try to outline the change that he has brought and wants to bring. In the past, he has noted the generational shift that he himself represents as the first Indian prime minister born after independence and the Modi government's latest tag line is, of course, "Transforming India." And he might emphasize that this changed India represents an opportunity for the U.S.

He won't wade directly into American election issues, but might note the importance of U.S. global engagement. He might also try to address some of the angst in the U.S. about other countries taking advantage of it and being "takers." He could do this by making the case that India is not a free rider--that through its businesses, market, talent and diaspora it is contributing to American economy and society, through its economic development it will contribute to global growth, and through Indian prosperity, security and a more proactive international role--with a different approach than another Asian country has taken--it'll contribute to regional stability and order. He might also suggest ways that the U.S. can facilitate India playing such a role.

Unlike previous leaders, he has not tended to appeal to others not to ask India to do more regionally and globally because it's just a developing country and needs to focus internally. The Modi government has been highlighting the contributions of India and Indians to global and regional peace and prosperity--through peacekeeping, the millions that fought in the World Wars, HADR operations in its neighborhood, evacuation operations in Yemen in which it rescued not just Indian citizens, but Americans as well.

His government has been more vocal in joint contexts of expressing its views on the importance of a rules-based order in the Asia-Pacific and Indian Ocean regions--and we might hear more on this in his address. Overall, a theme will likely be that India is not just a "taker," and will be a responsible, collaborative stakeholder.

It'll be interesting to see whether the Indian prime minister notes the role that his predecessors have played in getting the relationship to this point. With some exceptions--for example, he acknowledged Manmohan Singh's contribution during President Obama's visit to India last year--he has not tended to do so. But there's a case to be made for doing so--it can reassure members of Congress that the relationship transcends one person or party and is based on a strategic rationale, thus making it more sustainable. Such an acknowledgement could be in the context of noting that it's not just Delhi and Washington that have built and are building this relationship, but the two countries' states, private sectors, educational institutions and people. 

This wouldn't prevent Modi from highlighting the heightened intensity of the last two years, particularly the progress in defense and security cooperation. (From a more political perspective, given that there has been criticism in some quarters of India-U.S. relations becoming closer, it can also serve as a reminder that the Congress party-led government followed a similar path).

Modi will be competing for media attention in the U.S. thanks to the focus in the U.S. on the Democratic primaries this week, but he'll have Congressional attention. But it's worth remembering that Indian prime ministers have been feted before, but if they don't deliver on the promise of India and India-U.S. relations that they often outline, disillusionment sets in. Modi will have to convince them that India is a strategic bet worth making--one that will pay off.

This piece was originally published by Huffington Post India.

On his fourth trip to the U.S. as Indian Prime Minister, Narendra Modi will spend some quality time on Capitol Hill on Wednesday, where he'll address a joint meeting of the U.S. Congress. House Speaker Paul Ryan will also host the Indian premier for a lunch, which will be followed by a reception hosted jointly by the House and Senate Foreign Relations Committees and the India Caucus. What's the significance of this Congressional engagement and what might be Modi's message? 

Given that all the most-recent Indian leaders who've held five-year terms have addressed such joint meetings of Congress, some have asked whether Ryan's invitation to Modi is a big deal. The answer is, yes, it is an honour and not one extended all that often. Since 1934, there have been only 117 such speeches. Leaders from France, Israel and the United Kingdom have addressed joint meetings the most times (8 each), followed by Mexico (7), and Ireland, Italy and South Korea (6 each). With this speech, India will join Germany on the list with leaders having addressed 5 joint meetings of Congress: Rajiv Gandhi in 1985, P.V. Narashima Rao in 1994, Atal Bihari Vajpayee in 2000 and Manmohan Singh in 2005. India's first premier, Jawaharlal Nehru, spoke to the House and Senate in separate back-to-back sessions in 1949 as well. 

Congress is a key stakeholder in the U.S.-India relationship and can play a significant supportive or spoiler role. While American presidents have a lot more lee-way on foreign policy than domestic policy, Congress is not without influence on U.S. foreign relations, and shapes the context for American engagement abroad. Moreover, the breadth and depth of the U.S.-India relationship, as well as the blurring of the line between what constitutes domestic and foreign policy these days means that India's options can be affected by American legislative decisions or the political mood on a range of issues from trade to immigration, energy to defense. 

The Indian Foreign Secretary recently said that the U.S. legislature was at "very much at the heart" of the relationship today. He noted it has been "very supportive" and "even in some more difficult days where actually the Congress has been the part of the US polity which has been very sympathetic to India." But India's had rocky experiences on the Hill as well--which only heightens the need to engage members of Congress at the highest levels. 

