I want to begin by saying how grateful we were at Brookings to partner with the Federal Reserve System on this concentrated poverty project. We like to think that at Brookings we know a lot about this subject, but it was only through this partnership with the Fed that we were able to ground this understanding in the experiences of the 16 communities across the United States that were the focus of the report’s case studies.

The report demonstrates that in addition to managing the macroeconomy, the Fed also possesses a unique and powerful understanding of the U.S. economy from the ground up, which is absolutely necessary for designing smart policy in turbulent times like these.

I want to also give special thanks to my colleagues David Erickson and Carolina Reid at the San Francisco Fed. They played several roles in this project for me: intellectual partners, co-conspirators, mood lighteners, and Fed sherpas. It can be tough for foreigners like myself to navigate this system, and they lightened my load throughout the project. I also want to thank my Brookings colleague Elizabeth Kneebone, who performed a lot of the data analysis for this project.

I want to argue three points, largely policy points, in my remarks this morning.

First, the current economic climate makes the issue of concentrated poverty, and our response, more relevant, not less.

Second, major near-term investments our country makes to resolve the economic crisis can and should provide meaningful opportunities for the most disadvantaged families and communities.

And third, our longer-run efforts to assist high-poverty areas and their residents must take account of the economic challenges and opportunities that manifest at the regional, metropolitan level.

To begin, let’s review where we were when the Fed and Brookings joined forces on this effort in May 2006.

• The unemployment rate was 4.7 percent, a five-year low.
• Payrolls were expanding every month for the third consecutive year.
• The poverty rate, while still above its low in 2000, was dropping.
• The federal deficit was a relatively manageable 2% of GDP.
• The Dow was above 11,000, and on its way up.
• And the 2008 general election promised a storied matchup between party favorites Hillary Clinton and Rudy Giuliani.

A lot can happen in 30 months!

In the wake of record house-price declines and financial market fallout, the economic outlook today is grim. The unemployment rate is 6.5 percent and rising. One projection suggests that the downturn could eventually increase the ranks of the nation’s poor by anywhere from 7 to 10 million. And amid declining revenues and increased expenditure needs, the U.S. budget deficit is expected to top $1 trillion this year.

In short, the situation for the lowest-income communities and their residents is not encouraging.

And neither is our starting point.

As Paul Jargowsky’s research has shown, the incidence of concentrated poverty in America dropped markedly during the 1990s, after two decades of increase. Some combination of a tight labor market and policy changes to promote work and break up the deepest concentrations of poverty seemed responsible for that decline.

But as Elizabeth and I found in a recent Brookings report, we may have given back much of that progress during the first half of this decade. The population in what we termed “high working poverty” communities rose by 40 percent between 1999 and 2005. This suggests that America’s high-poverty areas may have never really recovered from the modest downturn we experienced at the beginning of the decade.

Now, with all the turmoil in our economy, it would be easy to lose sight of these places and their residents, who even seem to have missed out on the benefits of recent growth.

But if we are to meet the enormous challenges facing our country—economic, social, and environmental—we simply can’t afford to take a blind eye to the continuing problem of concentrated poverty.

As decades of research and this report have shown, concentrated poverty magnifies the problems faced by the poor, and exacts a significant toll on the lives of families in its midst.

This report greatly enhances our understanding of how high-poverty communities of all stripes bear these costs. Moreover, it suggests that the contemporary circumstances of these communities owe not just to long-term market dynamics, but also to policy choices made over several decades’ time—some deliberate in their intent, and some producing unfortunate unintended consequences.

Today we’re at an important inflection point for policy. With the economy souring, we don’t have the luxury of using an “auto-pilot” strategy of macroeconomic growth to reach the most disadvantaged places and their residents. Quite the opposite—just as these communities are often “last in” for economic opportunity during boom times, they seem to be “first out” when things shift into reverse.

But the specific nature of the current crisis also poses added challenges for high-poverty communities.

That is because many of these areas were ground zero for risky subprime lending over the last several years. In many of the case-study communities in the report, half or more of recent home mortgages were high-cost subprime loans.

Now, they are on the front lines of the fallout. Our calculations of HUD data show that census tracts where the poverty rate was at least 40 percent in 2000—the conventional definition behind concentrated poverty—have an estimated foreclosure rate over 9 percent, roughly double the nationwide average.

