Wednesday, May 27, 2020

Omnibus Part Ii Challenges to Implementation

FINANCIAL PROFESSIONAL CONTENT This article assumes you have a basic understanding of what omnibus is based on its preceding article located here: Omnibus: What it is and why advisors should care. In a previous article, I discussed what makes omnibus so alluring: Clients receive statements and all tax reporting documents from a single firm and advisors are able to create, open, and administer 529 accounts from within their in-house system. But if omnibus is so great and provides all these unified services, why doesnï ¿ ½t every firm do it? 1. There are logistical challenges Omnibus creates an additional administration layer between the state sponsor and the 529 provider. From the stateï ¿ ½s perspective, assets inside an omnibus account appear as a single account. This means they cannot audit individual accounts without the cooperation of the broker-dealer that has taken over the recordkeeping of those accounts. This makes it difficult, if not impossible, for the state or the plan provider to conduct any sort of antifraud and AML (anti-money laundering) oversight in a systematic and routine way. Instead, those responsibilities are reallocated to the broker-dealer through the omnibus agreement, where the broker-dealer ensures that they will conduct all the required anti-fraud and AML due diligence. This is not to say that the broker-dealer isnï ¿ ½t capable of performing those activities, as they already do so every day for many other products. However, itï ¿ ½s the additional layer and complexity that is cause for concern. The current regulatory culture favors transparency, which omnibus accounting masks by its nature. Just this year the CMFI (Coalition of Mutual Fund Investors) sent comment to the SEC expressing concern over transparency in omnibus accounts and intermediary subaccounting. That being said, when a 529 plan provider is also a sizable broker-dealer, their systems may already be vertically integrated. For example, Merrill Lynchï ¿ ½s Next Gen accounts already sit in their proprietary recordkeeping system, which services and supports their own advisors. ï ¿ ½As the program manager for the Maine NextGen College Investing Planï ¿ ½, Merrill Lynch has always had the NextGen plan integrated (aka, omnibus) on our platform,ï ¿ ½ says Rich Polimeni, Director, Education Savings Programs. 2. There are legal challenges Almost every 529 plan has a state sponsor, and each state has different laws and oversight requirements for its respective 529 plan(s). Some of these laws were created to protect 529 account holders from exactly the kinds of activity made opaque by omnibus: fraud and money-laundering. A state may require annual audits for purposes of reconciling tax credit or deduction claims and grant requests. In other states the laws were simply written in a way that makes implementation challenging without a change in legislation, which is time-consuming. In each case a unique solution to omnibus implementation may be required to meet state legal requirements ï ¿ ½ if they can be met at all ï ¿ ½ further driving up costs and diminishing the appeal of going omnibus to both broker-dealer and 529 plan provider. 3. There are cost challenges In the 529 space, which is a low-margin and relatively low-asset business, getting the resources necessary to implement omnibus requires some internal campaigning at the broker-dealers. Wrestling technology development staff time from projects involving higher-margin products, such as retail and retirement investment accounts, requires a justifiable payoff timeline. For a smaller broker-dealer with only a few hundred or even a few thousand advisors, the cost to implement omnibus is not economically justified. ï ¿ ½It requires significant resources and time for broker-dealers to convert individual 529 accounts to an omnibus structure in a given 529 plan,ï ¿ ½ says Ascensusï ¿ ½s Chief Product Officer, Scott Morrison.ï ¿ ½In many cases the broker-dealer account base will not justify such an investment.ï ¿ ½ However, when you reach the scale of a wirehouse where you have tens of thousands of advisors, there comes a tipping-point where it may be less expensive to oversee and administer 529 business in-house, due to reduced paperwork, administration at the advisor level, and better internal reporting and oversight controls. When you add in how much easier it makes life for the advisor, who can open and fund an account within their own firmï ¿ ½s systems, it makes for a compelling case to secure those internal resources for implementation. Yet it can still be a challenge because it further requires partnerships between the broker-dealer and each 529 provider, legal agreements between both parties that can take months of negotiation, and ï ¿ ½ usually ï ¿ ½ the review and approval of the state sponsor. Further, some state sponsors are more diligent than others, extending the process in terms of time and resources. Given all of these challenges, itï ¿ ½s not surprising that after more than ten years of discussion omnibus implementation only a handful of firms have a live omnibus environment with one or more 529 providers. Several have had delays after starting the process, only to find one or more of the aforementioned challenges insurmountable. In the next newsletter we will look at alternatives to omnibus and what the future may