The speech and the other interactions offer Modi an opportunity to acknowledge the role of Congress in building bilateral relations, highlight shared interests and values, outline his vision for India and the relationship, as well as tackle some Congressional concerns and note some of India's own. He'll be speaking to multiple audiences in Congress, with members there either because of the strategic imperative for the relationship, others because of the economic potential, yet others because of the values imperative--and then there are those who'll be there because it is important to their constituents, whether business or the Indian diaspora. There is also the audience outside Congress, including in India, where the speech will play in primetime. What will Modi's message be? A glimpse at previous speeches might offer some clues, though Modi is likely also to want to emphasize change. 

The speeches that came before

The speeches of previous prime ministers have addressed some common themes. They've acknowledged shared democratic values. They've mentioned the two-way flow of inspiration and ideas with individuals like Henry David Thoreau, Mahatma Gandhi, Martin Luther King getting multiple mentions. They've noted the influence of American founding documents or fathers on the Indian constitution. They've highlighted India's achievements, while stressing that much remains to be done. 

They've noted their country's diversity, and the almost-unique task Indian leaders have had--to achieve development for hundreds of millions in a democratic context. Since Gandhi, each has mentioned the Indian diaspora, noting its contributions to the U.S. Each prime minister has also expressed gratitude for American support or the contribution the U.S. partnership has made to India's development and security. They've acknowledged differences, without dwelling on them. They've addressed contemporary Congressional concerns that existed about Indian policy--in some cases offering a defense of them, in others' explaining the reason behind the policy.

Many of the premiers called for Congress to understand that India, while a democracy like the U.S. and sharing many common interests, would not necessarily achieve its objectives the same way as the U.S. And each subtly has asked for time and space, accommodation and support to achieve their goals--and argued it's in American interests to see a strong, stable, prosperous, democratic India.

In terms of subjects, each previous speech has mentioned economic growth and development as a key government priority, highlighting what policymakers were doing to achieve them. Since Gandhi, all have mentioned nuclear weapons though with different emphases: he spoke of disarmament; Rao of de-nuclearization and concerns about proliferation; two years after India's nuclear test, Vajpayee noted India's voluntary moratorium on testing and tried to reassure Congress about Indian intentions; and speaking in the context of the U.S.-India civil nuclear talks, Singh noted the importance of civil nuclear energy and defended India's track record on nuclear non-proliferation.

Since Rao, every prime minister has mentioned the challenge that terrorism posed for both the U.S. and India, with Vajpayee and Singh implicitly noting the challenge that a neighboring country poses in this regard from India's perspective. And Rao and Singh made the case for India to get a permanent seat on the U. N. Security Council.

The style of the speeches has changed, as has the tone. Earlier speeches were littered with quotes from sources like Christopher Columbus, Swami Vivekananda, Abraham Lincoln, Lala Lajpat Rai and the Rig Veda. Perhaps that was reflective of the style of speechwriting in those eras, but perhaps it was also because there were fewer concrete issues in the bilateral relationship to address. The evolution in the areas of cooperation is evident in the speeches. 

Rao's speech about two decades ago, for instance, listed U.S.-India common interests as peacekeeping, environmental crises, and combating international terrorism and international narcotics trafficking. Compare that to Singh's address which talked of cooperation on a range of issues from counterterrorism, the economy, agriculture, energy security, healthy policy, humanitarian assistance and disaster relief (HADR), democracy promotion, and global governance.

The speech yet to come

Modi will likely strike some similar themes, acknowledging the role that the U.S. Congress has played in shaping the relationship and expressing gratitude for its support. Like Vajpayee, particularly in a U.S. election year, Modi might note the bipartisan support the relationship has enjoyed in recent years. He'll undoubtedly talk about shared democratic values in America's "temple of democracy"--a phrase he used for the Indian parliament when he first entered it after his 2014 election victory. Modi will not necessarily mention the concerns about human rights, trade and investment policies, non-proliferation or India's Iran policy that have arisen on the Hill, but he will likely address them indirectly. 

For example, by emphasizing India's pluralism and diversity and the protection its Constitution gives to minorities, or the constructive role the country could play regionally (he might give examples such as the recently inaugurated dam in Afghanistan). Given the issues on the bilateral agenda, he'll likely mention the strategic convergence, his economic policy plans, terrorism, India's non-proliferation record, defense and security cooperation, and perhaps--like Vajpayee--the Asia-Pacific (without directly mentioning China). And like Vajpayee, he might be more upfront about Indian concerns and the need to accommodate them. 