This poses both an immediate and a long-term threat to what little stability these communities possess.

Over the short term, these areas face problems associated with heightened property neglect, vacancy, and abandonment. Not only can those conditions breed crime and disorder, but also they can accelerate a process of further disinvestment from high-poverty neighborhoods, which are all too familiar with that cycle of decline.

Over the long run, the public sector will work to return foreclosed properties in these neighborhoods to productive use. But there is a danger that we may once again re-concentrate poverty in these neighborhoods if these assets are not managed and deployed strategically.

In sum, recent trends and a perilous road ahead merit a meaningful policy response to the challenges facing areas of concentrated poverty and their residents.

This brings me to my second point, which is that near-term policy choices can ameliorate the impacts of the current crisis on areas of concentrated poverty.

In less than 50 days, a new administration will take office in Washington, facing economic challenges of a scale not seen in decades.

The president-elect and his advisors have signaled that they are ready to “do what it takes” to stimulate the economy, create and protect jobs, and catalyze investment in new sectors to spur longer-term growth.

I believe that policies advanced by the new administration and Congress in the first few weeks of the new year, if designed and executed well, could matter greatly for the fortunes of the nation’s high-poverty communities.

First, a comprehensive strategy to deal with the foreclosure crisis is sorely needed. This would feature, first and foremost, a broad plan to forestall the rising tide of mortgages, including many in high-poverty communities, headed for default due to falling home prices, economic dislocation, and poor underwriting.

However, even a sweeping, generous approach will not prevent the inevitable. Especially in high-poverty areas, more loans will fall into foreclosure, more people will lose their homes, and fiscally-strapped local governments will be left to manage the consequences of increasing vacancy and abandonment.

The Neighborhood Stabilization Program enacted by Congress and the Bush administration during the summer of 2008 represents an initial effort to arm state and local leaders with the resources to tackle the neighborhood impacts of rising foreclosures.

But significant deterioration of the economy in the intervening months suggests that the problem may now be of a much larger scale than was originally anticipated. What’s more, many local governments lack the capacity, expertise, and legal authorities to use existing or additional resources strategically.

So the new administration, and HUD in particular, will need to consider a further round of response—using some mix of fiscal, regulatory, capacity-building, and bully pulpit powers—to help cash-strapped local governments mitigate the impacts of foreclosure on their most vulnerable communities.

Second, there seems to be wide agreement that the economic recovery package should include a series of measures that inject money into the economy right away.

So the package will provide immediate assistance to families, communities, and governments hit hard by the downturn, in the likely form of extended unemployment and increased food stamp benefits, increased state and local aid, and low- to middle-income tax cuts, spending designed to make a real economic impact in the next several months.

A couple of details here are of real consequence to communities of concentrated poverty.

• Income tax cuts included in the package should be refundable, like the Earned Income Tax Credit, or EITC. Boosting the EITC, for instance, would provide additional help to workers most likely to be hit hard by the downturn, and target resources to families most likely to spend the additional cash immediately. As the report shows, at least 30 percent, and as many as 60 percent, of families in the case-study communities today benefit from the EITC.
• Unemployment insurance benefits should be extended, but also modernized. As the case studies showed, work among residents of high-poverty communities is often seasonal or part-time, even in a good economy. As a result, many laid-off workers from poor areas in several states may not qualify for benefits due to outmoded eligibility rules. Therefore, in addition to extending weeks of eligibility for UI, Congress and the new administration might also consider providing incentives to states to expand the pool of workers who could benefit from the program during the downturn.

Third, infrastructure will clearly figure prominently among the spending priorities in the recovery package.

Yet there is a significant risk that focusing dollars primarily on projects that states deem “shovel-ready,” as has been discussed, will repeat mistakes of the past. It would primarily subsidize road-building at the metropolitan fringe, and do little to enhance long-run economic growth, or provide better opportunities for low-income people and the places they live.

Infrastructure investments of the magnitude under consideration must not only create jobs, but also promote inclusive and sustainable growth. That means setting strict criteria for federal investment, including a real assessment of costs and benefits that considers economic, environmental, and social impacts. As the report shows, poor infrastructure often acts as a barrier to the economic integration of high-poverty communities into their larger municipal and regional areas.