hold for 529 plan administration. FINANCIAL PROFESSIONAL CONTENT This article assumes you have a basic understanding of what omnibus is based on its preceding article located here: Omnibus: What it is and why advisors should care. In a previous article, I discussed what makes omnibus so alluring: Clients receive statements and all tax reporting documents from a single firm and advisors are able to create, open, and administer 529 accounts from within their in-house system. But if omnibus is so great and provides all these unified services, why doesnï ¿ ½t every firm do it? 1. There are logistical challenges Omnibus creates an additional administration layer between the state sponsor and the 529 provider. From the stateï ¿ ½s perspective, assets inside an omnibus account appear as a single account. This means they cannot audit individual accounts without the cooperation of the broker-dealer that has taken over the recordkeeping of those accounts. This makes it difficult, if not impossible, for the state or the plan provider to conduct any sort of antifraud and AML (anti-money laundering) oversight in a systematic and routine way. Instead, those responsibilities are reallocated to the broker-dealer through the omnibus agreement, where the broker-dealer ensures that they will conduct all the required anti-fraud and AML due diligence. This is not to say that the broker-dealer isnï ¿ ½t capable of performing those activities, as they already do so every day for many other products. However, itï ¿ ½s the additional layer and complexity that is cause for concern. The current regulatory culture favors transparency, which omnibus accounting masks by its nature. Just this year the CMFI (Coalition of Mutual Fund Investors) sent comment to the SEC expressing concern over transparency in omnibus accounts and intermediary subaccounting. That being said, when a 529 plan provider is also a sizable broker-dealer, their systems may already be vertically integrated. For example, Merrill Lynchï ¿ ½s Next Gen accounts already sit in their proprietary recordkeeping system, which services and supports their own advisors. ï ¿ ½As the program manager for the Maine NextGen College Investing Planï ¿ ½, Merrill Lynch has always had the NextGen plan integrated (aka, omnibus) on our platform,ï ¿ ½ says Rich Polimeni, Director, Education Savings Programs. 2. There are legal challenges Almost every 529 plan has a state sponsor, and each state has different laws and oversight requirements for its respective 529 plan(s). Some of these laws were created to protect 529 account holders from exactly the kinds of activity made opaque by omnibus: fraud and money-laundering. A state may require annual audits for purposes of reconciling tax credit or deduction claims and grant requests. In other states the laws were simply written in a way that makes implementation challenging without a change in legislation, which is time-consuming. In each case a unique solution to omnibus implementation may be required to meet state legal requirements ï ¿ ½ if they can be met at all ï ¿ ½ further driving up costs and diminishing the appeal of going omnibus to both broker-dealer and 529 plan provider. 3. There are cost challenges In the 529 space, which is a low-margin and relatively low-asset business, getting the resources necessary to implement omnibus requires some internal campaigning at the broker-dealers. Wrestling technology development staff time from projects involving higher-margin products, such as retail and retirement investment accounts, requires a justifiable payoff timeline. For a smaller broker-dealer with only a few hundred or even a few thousand advisors, the cost to implement omnibus is not economically justified. ï ¿ ½It requires significant resources and time for broker-dealers to convert individual 529 accounts to an omnibus structure in a given 529 plan,ï ¿ ½ says Ascensusï ¿ ½s Chief Product Officer, Scott Morrison.ï ¿ ½In many cases the broker-dealer account base will not justify such an investment.ï ¿ ½ However, when you reach the scale of a wirehouse where you have tens of thousands of advisors, there comes a tipping-point where it may be less expensive to oversee and administer 529 business in-house, due to reduced paperwork, administration at the advisor level, and better internal reporting and oversight controls. When you add in how much easier it makes life for the advisor, who can open and fund an account within their own firmï ¿ ½s systems, it makes for a compelling case to secure those internal resources for implementation. Yet it can still be a challenge because it further requires partnerships between the broker-dealer and each 529 provider, legal agreements between both parties that can take months of negotiation, and ï ¿ ½ usually ï ¿ ½ the review and approval of the state sponsor. Further, some state sponsors are more diligent than others, extending the process in terms of time and resources. Given all of these challenges, itï ¿ ½s not surprising that after more than ten years of discussion omnibus implementation only a handful of firms have a live omnibus environment with one or more 529 providers. Several have had delays after starting the process, only to find one or more of the aforementioned challenges insurmountable. In the next newsletter we will look at alternatives to omnibus and what the future may hold for 529 plan administration.