While he might strike some similar themes as his predecessors and highlight aspects of continuity, Modi will also want to emphasize that it's not business as usual. He'll likely try to outline the change that he has brought and wants to bring. In the past, he has noted the generational shift that he himself represents as the first Indian prime minister born after independence and the Modi government's latest tag line is, of course, "Transforming India." And he might emphasize that this changed India represents an opportunity for the U.S.

He won't wade directly into American election issues, but might note the importance of U.S. global engagement. He might also try to address some of the angst in the U.S. about other countries taking advantage of it and being "takers." He could do this by making the case that India is not a free rider--that through its businesses, market, talent and diaspora it is contributing to American economy and society, through its economic development it will contribute to global growth, and through Indian prosperity, security and a more proactive international role--with a different approach than another Asian country has taken--it'll contribute to regional stability and order. He might also suggest ways that the U.S. can facilitate India playing such a role.

Unlike previous leaders, he has not tended to appeal to others not to ask India to do more regionally and globally because it's just a developing country and needs to focus internally. The Modi government has been highlighting the contributions of India and Indians to global and regional peace and prosperity--through peacekeeping, the millions that fought in the World Wars, HADR operations in its neighborhood, evacuation operations in Yemen in which it rescued not just Indian citizens, but Americans as well.

His government has been more vocal in joint contexts of expressing its views on the importance of a rules-based order in the Asia-Pacific and Indian Ocean regions--and we might hear more on this in his address. Overall, a theme will likely be that India is not just a "taker," and will be a responsible, collaborative stakeholder.

It'll be interesting to see whether the Indian prime minister notes the role that his predecessors have played in getting the relationship to this point. With some exceptions--for example, he acknowledged Manmohan Singh's contribution during President Obama's visit to India last year--he has not tended to do so. But there's a case to be made for doing so--it can reassure members of Congress that the relationship transcends one person or party and is based on a strategic rationale, thus making it more sustainable. Such an acknowledgement could be in the context of noting that it's not just Delhi and Washington that have built and are building this relationship, but the two countries' states, private sectors, educational institutions and people. 

This wouldn't prevent Modi from highlighting the heightened intensity of the last two years, particularly the progress in defense and security cooperation. (From a more political perspective, given that there has been criticism in some quarters of India-U.S. relations becoming closer, it can also serve as a reminder that the Congress party-led government followed a similar path).

Modi will be competing for media attention in the U.S. thanks to the focus in the U.S. on the Democratic primaries this week, but he'll have Congressional attention. But it's worth remembering that Indian prime ministers have been feted before, but if they don't deliver on the promise of India and India-U.S. relations that they often outline, disillusionment sets in. Modi will have to convince them that India is a strategic bet worth making--one that will pay off.

This piece was originally published by Huffington Post India.

Great power competition has returned. Or rather, it has reminded us that it was always lurking in the background. This is not a minor development in international affairs, but it need not mean the end of the world order as we know it.  

The real impact of the return of great power competition will depend on how the United States responds to these changes. America needs to recognize its central role in maintaining the present liberal international order and muster the will to use its still formidable power and influence to support that order against its inevitable challengers.

Competition in international affairs is natural. Great powers by their very nature seek regional dominance and spheres of influence. They do so in the first instance because influence over others is what defines a great power. They are, as a rule, countries imbued with national pride and imperial ambition. But, living in a Hobbesian world of other great powers, they are also nervous about their security and seek defense-in-depth through the establishment of buffer states on their periphery. 

Historically, great power wars often begin as arguments over buffer states where spheres of influence intersect—the Balkans before World War I, for instance, where the ambitions of Russia and Austria-Hungary clashed. But today’s great powers are rising in a very different international environment, largely because of the unique role the United States has played since the end of the Second World War. The United States has been not simply a regional power, but rather a regional power in every strategic region. It has served as the maintainer of regional balances in Europe, Asia, and the Middle East. The result has been that, in marked contrast to past eras, today’s great powers do not face fundamental threats to their physical security. 

So, for example, Russia objectively has never enjoyed greater security in its history than it has since 1989. In the 20^th century, Russia was invaded twice by Germany, and in the aftermath of the second war could plausibly claim to fear another invasion unless adequately protected. (France, after all, had the same fear.)  In the 19^th century, Russia was invaded by Napoleon, and before that Catherine the Great is supposed to have uttered that quintessentially Russian observation, “I have no way to defend my borders but to extend them.” Today that is not true. Russia faces no threat of invasion from the West.  Who would launch such an invasion? Germany, Estonia, Ukraine? If Russia faces threats, they are from the south, in the form of militant Islamists, or from the east, in the form of a billion Chinese standing across the border from an empty Siberia. But for the first time in Russia’s long history, it does not face a strategic threat on its western flank. 

