Role and Influence of the Finance Industry in Shaping the Effect of Financial Services Regulation - Research Paper Example

The Role and Influence of the Finance industry and Financial Firms in Shaping the Character and Effect of Financial Services Regulation By Name Course University Date Abstract The financial services sector plays a significant role in the economy. In addition to facilitating savings and economic investments, financial services in the UK are also among the largest exporters and employers. Financial services also make significant contributions to the Gross National Product (GDP). In particular, financial services provide funding for business growth and provide citizens with services allowing them to manage their own finances and assets and to access loans for covering debts and purchasing assets.1Thus the role of financial services in supporting and promoting the health of the real economy influences financial services regulations. In other words, the financial sector plays a significant role in the real economy and this influences financial services regulations. The primary goal of financial services regulations is to ensure that the financial services sector functions efficiently and in doing so, manages risks effectively.2 This research paper examines the role and influence of the financial industry and financial firms in shaping the character and effect of financial services regulation. This paper is therefore divided into three main parts. The first part of this paper analyses the role of the financial sector in the real economy. The second part of the paper analyses the influence of the financial sector on the character of financial services regulation. The final part of this paper analyses the effect of the financial sector on financial services regulation. Table of Contents Abstract 2 Table of Statutes 4 List of Abbreviations 5 Introduction 5 2. The Theory of Capture in Relation to the Financial Services Industry 8 3. The Role of Corporate Social Responsibility in the Financial Sector 9 4. The Character of Financial Services Regulations 10 4.1 The purpose of Financial Services Regulations 10 4.2 The Character of Financial Services Regulation: Soft Rules 11 4.3 The Role and Influence of the Financial Services Sector and Financial Firms on the Character of Financial Services Regulations 12 5. The Effect of Financial Services Regulations 14 3.1 The Role and Influence of the Financial Services Sector and Financial Firms on the Effects of Financial Services Regulations 17 6. Conclusion 20 Bibliography 22 Table of Statutes Banking Act 2009. Directive 2013/36/EU. Financial Services and Markets Act 2000. Financial Services Act 2012. Regulation (EU) No. 575/2013. List of Abbreviations CSR: Corporate Social Responsibility EU: European Union FCA: Financial Conduct Authority FSA: Financial Services Authority GDP: Gross Domestic Product PRA: Prudential Reporting Authority Introduction Financial institutions and firms are different from other firms in that when other firms fail, only shareholders and creditors feel the burden of the failure.3 When financial institutions fail, the effects are more widespread.4 This is because financial institutions and firms are also commercial banks that receive customers’ deposits, and where customers, governments and businesses have access to credit.5 Financial institutions and firms also include securities houses that aid in securities trading.6 Financial institutions and firms also include insurance companies which cover losses in property, health and life.7 As it is, there are no ‘formal international rules’ regulating financial institutions and as a result, ‘soft law rules’ are applied.8 Soft law rules include Basel III which is an updated version of capital and liquidity standards which was implemented in 2010 and updated in 2011. Another source of soft rules for financial institutions is the Financial Stability Board which published Core Principles for Effective Banking Supervision in 2011 which include corporate governance and recovery and resolution guidance. Many of these soft rules are also in national financial services regulations.9 For example, the UK’s financial sector is regulated by the Financial Services Authority (FSA) now known as the Financial Conduct Authority (FCA), an independent body of financial markets and services experts.10 The FSA was replaced by the FCA.11 Thus the character of financial services regulation is one of expertise and independence from government intervention. The independence and expertise of the FCA is necessary for satisfying the government’s renewed interest in managing risks and restoring investor and consumer confidence in the financial services sector.12 Thus the effect of financial services regulation is risk management through oversight by a body of experts that the financial services sector finds acceptable. The financial services sectors role and influence on the character and effect of financial services regulation is no different than its role in and influence on the real economy. Although a driver of and intermediary in the stability of the real economy, financial services are nonetheless, both public and private activities.13 However, regulating the financial services is necessitated by the complexity of financial services and the potential devastating consequences of risks mismanagement.14 Thus the FCA as an independent body, provides a means by which the private and public activities carried out by the financial services