To that end, we should also consider providing direct support for large, cash-strapped municipal governments that they could use to modernize and preserve roads, bridges, transit, water, sewer, and perhaps even broadband infrastructure. At the same time, we should hold them and grantees at all other levels of government accountable for connecting younger, disadvantaged workers and communities to the jobs that result.

In short, what happens in the first several weeks of the new year here in Washington could, if structured properly, provide meaningful support and opportunity for low-income areas and their residents. At a minimum, this might avert the sort of backsliding these communities suffered during the much milder recession we experienced earlier this decade.

So that brings me to my third and final point, which is that, over the longer term, we must advance policies that actively link the fortunes of poor communities to those of their regional neighbors. As you probably heard or read, our division at Brookings is named the “Metropolitan Policy Program.”

Our mission is to provide decision makers with cutting-edge research and policy ideas for improving the health and prosperity of cities and metropolitan areas.

You might ask, why metropolitan? After all, this is not a term that most Americans use, think about, or even recognize, even though 85 percent of us live in metropolitan areas. A friend of the program once told us that it sounded like a combination of “metrosexual” and “cosmopolitan.” Not exactly what we were going for.

More specifically, what relevance does “metropolitan” have for addressing the challenges of concentrated poverty?

Well, the report points to skills and employability problems that hold back residents of high-poverty communities. If the route to improving the lives of families affected by concentrated poverty runs in part through the labor market, then we must devise strategies and solutions that respect and respond to the geography of that market—which is metropolitan.

The report also points to housing problems, of various stripes, that segregate the poor in these communities and make their daily lives more difficult. Housing markets, too, are metropolitan—and housing dynamics in the wealthiest parts of each metro are inextricably linked to those in the poorest parts.

The fact is, our national economy—and that of most industrialized nations—is largely the aggregate of its individual metropolitan economies. In the United States, the 100 largest metro areas account for 12 percent of our land mass, hold 65 percent of our residents, and generate three-quarters of our Gross Domestic Product. They possess even greater shares of our innovative businesses, our most knowledgeable workers, the critical infrastructure that connects us to the global economy, and the quality places that attract, retain, and enhance the productivity of workers and firms.

And as the report shows, regions—both metropolitan and non-metropolitan—each retain distinctive clusters that shape their individual contributions to the national economic pie. Photonics in Rochester. Hospitality and tourism in Atlantic City and Miami. Manufacturing in Albany, Georgia. Agriculture and business services in Central California. These clusters do not possess equal strength or equal potential, but they define the starting point for thinking about the regional economic future of these areas, and economic opportunities for their residents.

Not only are the assets of our economy fundamentally metropolitan… increasingly, our challenges are, too. In 2006, we found that for the first time, more than half of the poor in metropolitan America lived in suburbs, not cities. While poor suburban families don’t yet concentrate at the levels seen in the communities in this report, they are trending in this direction. Between 1999 and 2005, the number of suburban tax filers living in “moderate” working poverty communities rose by nearly 50 percent.

So what does recognition of our metropolitan reality imply for longer-run policies to help the poorest communities and their residents?

Bruce has argued elsewhere that our nation must embrace a new, unified framework for addressing the needs of poor neighborhoods and their residents. He has termed this, Creating Neighborhoods of Choice and Connection. Neighborhoods of choice are communities in which lower-income people can both find a place to start, and as their incomes rise, a place to stay. They are also communities to which people of higher incomes can move, for their distinctiveness, amenities, or location. This requires an acceptance of economic integration as a goal of housing and neighborhood policy.

Neighborhoods of connection are communities that link families to opportunity, wherever in the metropolis that opportunity might be located. This requires a much more profound commitment to the “educational offer” in these communities and the larger areas of which they are a part. It also requires a pragmatic vision of the “geography of opportunity” with regard to jobs, housing, and other choices.

If we take this vision seriously, then our interventions must operate within, and relate to, the metro geography of our economy. This means viewing the conditions and prospects of poor areas through the lens of the broader economic regions of which they are a part, and explicitly gearing policy in that direction.