Much the same can be said of China, which enjoys far greater security than it has at any time in the last three centuries. The American role in East Asia protects it from invasion by its historic adversary, Japan, while none of the other great powers around China’s periphery have the strength or desire now or in the foreseeable future to launch an attack on Chinese territory. 

Therefore, neither Chinese nor Russians can claim that a sphere of influence is necessary for their defense. They may feel it necessary for their sense of pride. They may feel it is necessary as a way of restoring their wounded honor. They may seek an expanded sphere of influence to fulfill their ambition to become more formidable powers on the international stage. And they may have concerns that free, nations on their periphery may pass the liberal infection onto their own populaces and thus undermine their autocratic power. 

The question for the United States, and its allies in Asia and Europe, is whether we should tolerate a return to sphere of influence behavior among regional powers that are not seeking security but are in search of status, powers that are acting less out of fear than out of ambition. This question, in the end, is not about idealism, our commitment to a “rules-based” international order, or our principled opposition to territorial aggression. Yes, there are important principles at stake: neighbors shouldn’t invade their neighbors to seize their territory. But before we get to issues of principle, we need to understand how such behavior affects the world in terms of basic stability 

On that score, the historical record is very clear. To return to a world of spheres of influence—the world that existed prior to the era of American predominance—is to return to the great power conflicts of past centuries. Revisionist great powers are never satisfied. Their sphere of influence is never quite large enough to satisfy their pride or their expanding need for security. The “satiated” power that Bismarck spoke of is rare—even his Germany, in the end, could not be satiated. Of course, rising great powers always express some historical grievance. Every people, except perhaps for the fortunate Americans, have reason for resentment at ancient injustices, nurse grudges against old adversaries, seek to return to a glorious past that was stolen from them by military or political defeat. The world’s supply of grievances is inexhaustible.

These grievances, however, are rarely solved by minor border changes. Japan, the aggrieved “have-not” nation of the 1930s, did not satisfy itself by swallowing Manchuria in 1931. Germany, the aggrieved victim of Versailles, did not satisfy itself by bringing the Germans of the Sudetenland back into the fold. And, of course, Russia’s historical sphere of influence does not end in Ukraine. It begins in Ukraine.  It extends to the Balts, to the Balkans, and to heart of Central Europe. 

The tragic irony is that, in the process of carving out these spheres of influence, the ambitious rising powers invariably create the very threats they use to justify their actions. Japan did exactly that in the 30s. In the 1920s, following the Washington Naval Treaty, Japan was a relatively secure country that through a combination of ambition and paranoia launched itself on a quest for an expanded sphere of influence, thus inspiring the great power enmity that the Japanese had originally feared. One sees a similar dynamic in Russia’s behavior today. No one in the West was thinking about containing Russia until Russia made itself into a power that needed to be contained.

If history is any lesson, such behavior only ends when other great powers decide they have had enough. We know those moments as major power wars. 

The best and easiest time to stop such a dynamic is at the beginning. If the United States wants to maintain a benevolent world order, it must not permit spheres of influence to serve as a pretext for aggression. The United States needs to make clear now—before things get out of hand—that this is not a world order that it will accept. 

And we need to be clear what that response entails. Great powers of course compete across multiple spheres—economic, ideological, and political, as well as military. Competition in most spheres is necessary and even healthy. Within the liberal order, China can compete economically and successfully with the United States; Russia can thrive in the international economic order uphold by the liberal powers, even if it is not itself liberal. 

But security competition is different. It is specifically because Russia could not compete with the West ideologically or economically that Putin resorted to military means. In so doing, he attacked the underlying security and stability at the core of the liberal order. The security situation undergirds everything—without it nothing else functions. Democracy and prosperity cannot flourish without security. 

It remains true today as it has since the Second World War that only the United States has the capacity and the unique geographical advantages to provide this security. There is no stable balance of power in Europe or Asia without the United States. And while we can talk about soft power and smart power, they have been and always will be of limited value when confronting raw military power. Despite all of the loose talk of American decline, it is in the military realm where U.S. advantages remain clearest. Even in other great power’s backyards, the United States retains the capacity, along with its powerful allies, to deter challenges to the security order. But without a U.S. willingness to use military power to establish balance in far-flung regions of the world, the system will buckle under the unrestrained military competition of regional powers. 

Financial advisors offer their clients many advantages, such as setting reasonable savings goals, avoiding fraudulent investments and mistakes like buying high and selling low, and determining the right level of risk for a particular household. However, these same advisors are often incentivized to choose funds that increase their own financial rewards, and the nature and amount of the fees received by advisors may not be transparent to their clients, and small-scale savers may not be able to access affordable advice at all.  What is in the best interest of an individual may not be in the best interest of his or her financial advisor.