sector can be regulated without excessive government intrusion. The independent character of the FCA as the main regulatory body of the financial services sector in the UK is consistent with the public interest theory of regulations as opposed to the capture theory of regulations. The capture theory of regulations suggest that financial institutions exploit the government’s authority to their own advantage.15 Thus the question for consideration is whether or not the role and influence of financial institutions in the real economy and thus the public interest in financial transactions shapes the character and effect of financial services regulations or whether the interest of financial institutions and firms shapes the character and effect of financial services regulations. This paper is divided into four main parts. The first part of this paper discusses the theory of capture. The second part of this paper discusses the role of Corporate Social Responsibility in the Financial Sector. The third part of this paper analyses character of financial services regulation and the role and influence of the financial services sector and financial firms in shaping the character of financial services regulations. The fourth part of this paper discusses the effect of financial services regulations and the role and influence of the financial services sector and financial firms in shaping the effect of financial services regulations. 2. The Theory of Capture in Relation to the Financial Services Industry The theory of capture argues that capture is ‘present whenever a particular sector of the industry, subject to the regulatory regime’ has a significant influence over the regulatory regime that is ‘disproportionate to the balance of interests envisaged when the regulatory regime was established’.16 The regulation of the financial services sector is particularly complex and it can be argued that regulators are captured by the financial services sector.17 However, there is far more evidence that the regulation of financial services is captured by the public interest which is in turn informed by the role that the financial sector play in the real economy. For example, the regulatory regime does point toward a desire to support and promote financial institutions. However, this could mean that this support and promotion is based on the belief that the financial services sector promotes and supports the real economy and thus the public interests. The public interest is further evidenced by a regulatory regime that supervises and establishes how financial services can and cannot be conducted.18 It therefore appears that the financial services sector indirectly captures the regulatory regime in that the character and effect of financial services regulation suggest it is the relationship between financial services and the public via the real economy that guides regulatory choices. 3. The Role of Corporate Social Responsibility in the Financial Sector The public interest capture of financial services regulation is further seen through the nature of corporate social responsibility (CSR).19 CSR in the financial sector is a ‘market-based’ theme showing standards that are created by the financial sector.20 For example, the Equator Principles were established by banks for ensuring that banking projects comply with CSR issues associated involved in a project. However, the individual bank’s monitoring and supervision of the project’s CSR is not checked externally.21 Similarly, market-based regulations apply to the reputation of financial institutions and firms involved in investment projects that involve CSR .22 This sort of regulation requires some form of reputation ranking and the emphasis is on stakeholder and public interests.23 Therefore, even where the financial services sector self-regulate in CSR, it is captured by the public interest. 4. The Character of Financial Services Regulations 4.1 The purpose of Financial Services Regulations The character of financial services regulations is both microprudential and macroprudential theories of financial regulation.24 Microprudential regulation is rearded as conventional financial regulation based on the idea that financial institutions, especially banks, ‘finance themselves with government-insured deposits’.25 Therefore, if left to their own discretion, financial institutions could take excessive risks since the taxpayers bear the burden through government-insured deposits.26 The goal of financial regulation is to see that financial institutions ‘internalize losses,’ safeguarde the insurance deposit and mitigate ‘moral hazard’.27 Macroprudential regulations is described as: …an effort to control the social costs associated with excessive balance-sheet shrinkage on the part of multiple financial institutions hit with common shock.28 In other words when financial institutions face shocks, they usually shrink assets via reducing lending and as a result, this has a negative impact on the real economy. When a number of banks take this form of action the price of securities drop causing a ‘fire sale’ and a credit crunch.29 Macroprudential theorists argue that instead of shrinking assets, financial institutions should keep a capital balance as a shield against shocks.30 4.2 The Character of Financial Services Regulation: Soft Rules The macroprudential character of financial services regulations is reflected by the Basel Accords especially Basel III which was introduced after the global financial crisis, 2008.31 