A simple example relates to the geography of work. In the Springfield, Massachusetts metro area, roughly 30 percent of the region’s jobs still cluster in the neighborhoods close to downtown, including Old Hill and Six Corners. In the Miami metro area, by contrast, only 9 percent of the region’s jobs lie close to its downtown, implying transportation needs of a quite different scale for Little Haiti’s residents. In response, we should empower metropolitan transportation planners to address the unique nature of these spatial divides, and measure their performance on creating inclusive systems that overcome them.

This metro lens applies to workforce development as well. Labor market intermediaries are some of the most promising mechanisms for bridging the information and skills divide between poor communities and regional economic opportunity. One of the highest performers, the Wisconsin Regional Training Partnership, works in the home region of one of our case-study communities, Milwaukee. If workforce policies and funding at all levels of government were to emphasize employer partnerships, provide greater flexibility, and reward performance, we could grow more capable institutions like these that serve the needs of low-income communities and regional firms alike.

A metro perspective can apply to school reform as well. We have called for a new focus at the Department of Education on supporting proven, successful educational entrepreneurs—charter management organizations like KIPP, human capital providers like Teach for America, student support organizations like College Summit. The demand for these entrepreneurial solutions extends well beyond the highest-poverty neighborhoods. Federal education policy should consider investing in these entrepreneurs at the metropolitan scale, to aggregate a critical mass of those organizations, serve a significant percentage of the area’s children, and drive positive changes in the entire public education environment.

Finally, our housing policies must embrace metro-wide economic diversity, which is a hallmark of neighborhoods of choice and connection.

This means expanding housing opportunities for middle-income families in deprived neighborhoods. We simply cannot continue to cluster low-income housing in already low-income areas, perpetuating the sort of economic segregation evident in so many of the case-study communities, and thereby consign another generation to a childhood amid concentrated poverty. Likewise, we must guard against the possibility that the current foreclosure crisis leads to a re-concentration of poor households in neighborhoods that were just beginning to achieve greater economic diversity.

But this is a two-way street. It also means creating more high-quality housing opportunities for low-income families in growing suburban job centers. Requiring or providing incentives to metropolitan areas to engage in regional housing planning, alongside regional transportation planning, may be a necessary first step. Those plans could also apply a more rational screen to the development choices that have fueled sprawl, and thereby added to the social and economic isolation of the lowest-income communities.

Let me end where I began.

This is both an auspicious and a challenging moment at which to wrestle with the problem of concentrated poverty in America.

Auspicious in that we are approaching the dawn of a new government in Washington that has signaled concern for our nation’s low-income residents and communities, recognition that metropolitan economies are the engines of our prosperity, and a pragmatic commitment to doing what works.

Challenging in that making progress against concentrated poverty, and improving opportunity for those in its midst, is a tall order when the macroeconomy isn’t cooperating.

But the current economic climate is not an excuse to avoid this problem; rather, it’s an imperative to act, strategically and purposefully.

That means doing the big near-term things the right way, so that low-income communities and their residents do not bear an excessive brunt of the downturn, and so that they participate meaningfully in our eventual economic recovery.

And it means getting the long-term vision right, so that policy advances sustainable, metro-led solutions that connect poor neighborhoods and poor families to opportunity in the wider economy around them.

The Federal Reserve System has tremendous, well-earned credibility for understanding and advancing dialogue around the future of our nation’s economic regions. I look forward to continuing to work with the Fed to increase public understanding of concentrated poverty, and to make tackling it a crucial element of strategies to promote regional and national prosperity.

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One of Cleveland's neighborhoods made the Washington scene earlier this month.

Alas, it wasn't up for a multibillion-dollar bailout.

Instead, the Central neighborhood and 15 other communities across the United States were the centerpiece of a new report published by the Federal Reserve System and the Brookings Institution.

These communities share a simple, disappointing characteristic. In 2000 - the peak of the last economic boom - at least 40 percent of their residents lived below the federal poverty line. That was about three times the national average.

No American needs to look very far to find places like these. Concentrated poverty affects manufacturing cities like Cleveland, and Albany, Ga.; immigrant gateways like Miami, Fla., and Fresno, Calif.; and rural areas like eastern Kentucky and northern Montana. About 4 million poor Americans live in these areas of extremely high poverty.

How did this happen? Policy decisions made decades ago - like clustering thousands of the Cleveland region's public housing units in the Central neighborhood - helped shape their trajectory. So too did economic changes, like the long-run loss of decent-paying manufacturing jobs, or - in rural areas - mining and agricultural jobs.