To combat this problem, the Department of Labor (DoL) recently proposed a regulation designed to increase consumer protection by treating some investment advisors as fiduciaries under ERISA and the 1986 Internal Revenue Code.  The proposed conflict of interest rule is an important step in the right direction to increasing consumer protections.  It addresses evidence from a February 2015 report by the Council of Economic Advisers suggesting that consumers often receive poor recommendations from their financial advisors and that as a result their investment returns on IRAs are about 1 percentage point lower each year.   Naturally, the proposal is not without its controversies and it has already attracted at least 775 public comments, including one from us .

For us, the DoL’s proposed rule is a significant step in the right direction towards increased consumer protection and retirement security.  It is important to make sure that retirement advisors face the right incentives and place customer interests first.  It is also important make sure savers can access good advice so they can make sound decisions and avoid costly mistakes.  However, some thoughtful revisions are needed to ensure the rule offers a net benefit. 

If the rule causes advisors’ compliance costs to rise, they may abandon clients with small-scale savings, since these clients will no longer be profitable for them.  If these small-scale savers are crowded out of the financial advice market, we might see the retirement savings gap widen.  Therefore we encourage the DoL to consider ways to minimize or manage these costs, perhaps by incentivizing advisors to continue guiding these types of clients.  We also worry that the proposed rule does not adequately clarify the difference between education and advice, and encourage the DoL to close any potential loopholes by standardizing the general educational information that advisors can share without triggering fiduciary responsibility (which DoL is trying to do).  Finally, the proposed rule could encourage some advisors to become excessively risk averse in an overzealous attempt to avoid litigation or other negative consequences.  Extreme risk aversion could decrease market returns for investors and the ‘value-add’ of professional advisors, so we suggest the DoL think carefully about discouraging conflicted advice without also discouraging healthy risk.

The proposed rule addresses an important problem, but in its current form it may open the door to some undesirable or problematic outcomes.  We explore these issues in further detail in our recent paper.

Americans are enjoying longer lifespans than ever before. Living longer affords individuals the opportunity to make more contributions to the world, to spend more time with their loved ones, and to devote more years to their favorite activities – but a longer life, and particularly a longer retirement, is also expensive. The retirement security landscape is evolving as workers, employers, retirees, and financial services companies find their needs shifting. Once, many workers planned to stay with a single employer for most or all of their careers, building up a sizeable pension and looking forward to a comfortable retirement. Today, workers more and more workers will be employed by many different employers.  Additionally, generous defined benefit (DB) retirement plans are less popular than they once were – though they were never truly commonplace – and defined contribution (DC) plans are becoming ever more prevalent.  

Figure 1, below, shows the change from DB to DC that has occurred over the past three decades.

In the past many retirees struggled financially towards the end of their lives, just as they do now, but even so, the changes to the retirement security landscape have been real and marked, and have had a serious impact on workers and retirees alike. DB plans are dwindling, DC plans are on the rise, and as a result individuals must now take a more active role in managing their retirement savings. DC plans incorporate contributions from employees and employers alike, and workers much choose how to invest their nest egg.  When a worker leaves a job for retirement or for a different job he or she will often roll over the money from a 401(k) plan into an Individual Retirement Account (IRA). While having more control over one’s retirement funds might seem on its face to be a net improvement, the reality is that the average American lacks the financial literacy to make sound decisions (SEC 2012).

The Council of Economic Advisers (CEA) expressed concern earlier this year that savers with IRA accounts may receive poor investment advice, particularly in cases where their financial advisors are compensated through fees and commissions. “[The] best recommendation for the saver may not be the best recommendation for the adviser’s bottom line” (CEA 2015). President Obama echoed these concerns in a speech at AARP in February, asking the Department of Labor (DoL) to update its rules for financial advisors to follow when handling IRA accounts (White House 2015). The DoL receives its authority to craft such rules and requirements from the 1974 Employee Retirement Income Security Act (ERISA) (DoL 2015a).

The DoL recently proposed a regulation designed to increase consumer protection by treating some investment advisors as fiduciaries under ERISA and the 1986 Internal Revenue Code (DoL 2015b). The proposed rule has generated heated debate, and some financial advisors have responded with great concern, arguing that it will be difficult or impossible to comply with the rule without raising costs to consumers and/or abandoning smaller accounts that generate little or no profit. Advisors who have traditionally offered only the proprietary products of a single company worry that the business model they have used for many years will no longer be considered to be serving the best interests of clients.