The Basel Accords for minimum capital requirements were implemented by the European Union (EU) via Regulation (EU) No. 575/2013. Regulation (EU) No. 575/2013 provides that financial institutions must maintain a minimum capital ‘ratio’ of 8%.32 The microprudential character of financial services regulations is seen by the further implementation of the Basel III through Directive 2013/36/EU. The Directive calls for ‘access to the activity of credit institutions and investment firms’ and ‘supervisory powers and tools for the prudential supervision of institutions by competent authorities’.33 Supervisory powers in the UK are conferred upon the FSA/FCA under the Financial Services and Markets Act 2000. The character of the FSA/FCA regulatory powers is seen by its goals. The goals are to ensure ‘market confidence’, ‘financial stability’, protect consumers and reduce financial crime.34 In meeting these goals the 2000 Act calls for transparency and for the FSA/FCA to request information coupled with the authority of the FCA to enforce a breach of compliance via the Tribunal.35 The 2000 Act also provides penalties for false or misleading statements requiring accurate published statements for investors.36 The Banking Act 2009 goes into greater detail establishing permissible activities, rules for disqualifying directors and for enforcing compliance.37 The 2009 Act ties in with the 2000 Act in placing regulatory control on the FCA who must implement regulatory rules. The end result is that the financial services industry’s regulatory regime is characterized by close supervision by a body of experts that are independent, but created by legislators. The financial sector’s role in and influence on the shaping of the character of regulations is therefore connected to the financial institutions’ ‘complexities’, fragmented information, ‘interdepedencies, ungovernability and the rejection of a clear private-Public distinction.’38 4.3 The Role and Influence of the Financial Services Sector and Financial Firms on the Character of Financial Services Regulations The minimum capital requirements is influenced by the financial services sector’s role in the real economy. In lean times, financial institutions usually shrink their assets through reducing loans. However, this only contributes to worsening the economic downturn.39 At the same time, financial institutions have the security of deposit insurance, thus, capital requirements can prevent excessive risk-taking. For example, financial institutions, with the knowledge that insurance provides security against risks may approve loans for borrowers who are not qualified.40 The risk of this kind of behaviour in the financial sector influences the minimum capital requirement contained in financial services regulation.41 Goodhart’s article reveals that the 2008 global financial crisis exposed the role and influence of the financial services sector and financial firms in the microprudential and macroprudential character of regulatory responses.42In particular, Goodhart states that the behaviour of the financial sector prior to the global financial crisis played a significant role in and influenced post-crisis regulatory responses. Some of this behaviour include solvency problems which are exacerbated by insurance, liquidity risk mismanagement, crisis mismanagement and lack of due diligence.43The financial services regulations described in the previous section are consistent with this kind of behaviour. For example, liquidity mismanagement appears to be connected to the minimum capital requirement.44 The lack of due diligence in lending is also connected to the minimum capital requirement.45 However, the lack of due diligence is also linked to the call for transparency and the supervision of financial market activities. For the most part, the minimum capital requirement appears to be the catalyst for risk-taking and the regulatory transparency and accountability responses.46 In a study conducted by Pennacchi, it was discovered that deposit insurance was linked to financial system risks. In reality, deposit insurance is an incentive for financial institutions to ‘take excessive systematic risks’.47By implementing a minimum capital requirement, it is anticipated that financial institutions would manage risks more efficiently. It can be concluded that the deposit insurance is a necessary safety net to protect against systematic failure for the benefit of investors, the financial sector and the economy as a whole. After all, there is a risk of loss in all financial transactions regardless of the due diligence. However since the deposit insurance is believed to have contributed to excessive risk-taking, this influenced regulators to implement a minimum capital requirement. At the same time, the primary concern is the role that financial institutions play in stimulating and maintaining a healthy economy. 