By allowing poverty to concentrate in these places, we've magnified the problems their poor residents face. For instance, many low-income children in these communities start school not yet "ready to learn." On top of that, though, they attend schools burdened with lots of other poor kids who face similar challenges, and deal with higher levels of neighborhood crime that affect their mental health and educational performance.

The challenges of concentrated poverty extend to many other areas: low adult work-force skills and employment, poor-quality housing and a lack of investment by mainstream businesses.

And that's in a good economy. Today, Central - and thousands of other high-poverty communities like it across the nation - faces even more significant challenges as the United States enters what may be its worst recession in decades.

So what should Washington do for these places and their residents in the face of such difficult circumstances?

First, we must not lose sight of them in the economic turmoil. That's especially true because the roots of this crisis, in the subprime mortgage market, grew in many very poor neighborhoods like Central. As a result, home foreclosure rates in high-poverty communities are more than double the national average.

To stabilize these hard-hit communities, Washington must adopt new measures to prevent foreclosure and provide additional resources and guidance for state and local governments to help them cope with the rising numbers of vacant properties.

Second, a forthcoming economic stimulus package from Washington that could amount to half a trillion dollars or more should not bypass these neighborhoods and their residents.

That implies the need for immediate federal aid to sustain basic public services in states like Ohio, where the deficit for this year already tops $1 billion. It also suggests providing direct assistance to struggling workers and their families, through enhanced unemployment benefits and tax credits.

At the same time, the infrastructure dollars in the package - which could amount to more than $100 billion - must be spent strategically. States should not be permitted to go on expanding highway capacity at the metropolitan fringe, to the detriment of poor communities near the urban core. Cities like Cleveland, and metropolitan organizations like the Northeast Ohio Areawide Coordinating Agency, should get their fair share of new transportation funds. And funds should be set aside for training programs that provide low-income residents with a pathway to decent jobs.

Third, we have to rethink neighborhood policy over the longer term.

For too long, government has funded housing, schools and economic development in these communities as though they were islands unto themselves.

That's not how the real economy works. These neighborhoods are part of larger regional labor and housing markets. Decisions made across the Cleveland region, such as where firms locate new jobs, or where families buy homes and send their kids to school, ultimately dictate whether neighborhoods like Central can become real neighborhoods of choice and better connected to economic opportunity.

Public policy must leverage that real economy for the benefit of lower-income residents, by building on smart regional strategies like the Fund for Our Economic Future and WIRE-Net in Northeast Ohio. It should diversify housing in poor communities, but also encourage affordable housing development in wealthier parts of metropolitan areas.

Cleveland's Central neighborhood, like other high-poverty communities across the United States, faces a tough road ahead. Short-term opportunities, and long-term strategies, are needed to help its next generation of residents overcome the challenges of concentrated poverty.

      

As the first decade of the 2000s drew to a close, the two downturns that bookended the period, combined with slow job growth between, clearly took their toll on the nation’s less fortunate residents.

Over a ten-year span, the country saw the poor population grow by 12.3 million, driving the total number of Americans in poverty to a historic high of 46.2 million. By the end of the decade, over 15 percent of the nation’s population lived below the federal poverty line—$22,314 for a family of four in 2010—though these increases did not occur evenly throughout the country.

An analysis of data on neighborhood poverty from the 2005–09 American Community Surveys and Census 2000 reveals that:

After declining in the 1990s, the population in extreme-poverty neighborhoods—where at least 40 percent of individuals live below the poverty line—rose by one-third from 2000 to 2005–09. By the end of the period, 10.5 percent of poor people nationwide lived in such neighborhoods, up from 9.1 percent in 2000, but still well below the 14.1 percent rate in 1990.

Concentrated poverty nearly doubled in Midwestern metro areas from 2000 to 2005–09, and rose by one-third in Southern metro areas. The Great Lakes metro areas of Toledo, Youngstown, Detroit, and Dayton ranked among those experiencing the largest increases in concentrated poverty rates, while the South was home to metro areas posting both some of the largest increases (El Paso, Baton Rouge, and Jackson) and decreases (McAllen, Virginia Beach, and Charleston). At the same time, concentrated poverty declined in Western metro areas, a trend which may have reversed in the wake of the late 2000s housing crisis.