Rather than offering detailed comments on the DoL proposals, this paper will look more broadly at the problem of saving for retirement and the role for professional advice. This is, of course, a well-travelled road with a large literature by academics, institutions and policy-makers, however, it is worthwhile to think about market failures, lack of information and individual incentives and what they imply for the investment advice market.

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Introduction

I would like to thank the Department for giving me the opportunity to testify on this important issue. The document I submitted to you is more general than most of the comments you have received, talking about the issues facing retirement savers and policymakers, rather than engaging in a point-by-point discussion of the detailed DOL proposal¹.

Issues around Retirement Saving

1. Most workers in the bottom third of the income distribution will rely on Social Security to support them in retirement and will save little. Hence it is vital that we support Social Security in roughly its present form and make sure it remains funded, either by raising revenues or by scaling back benefits for higher income retirees, or both.

2. Those in the middle and upper middle income levels must now rely on 401k and IRA funds to provide income support in retirement. Many and perhaps most households lack a good understanding of the amount they need to save and how to allocate their savings. This is true even of many savers with high levels of education and capabilities.

3. The most important mistakes made are: not saving enough; withdrawing savings prior to retirement; taking Social Security benefits too early² ; not managing tax liabilities effectively; and failing to adequately manage risk in investment choices. This last category includes those who are too risk averse and choose low-return investments as well as those that overestimate their own ability to pick stocks and time market movements. These points are discussed in the paper I submitted to DoL in July. They indicate that retirement savers can benefit substantially from good advice.

4. The market for investment advice is one where there is asymmetric information and such markets are prone to inefficiency. It is very hard to get incentives correctly aligned. Professional standards are often used as a way of dealing with such markets but these are only partially successful. Advisers may be compensated through fees paid by the investment funds they recommend, either a load fee or a wrap fee. This arrangement can create an incentive for advisers to recommend high fee plans.

5. At the same time, advisers who encourage increased saving, help savers select products with good returns and adequate diversification, and follow a strategy of holding assets until retirement provide benefits to their clients.

Implications for the DoL’s proposed conflicted interest rule

1. Disclosure. There should be a standardized and simple disclosure form provided to all households receiving investment advice, detailing the fees they will be paying based on the choices they make. Different investment choices offered to clients should be accompanied by a statement describing how the fees received by the adviser would be impacted by the alternative recommendations made to the client.

2. Implications for small-scale savers. The proposed rule will bring with it increased compliance costs. These costs, combined with a reluctance to assume more risk and a fear of litigation, may make some advisers less likely to offer retirement advice to households with modest savings. These households are the ones most in need of direction and education, but because their accounts will not turn profits for advisors, they may be abandoned. According to the Employee Benefits Security Administration (EBSA), the proposed rule will save families with IRAs more than $40 billion over the next decade. However, this benefit must be weighed against the attendant costs of implementing the rule. It is possible that the rule will leave low- and medium-income households without professional guidance, further widening the retirement savings gap. The DoL should consider ways to minimize or manage these costs. Options include incentivizing advisors to continue guiding small-scale savers, perhaps through the tax code, and promoting increased financial literacy training for households with modest savings. Streamlining and simplifying the rules would also help.

3. Need for Research on Online Solutions. The Administration has argued that online advice may be the solution for these savers, and for some fraction of this group that may be a good alternative. Relying on online sites to solve the problem seems a stretch, however. Maybe at some time in the future that will be a viable option but at present there are many people, especially in the older generation, who lack sufficient knowledge and experience to rely on web solutions. The web offers dangers as well as solutions, with the potential for sub-optimal or fraudulent advice. I urge the DoL to commission independent research to determine how well a typical saver does when looking for investment advice online. Do they receive good advice? Do they act on that advice? What classes of savers do well or badly with online advice? Can web advice be made safer? To what extent do persons receiving online advice avoid the mistakes described earlier?

4. Pitfalls of MyRA. Another suggestion by the Administration is that small savers use MyRA as a guide to their decisions and this option is low cost and safe, but the returns are very low and will not provide much of a cushion in retirement unless households set aside a much larger share of their income than has been the case historically.

5. Clarifications about education versus advice. The proposed rule distinguished education from advisement. An advisor can share general information on best practices in retirement planning, including making age-appropriate asset allocations and determining the ideal age at which to retire, without triggering fiduciary responsibility. This is certainly a useful distinction. However, some advisors could frame this general information in a way that encourages clients to make decisions that are not in their own best interest. The DoL ought to think carefully about the line between education and advice, and how to discourage advisors from sharing information in a way that leads to future conflicts of interest. One option may be standardizing the general information that may be provided without triggering fiduciary responsibility.