5. The Effect of Financial Services Regulations The intended effect of financial services regulations through capital requirements is threefold. First, it is intended to improve confidence in the banking system, by providing ‘predictability for banks and bank shareholders’.48 Secondly, minimum capital requirements prevents a financial institution’s capital ‘falling to levels that threaten losses’ to the ‘insurance fund.’49 Additionally, the minimum capital requirement requires financial institutions to keep a net worth on the positive side and acts as a buffer against the risk of ‘moral hazard’.50 Thirdly, the minimum capital requirement ensures that ‘early corrective action mitigates the regulatory forbearance problem by preventing regulators from using their discretion about whether or not to take action.’51 It is anticipated that the effect of a capital requirement is that financial activities are no longer restricted. With banks having to maintain a minimum capital, there will always be enough capital held against these activities and there is no longer the need to fall back on deposit insurances. The prospect of having to fall back on a minimum capital requirement is also expected to provide an incentive for financial institutions to harness their risk-taking.52 The overall effect of financial regulation is to facilitate a system of financial services that is proactive in preventing systematic failure as opposed to a reactive system.53 The focus is meant to be on crisis prevention as opposed to risk prevention because risks will always be present.54 The regulatory framework under the FCA in the UK is arguably designed to prevent crisis or to ensure crisis management through the requirement of transparency and accurate reporting. Similarly, both the deposit insurance and minimum capital requirements are intended to prevent crises or to provide a system for crises management. In the protection of consumers, the FCA is reminded that the effect of regulation is not to eliminate risk. Specifically, Section 1C of the Financial Services Act 2012 states that in providing consumers protection the FCA must take account of the ‘differing degrees of risk involved in different kinds of investment or other transactions’.55 Thus the effect of financial regulation is not to protect consumers from nor to prevent risks altogether. The main effect is the extent to which risks are managed within the overall crises prevention and management scheme. Another effect of financial services regulation is contained in Section 1D of the Financial Services Act. Section 1D provides that one of the main purpose of the FCA’s mandate is an integrity objective. In this regard, ‘the integrity objective is: protecting and enhancing the integrity of the UK financial system.’56 The integrity objective describes integrity as the ‘soundness, stability and resilience’ of the UK’s financial system.57 Integrity also means that the UK’s financial system is not being used for ‘a purpose connected with financial crime’ or that it is not ‘being affected by behaviour that amounts to market abuse’.58 Integrity also means that the UK’s financial system is such that the financial markets are operating in an orderly manner and the price information in the financial markets is transparent.59 Another intended effect of financial services regulation is contained in the competitive objective of the FCA under the Financial Services Act 2012. The FCA’s competition objective is market by the promotion of consumer interests. The FCA may take account of the different needs of consumers ‘who use or may use’ financial services, ‘including their need for information’ enabling ‘them to make informed choices’.60 The FCA should also take into consideration the ‘ease with which consumers’ using financial services or seeking to use financial services ‘can access them.’61 A competitive financial services markets also means that consumers can easily change from one service provider to another. A competitive market should also be one in which ‘new entrants can enter the market’ and for further consideration, the FCA should take account of ‘how far competition is encouraging innovation’.62 The consumer centric effect of financial regulations is implicit in the behaviour of investors of all types. For the most part it appears that financial regulation reform is a response to investor behaviour and concerns for the effect that financial transactions have on consumption trends. For example, in a White Paper by Freddie McMahon, it was noted that investors are becoming more sophisticated in demanding information. Investors now want more certainty and are demanding ‘greater control’ over their investments.63 This may very well be an effect of the regulatory regime which creates a chain reaction. With the FCA demanding transparency, consumers have come to expect greater transparency and with an increase in demand for transparency legislators have now emphasized the importance of consumer information. It can be concluded that the effect of financial services regulation is multi-faceted. The overall intended effect is to protect consumers/investors from excessive risk-taking or poor crisis management. This is accomplished by two significant tools: minimum capital requirements and transparency. . 