The population in extreme-poverty neighborhoods rose more than twice as fast in suburbs as in cities from 2000 to 2005–09. The same is true of poor residents in extreme-poverty tracts, who increased by 41 percent in suburbs, compared to 17 percent in cities. However, poor people in cities remain more than four times as likely to live in concentrated poverty as their suburban counterparts.

The shift of concentrated poverty to the Midwest and South in the 2000s altered the average demographic profile of extreme-poverty neighborhoods. Compared to 2000, residents of extreme-poverty neighborhoods in 2005–09 were more likely to be white, native-born, high school or college graduates, homeowners, and not receiving public assistance. However, black residents continued to comprise the largest share of the population in these neighborhoods (45 percent), and over two-thirds of residents had a high school diploma or less.

The recession-induced rise in poverty in the late 2000s likely further increased the concentration of poor individuals into neighborhoods of extreme poverty. While the concentrated poverty rate in large metro areas grew by half a percentage point between 2000 and 2005–09, estimates suggest the concentrated poverty rate rose by 3.5 percentage points in 2010 alone, to reach 15.1 percent. Some of the steepest estimated increases compared to 2005–09 occurred in Sun Belt metro areas like Cape Coral, Fresno, Modesto, and Palm Bay, and in Midwestern places like Indianapolis, Grand Rapids, and Akron.

These trends suggest the strong economy of the late 1990s did not permanently resolve the challenge of concentrated poverty. The slower economic growth of the 2000s, followed by the worst downturn in decades, led to increases in neighborhoods of extreme poverty once again throughout the nation, particularly in suburban and small metropolitan communities and in the Midwest. Policies that foster balanced and sustainable economic growth at the regional level, and that forge connections between growing clusters of low-income neighborhoods and regional economic opportunity, will be key to longer-term progress against concentrated disadvantage.

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The Chinese government has recently made early childhood development a national priority, recognizing the social and economic dividends that quality early learning opportunities reap for its human capital in the long term. As the country with the largest population in the world, 100 million children under the age of six in China stand to benefit from increased access to high quality early childhood education.

The quality of education in a country is indicative of its overall development prospects. Over the past two decades – building on the momentum generated by the Education for All and Millennium Development Goals – there have been significant increases in the number of children enrolled in school. Now, with discussions heating up around what the next set of development goals will look like in 2015, it is critical that learning across the education spectrum – from early childhood through adolescence and beyond – is included as a global priority. Starting early helps children enter primary school prepared to learn. High-quality early childhood development opportunities can have long-term impacts on a child’s later success in school.

Last month, the Chinese Ministry of Education, in partnership with the United Nations Children’s Fund, launched its first national early childhood advocacy month to promote early learning for all children. The campaign, which includes national television public service announcements on the benefits of investing early in education, builds on a commitment made by the government in 2010 to increase funding for early childhood education over the next decade. The Chinese government pledged to build new preschool facilities, enhance and scale up teacher training, provide subsidies for rural families for access to early learning opportunities, and increase support for private early childhood education centers.

A new policy guide by the Center for Universal Education outlines recommendations that education stakeholders, including national governments, can take to ensure that all children are in school and learning. These steps include establishing equity-based learning targets for all children, systematically collecting data for tracking progress against these targets, and allocating sufficient resources to education beginning in early childhood. The policy guide, based on a report calling for a Global Compact on Learning, is available in Mandarin, as well as Spanish, Portuguese, French and, soon, Arabic.

The success of China’s productivity and growth over the last few decades is attributable in part to its commitment to building a robust education system. As international attention mounts around the post-2015 education and development agendas, the priorities of national governments must be a central organizing principle. When national governments take bold steps to prioritize early childhood development, the global community should take its cue and integrate early childhood development into the broader push toward access plus learning. There is an opportunity for the global education community to push toward reaching the Education for All and Millennium Development Goals while ensuring that the post-2015 agendas include a focus on the quality of education, learning and skills development, beginning with the youngest citizens.