6. Implications for risk management. Under the proposed rule advisors may be reluctant to assume additional risk and worry about litigation. In addition to pushing small-scale savers out of the market, the rule may encourage excessive risk aversion in some advisors. General wisdom suggests that young savers should have relatively high-risk portfolios, de-risking as they age, and ending with a relatively low-risk portfolio at the end of the accumulation period. The proposed rule could cause advisors to discourage clients from taking on risk, even when the risk is generally appropriate and the investor has healthy expectations. Extreme risk aversion could decrease both market returns for investors and the “value-add” of professional advisors. The DoL should think carefully about how it can discourage conflicted advice without encouraging overzealous risk reductions.

The proposed rule is an important effort to increase consumer protection and retirement security. However, in its current form, it may open the door to some undesirable or problematic outcomes. With some thoughtful revisions, I believe the rule can provide a net benefit to the country.

^{1. Baily’s work has been assisted by Sarah E. Holmes. He is a Senior Fellow at the Brookings Institution and a Director of The Phoenix Companies, but the views expressed are his alone.}

^{2. As you know, postponing Social Security benefits yields an 8 percent real rate of return, far higher than most people earn on their investments. For most of those that can manage to do so, postponing the receipt of benefits is the best decision.}

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Visiting Astana, the modernistic capital of Kazakhstan, last week, I couldn't help feeling that I was at, or at least close to, the center of the universe. 

Consider this:  On September 7, the president of Kazakhstan, Nursultan Nazarbayev, having just returned from attending the G-20 Summit in St. Petersburg at the invitation of President Putin of Russia, welcomed President Xi Jinping of China for an official visit in Astana. President Xi gave a speech that day at Nazarbayev University, in which he unabashedly borrowed a turn of phrase from former U.S. Secretary of State Hillary Clinton  by proposing a “New Silk Road” to serve as an “economic belt” of Eurasia, connecting “3 million people from the Pacific to the Baltic Sea” with Kazakhstan as a key partner along the way. 

On September 10, President Nazarbayev opened the Eurasian Emerging Markets Forum in Astana, at which he addressed some 800 participants, including high-level dignitaries and representatives from 87 countries.  In his keynote speech, he laid out his plans to catapult Kazakhstan into the ranks of the top 30 developed countries in the world by 2050.  The rest of the forum was devoted to exploring the ways in which this ambitious vision could be achieved and how economic integration of the Eurasian supercontinent—i.e., Europe plus Asia, with Kazakhstan at its center—would be a driver of regional and global prosperity. 

Finally, on September 13, President Nazarbayev joined the leaders of China, Russia and the five Central Asian republics in Bishkek for a summit of the Shanghai Cooperation Organization (SCO), which was also attended by a number of other regional leaders with observer status, including from Afghanistan, India, Iran and Pakistan.  Besides the usual pledges of good neighborly relations within the group, the leaders weighed in with a chorus of statements about current geopolitical trouble spots, including Afghanistan, Iran and Syria, many of them directed critically at the United States.

While the president and people of Kazakhstan might have felt at the center of global action this week, there is little doubt that China and Russia are the key external actors on the Central Asian stage.  Europe and the United States are far away and hardly visible, and everybody expects that, with the imminent end of NATO’s engagement in Afghanistan, their attention to Central Asia will slip even further.  In contrast, the leaders of China and Russia are clearly focused on this region.  

Central Asian leaders, while perhaps privately worried about the long-term consequences of too tight an embrace by China, welcome the low-key approach of their big neighbor...

If there had been any doubt, President Xi’s speech in Astana showed that China is now concerned with Central Asia at the highest level.  While China faces its neighbors in the Pacific region in an assertive pose designed to counter what it sees as encirclement by unfriendly countries led by the U.S., it evidently feels no threat in Central Asia and projects an image of itself as benevolent and modest senior partner.  No doubt sensing opportunities to create a stable backyard, to secure access to energy resources and to build a land bridge to European and Middle Eastern markets while also gently wresting influence away from Russia, China has a strong incentive to push westward.  The substantial energy supply deals  that President Xi signed in Kazakhstan, Turkmenistan and Uzbekistan this past week and the stress Xi placed in his Astana speech on measures to open up transport links throughout Eurasia reflect China’s growing engagement in this region.  Central Asian leaders, while perhaps privately worried about the long-term consequences of too tight an embrace by China, welcome the low-key approach of their big neighbor, which promises to strengthen their own hand economically and politically at least in the short term.