3.1 The Role and Influence of the Financial Services Sector and Financial Firms on the Effects of Financial Services Regulations Arguably, the role and influence of the financial services sector and financial firms on the effects of financial services regulations has an easy co-existence with those of regulators. As Macey argues: In finance, regulators and market participants ostensibly have overlapping, if not identical, goals. Those goals are to measure risk accurately and in a timely fashion, to improve the reliability of corporate disclosure in order to enable firms to make credible commitments to investors, and to cause scarce resources (capital) to flow to those market participants who can best make the best use of it.64 The financial services sector is interested in obtaining investors and consumers by demonstrating that they can be distinguished from competitors. At the same time regulators are determined that consumers and investors are put in a position to make good investment decisions s.65 Although the financial services sector is determined to achieve vastly similar goals, they may differ in how they wish to achieve them. Therefore one party has an impact on the other. In this case the financial services have a role to play in and influences the shaping of the effect of financial services regulation. For instance, the financial services sector and financial firms design securities and ‘incentive-based compensation’ and other devices as a ‘signal that they are telling the truth’.66This influences regulators to implement transparency rules and penalties for fraud. However, since regulators have found it difficult to detect fraud, this results in the implementation of devices and instruments commonly used by the financial services sector.67 Thus, the financial services sector and financial firms have a direct influence on the effect of regulations. The most important role of and influence of the financial services sector is its impact on the real economy. Regulators are more concerned with stability within the financial services sector to promote economic stability. For example, in a press release by the European Commission in May 2014, President of the European Commission, Jose Manuel Barroso stated: The financial services industry is one of Europe’s greatest assets, and we want it to prosper so that it can lend to citizens and businesses and so help the recovery in the wider economy. But European taxpayers have forked out huge amounts to prevent a financial collapse, and they rightly ask two things in return: that the sector plays its role fairly, and that future banking crises never again become sovereign crises. This is about fairness.68 Therefore, the role and influence of the financial services sector in the shaping of the effect of regulation is dependent on its contribution to economic health. In other words, regulators are mindful of the significant role that the financial services sector plays in the economic health and how this is influenced by the relationship between consumers, investors and the financial services sector. What this all means is that the main role and influence of the financial services sector on shaping the effect of financial services regulators is the risks that financial services entail. There are risks that arise during the course of business. These risks are ‘inherent risks’ and are largely unavoidable.69 However, risks that arise out of control and management of inherent risks can be regulated and this drives the shaping of the effect of financial regulation. In this regard, financial regulators want to ensure that financial firms and the financial sector have tools for assessing and rating risks, communicate their assessments to the proper authorities, and have appropriate responses to risks.70 It can therefore be concluded that market discipline or the extent to which the financial services sector demonstrate market discipline in terms of promoting a healthy economy is the main role and influence on the shaping of the effects of financial services regulation. Market discipline is intended to prevent excessive risk-taking which inevitably leads to financial crisis to the detriment of the economy. Thus as long as the financial services sector and financial firms conduct business in ways that threaten economic stability, regulators will step in to promote market discipline. However, both regulators and the financial services sector have an equal incentive to promote and maintain a healthy economy. Therefore this incentive both influences and plays a role in the shaping of the effects of financial services regulation. 6. Conclusion Research findings indicate that the financial services sector and financial firms play a significant role and influences the shaping of the character and effects of financial services regulations. All regulatory frameworks and methods follow from the fact that the financial services sector and financial firms are drivers of the economy. Just as the financial services sector’s transactions and behaviour promote economic health, transactions and behaviour can be devastating to the economy, if the financial sector and financial firms are left to their own devises. The primary concern is that when there are economic shocks, the financial services sector will shrink assets which only worsens crises. This is turn influenced regulators to create a capital requirements focused on liquidity and consumer protection. The mere nature of risks associated with financial transactions has also influenced the way that regulators approach risk management and crisis prevention as well as consumer and investment protection. Even so, there is a correlation between what regulators want to achieve and what the financial services’ sector wants to achieve: a productive financial market. Regulators are informed by the nature of the business and its relationship with consumers and investors. In this regard, regulators play the role of mediators between the financial services sector and their consumers and investors and seek to promote the welfare of both factions for the greater good of the community. Therefore it is the relationship between the financial services sector and the economy that defines its role and influence on the shaping of the character and effect of financial services