       

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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The replenishment process for concessional resources of the multilateral development banks is broken. We have come to this conclusion after a review of the experience with recent replenishments of multilateral development funds. We also base it on first-hand observation, since one of us was responsible for the World Bank’s International Development Association (IDA) replenishment consultations 20 years ago and recently served as the external chair for the last two replenishment consultations of the International Fund for Agricultural Development (IFAD), which closely follow the common multilateral development bank (MDB) practice. As many of the banks and their donors are preparing for midterm reviews as a first step toward the next round of replenishment consultations, this is a good time to take stock and consider what needs to be done to fix the replenishment process.

So what’s the problem?

Most of all, the replenishment process does not serve its key intended function of setting overall operational strategy for the development funds and holding the institutions accountable for effectively implementing the strategy. Instead, the replenishment consultations have turned into a time-consuming and costly process in which donor representatives from their capitals get bogged down in the minutiae of institutional management that are better left to the boards of directors and the managements of the MDBs. There are other problems, including lack of adequate engagement of recipient countries in donors’ deliberations, the lack of full participation of the donors’ representatives on the boards of the institutions in the process, and inflexible governance structures that serve as a disincentive for non-traditional donors (from emerging countries and from private foundations) to contribute.

But let’s focus on the consultation process. What does it look like? Typically, donor representatives from capitals assemble every three years (or four, in the case of the Asian Development Bank) for a year-long consultation round, consisting of four two-day meetings (including the meeting devoted to the midterm review of the ongoing replenishment and to setting the agenda for the next consultation process). For these meetings, MDB staff prepare, per consultation round, some 20 substantive documents that are intended to delve into operational and institutional performance in great detail. Each consultation round produces a long list of specific commitments (around 40 commitments is not uncommon), which management is required to implement and monitor, and report on in the midterm review. In effect, however, this review covers only half the replenishment cycle, which leads to the reporting, monitoring, and accountability being limited to the delivery of committed outputs (e.g., a specific sector strategy) with little attention paid to implementation, let alone outcomes.

The process is eerily reminiscent of the much maligned “Christmas tree” approach of the World Bank’s structural adjustment loans in the 1980s and 1990s, with their detailed matrixes of conditionality; lack of strategic selectivity and country ownership; focus on inputs rather than outcomes; and lack of consideration of the borrowers’ capacity and costs of implementing the Bank-imposed measures. Ironically, the donors successfully pushed the MDBs to give up on such conditionality (without ownership of the recipient countries) in their loans, but they impose the same kind of conditionality (without full ownership of the recipient countries and institutions) on the MDBs themselves—replenishment after replenishment.

Aside from lack of selectivity, strategic focus, and ownership of the commitments, the consultation process is also burdensome and costly in terms of the MDBs’ senior management and staff time as well as time spent by ministerial staff in donor capitals, with literally thousands of management and staff hours spent on producing and reviewing documentation. And the recent innovation of having donor representatives meet between consultation rounds as working groups dealing with long-term strategic issues, while welcome in principle, has imposed further costs on the MDBs and capitals in terms of preparing documentation and meetings.

It doesn’t have to be that way. Twenty years ago the process was much simpler and less costly. Even today, recent MDB capital increases, which mobilized resources for the non-concessional windows of the MDBs, were achieved with much simpler processes, and the replenishment consultations for special purpose funds, such as the Global Fund for HIV/AIDS, tuberculosis, and malaria and for the GAVI Alliance, are more streamlined than those of the MDBs.

So what’s to be done?

We recommend the following measures to fix the replenishment consultation process:

1. Focus on a few strategic issues and reduce the number of commitments with an explicit consideration of the costs and capacity requirements they imply. Shift the balance of monitoring and accountability from delivery of outputs to implementation and outcomes.
2. Prepare no more than five documents for the consultation process: (i) a midterm review on the implementation of the previous replenishment and key issues for the future; (ii) a corporate strategy or strategy update; (iii) the substantive report on how the replenishment resources will contribute to achieve the strategy; (iv) a financial outlook and strategy document; and (v) the legal document of the replenishment resolution.
3. Reduce the number of meetings for each replenishment round to no more than three and lengthen the replenishment period from three to four years or more.
4. Use the newly established working group meetings between replenishment consultation rounds to focus on one or two long-term, strategic issues, including how to fix the replenishment process.

The initiative for such changes lies with the donor representatives in the capitals, and from our interviews with donor representatives we understand that many of them broadly share our concerns. So this is a good time—indeed it is high time!—for them to act.