At the same time, there is also a new dynamic between Central Asia and Russia.  Since Mr. Putin resumed the Russian presidency in 2012, Russia has breathed new life into a long-dormant regional grouping, the Eurasian Economic Community (EurAsEC), by pushing hard to create a customs union  (and eventually an economic union) that, in Russia’s view, would encompass most of the republics of the former Soviet Union. Although only a fraction of the geographic space of continental Eurasia (Europe + Asia), the reference to “Eurasia” harks back to a long-standing Russian ideological vision.  Under this vision, Russia and its former Soviet neighbors are endowed with a unique combination of European and Asian values and, led by Russia, with a mission to dominate the land bridge between Europe and Asia. 

In the pursuit of establishing a unified economic “Eurasian” space, Russia has not only successfully pushed for the full implementation of the current customs union between Russia, Kazakhstan and Belorussia, but is also vigorously pursuing the expansion of the union in Ukraine, Central Asia (specifically targeting the Kyrgyz Republic and Tajikistan) and Armenia in the South Caucasus.  In the case of Armenia and Ukraine, this pursuit has taken on a decidedly anti-European Union tone, as Russia seems to spare no effort to ensure that these countries will join its own economic orbit, rather than associating with the EU.  In Central Asia, the Russian campaign of expanding the customs union has been more low key, but nonetheless persistent with the quiet support of Kazakhstan.  Interestingly, this effort to create a unified economic space has not been cast by Russia as a move to counteract the growing influence of China in Central Asia, even though it is undoubtedly one of the underlying long-term motives for Russian diplomacy in the region.  

Much more important for China will be whether the “Eurasian” economic union can create safe, low-cost and high-speed transit routes to China’s key trading partners in Europe, South Asia and the Middle East.

Indeed, for Central Asia in general and for Kazakhstan in particular, the important questions for the future will be how China and Russia shape their mutual relations overall and how they will seek to accommodate their overlapping interests in the region.  For the moment, a common geopolitical front vis-à-vis the U.S., evident in their joint positions at the U.N. Security Council and at the SCO summit last week, is an overarching priority for China and Russia.  Moreover, they share the common interest of establishing a stable and prosperous political and economic sphere in Central Asia.  For now and the foreseeable future, China’s thirst for energy is large enough to allow both Russia and Central Asian countries to pursue opportunities for major oil and gas supply deals with China without undue competition. Finally, whatever protectionist effects an expansion of the Russian-led customs union may have in limiting trade between China and Central Asia will likely be temporary and will hardly be noticed in China’s huge overall trade account.  Much more important for China will be whether the “Eurasian” economic union can create safe, low-cost and high-speed transit routes to China’s key trading partners in Europe, South Asia and the Middle East. This priority strongly resonated in President Xi’s speech, in which he not only staked out an interest in Eurasian economic integration, but also promised greater cooperation between the SCO and EurAsEC.

What does all of this mean in practical terms for Central Asia and for Kazakhstan?  As President Nazarbayev indicated in his speech at the Eurasian Emerging Markets Forum, he sees Kazakhstan as playing a key role in supporting the economic integration of larger Eurasia.  This presumably should mean: investing in regional infrastructure, such as the major East-West Highway through Kazakhstan as a link from China to Europe; assuring that the customs union pursues open, rather than protectionist, policies; and convincing the other Central Asian countries, including Uzbekistan and Turkmenistan, to participate in an effort to increase the region’s connectivity both internally and with the rest of the world. 

In addition, there are a number of institutional options for promoting these goals and for turning China’s and Russia’s engagement in Central Asia into a pragmatic partnership.  One option would be to have China join the Eurasian Development Bank (EADB), the financial arm of EurAsEC.  Another would be for Russia to join the Central Asian Regional Economic Cooperation Program (CAREC), in which China has teamed up with Central Asian countries (now also including Afghanistan, Mongolia and Pakistan) and with six international financial organizations (including the Asian Development Bank and the World Bank) with the goal of improving regional cooperation and investment in trade, transport and energy.  Either or both of these two options could then offer SCO a financial and technical institutional platform to pursue economic integration between China, Russia and Central Asia (and, ultimately, even South Asia), a goal that has eluded SCO up until now. 

Kazakhstan is a member of EurAsEc, EADB, CAREC and SCO, and is therefore in a unique position to promote institutional changes along some or all of these lines.  One place to start would be the next ministerial conference of CAREC, to be held in Astana on October 24-25.  Of course, it is by no means clear that China and Russia will see it in their interest to dilute their lead roles in EADB and CAREC, the regional organizations that they now respectively dominate.  However, establishing a strong and meaningful institutional capacity that would support the economic integration process in Central Asia and in the larger Eurasia would be of great benefit for Kazakhstan, since it would help turn the country from being “land-locked” to being “land-linked” with the world’s largest and most dynamic economies.