regulations. Research Report: A research of financial services regulations was conducted before beginning the research. In this regard, the researcher read the Financial Services and Markets Act 2000, the Financial Services Act 2012, and the Capital Requirement Directive (EU) and Regulation (EU). The researcher peruses the Basel Accords. Upon reading the legislation, the researcher conducted research via a review of literature on the FSA and the FCA as well as commentary and critique of the statutory instruments studied. Textbooks were read for factual and theoretical information and analysis. Journal articles were read for analysis and critique of financial services and financial firms’ role and influence on shaping the character and effect of financial services regulation. At the end of the day, the researcher was unable to find any material or argument directly linking the role and influence of the financial services sector. The researcher therefore decided to first look at the character of financial services regulation and to tie it in with the financial services industry. Similarly, the researcher looked at the effect of financial services regulations and tied that in with the role and influence of the financial services sector. Bibliography Textbooks Andenas, M and Chiu, I The Foundations and Future of Financial Regulation: Governance for Responsibility, (Oxon: Routledge 2014) 93. Cotteir, T and Lastra, RM ‘Introduction,’ In Cottier, T; Jackson, JH and Lastra, RM (Eds.) International Law in Financial Regulation and Monetary Affairs, (Oxford, UK: Oxford University Press 2012) 1-8. de Bondt, GJ, Financial Structure and Monetary Transmission in Europe: A Cross-Country Study, (Cheltenham, Glos.: Edward Elgar Publishing Limited 2000). Drumond, I, ‘Bank Capital Requirements, Business Cycle Fluctuations and the Basel Accords: A Synthesis,’ In Sayer, S (Ed.) Issues in Finance: Credit, Crises and Policies, (West Sussex: John Wiley and Sons 2010) 5-38. Falconer, S, Financial Services Management: A Qualitative Approach, (Oxon: Routledge 2014). Herring, RJ and Carmassi, J, ‘Complexity and Systematic Risk: What’s Change Since the Crisis?’ In Berger, AN; Molyneux, P and Wilson, JOS (Eds.) The Oxford Handbook of Banking, (Oxford: Oxford University Press 2010) 77-112. Johnson, C and Kaufman, GG, ‘When a Bank is not a Bank: The Case of Industrial Loan Companies,’ In Bliss, RR and Kaufman, GG, (Eds.) Financial Institutions and Markets: Current Issues in Financial Markets, (New York, NY: Palgrave MacMillan 2008) Ch. 1. Jorion, P, Financial Risk Manager Handbook. (Hoboken, NJ: John Wiley & Sons, Inc 2009). Waters, DF and Hopper, M, ‘Regulatory Discipline and the European Convention on Human Rights – A Reality Check,’ In Ferran, E and Goodhart, CAE (Eds.) Regulating Financial Services and Markets in the Twenty First Century, (Oxford: Hart Publishing 2001) 95-114. Journal Articles Baxter, LG, ‘Capture in Financial Regulation: Can we Channel it Toward the Common Good?’ (2011) 21 Cornell Journal of Law and Public Policy, 175-200. Edwards, FR and Mishkin, FS, ‘The Decline of Traditional Banking: Implications for Financial Stability and Regulatory Policy,’ (July 1995) FRBNY Economic Policy Review, 27-47. Goodhart, CAE, ‘The Regulatory Response to the Financial Crisis,’ (December 2008)4(4) Journal of Financial Stability, 351-358. Hanson, SG; Kashyap, AK and Stein, JC,‘A Macroprudential Approach to Financial Regulation,’ (Winter 2011) 25(1) The Journal of Economic Perspectives, 3-28. Levine, ME and Forrence, JL, ‘Regulatory Capture, Public Interest, and the Public Agenda: Toward a Synthesis,’ (April 1990) 6 Journal of law, Economics & Organization, 167-198. Ling, SL; Hwang, D-Y; Wang, KL and Xie, ZW, ‘Banking Capital and Risk-taking Adjustment under Capital Regulation: The Role of Financial Freedom, Concentration and Governance Control,’ (2013 2(2) International Journal of Management, Economics and Social Sciences, 99. Macey, JR, ‘The Regulator Effect in Financial Regulation,’ (2013) 98 Cornell Law Review, 591-636. Peek, J and Rosengren, E, ‘The Capital Crunch: Neither a Borrower nor a Lender Be,’ (August 1995) 27(3) Journal of Money, Credit and Banking, 625-638. Pennacchi, G, ‘Deposit Insurance, Bank Regulation, and Financial System Risks.’ (January 2006) 53(1) Journal of Monetary Economics, 1-30. Wade, R, ‘A New Global Financial Architecture,’ (July-August 2007) 46 New Left Review, 113. Miscellaneous Publications Black, Dr. J, ‘The Development of Risk Based Regulation in Financial Services, Canada, the UK and Australia: A Research Report,’ (September 2004) ESCR Centre for the Analysis of Risk and Regulation, London School of Economics and Political Science, 1-66 Claessens, S and Kodres, L, ‘The Regulatory Responses to the Global Financial Crisis: Some Uncomfortable Questions,’ (March 2014) International Monetary Fund, Research Department and Institute for Capacity Development, WP/14/46, 1-39. European Commission, ‘Financial Regulation: European Commission Presents a First Comprehensive Review of the EU’s Reform Agenda,’ (15 May 2014) Press Release, Brussels, 1-4. Great Britain, Parliament, House of Lords, ‘The Future of EU Financial Regulation and Supervision,’ (London, UK: The Stationery, 1999 HM Treasury, ‘A New Approach to Financial Regulation: Building a Stronger System,’ (February 2011) CM 8012. McHahon, F, ‘A Customer-Centric Paradigm Shift in the UK Pensions and Investment Industry,’ (February 2011) White Paper, Fusion Experience, 1-20. Read More