Judging by his statement, Commissioner Jackson appears to distrust corporate managers (i) when they keep profits within a company and use it to acquire another company and also (ii) when they disburse profits by buying back stock. See, e.g., . In general, a company that has more money than it can reasonably use for internal expansion must either use the money to buy something else or return it to shareholders. Here, Commissioner Jackson argues that "many mergers are not in investors' long-…

Dodd-Frank significantly increased the authority of, and the responsibilities imposed on, the banking regulators, particularly the Federal Reserve Board. Given these greater responsibilities, it is not surprising that bank regulators wish to be cautious. On the other hand, it is their duty to become more familiar with the products and markets that their authority now impacts. To the extent that the regulators exercise undue caution because of a lack of familiarity with a market or product,…

I understand is a big hit in Finland.

This is a significant letter, not so much for its comments on the particular rules, as for what it says about the costs of regulation; i.e., that regulatory change is expensive and that regulatory complexity is expensive, even ignoring the substance of any particular rule. Put differently, in many cases, regulated firms prefer rule stability to rule improvement or liberalization.

That observation is also consistent with a very slow rate of economic growth during the post-Dodd-…