Tuesday, May 19, 2020

Karl Marx s Theory Of Human Exploitation And Alienation...

Capitalism is an economic system in which the investment and distribution of wealth is maintained by individuals and businesses under little governmental regulation. It protects individual rights, allowing one to hold private property and investments in their own name. That being said, some, such as Karl Marx, find the capitalist system dehumanizing and see a dire need for its abolition. In this paper, I will present an argument against Karl Marx’s theory of human exploitation and alienation under capitalism. I will begin by discussing Marx’s basic beliefs on human nature. I will then use this foundation to present Marx’s argument against capitalism and how he believes it leads to human alienation. Lastly, I will refute Marx’s argument against capitalism and provide a compelling argument in defense of capitalism. The Marxist view of human nature is rooted in the belief that humans are essentially productive beings that work for their living. They have an inherent drive to engage in purposive productive activity. The way that one exerts this productive activity is socially learned and directly affected by the economics of the society in which one lives (Stevenson 197). On an even larger scale, Marx claims that a society’s economic base conditions its entire ideological superstructure, which includes its system of beliefs, laws, morality, politics, and philosophy. There are two components to a society’s economic base: its material powers of production and itsShow MoreRelatedKarl Marx : A German Influential Philosopher And One Of The Intellectual Fathers Of Communism1477 Words   |  6 PagesKarl Marx is known to be a German influential philosopher and one of the intellectual fathers of communism, writing when the industrial revolution and imperialism period was changing the nat ure of both the economies of individual nations and the global economy itself. 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Wednesday, May 6, 2020

The Human Lifespan Is Full Of Growth And Development

Morgan Howard PSY 2023- Developmental Psychology Professor Hanselman-Scott 26 April 2015 The human lifespan is full of growth and development. Lifespan development is categorized into five major stages, which are the prenatal period, infancy, childhood, adolescence, and adulthood. While physical changes are obvious, we also develop in less obvious ways, such as cognitively and socially. Development begins during the prenatal period. This developmental stage begins as soon as the sperm meets the egg and fertilization occurs. During this period, the mother’s diet, age, and drug use can have a major effect on the fetus. Cognitive functions can be affected by the drug and alcohol use of the mother. An example of this is seen in a child with a fetal alcohol spectrum disorder. A child with FASD may have a poor memory, difficulty paying attention, and/or language delays (â€Å"Alcohol Use in Pregnancy†). The mother’s use of drugs and alcohol can also lead to difficulty dealing with multiple stimuli and forming attachments. Intelligence and certain personali ty traits may be partially determined during this time. The prenatal period ends with the birth of the infant. During infancy, infants experience many cognitive changes. Infants begin to express curiosity and explore their surroundings. They may do this by reaching and grasping for objects that interest them, or by wiggling and crawling towards an interesting object. Jean Piaget studied cognitive development from infancy throughShow MoreRelatedLifespan Development1516 Words   |  7 PagesLifespan Development and Personality Luis Cervantes PSY/103 January 11, 2016 Susanne Nishino Lifespan Development and Personality Developmental psychology is the study of how human beings age and transform throughout the eight major stages of life. 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Hiv And Its Effects On Society - 1724 Words

HIV Song Choi 76914396 Public Health 1 2016 Dr. Zuzana Bic Public Health Problem HIV, which stands for Human Immunodeficiency Virus, belongs to a group of virus called retroviruses. HIV attacks the immune system and gradually causes greater and harmful damages. This means that without the proper care or treatment, a person who is affected by HIV is at a higher risk of developing infections and cancers than those who have a healthy immune system. HIV is an important issue in the society because according to the publications on Unlocking HIV, this infection is correlated with behaviors such as promiscuity, drug addiction, prostitution, or homosexuality. People become infected with HIV through sex,†¦show more content†¦According to The Aids Institution, scientists believe that a type of chimpanzee in West Africa was the source of HIV infections in humans. The earliest known HIV infection in humans was later detected in blood samples and it suggested that the root of the virus originated from chimpanzees. They believe that when humans h unted chimpanzees for meat and became exposed with their infected blood, a virus called simian immunodeficiency was transmitted to humans and then mutated into HIV. As time went by, the virus spread into other parts of the world and unfortunately became a nationwide epidemic. Researchers believe that HIV was introduced through the chimpanzees infected blood as people hunted the chimpanzees. The infected blood became the root of this retrovirus, which now is a life-threatening virus that affects the immune systems of humans. The community is already in great danger due to the HIV epidemic. HIV prevention efforts have helped people avoid this infection, but these efforts have not been able to stop this epidemic as a whole. The Centers for Disease Control and Prevention and Johns Hopkins University estimated that the number of people living with HIV would increase as time goes by. Unfortunately, as more people become exposed to HIV, transmission will also increase. This will ultimately increase the need for prevention services and healthcare systems as well as the money invested into finding curable measures for

About Medical Marijuana Essay Example For Students

About Medical Marijuana Essay Marijuana is medicine. It has been used for thousands of years to treat a wide variety of ailments. Marijuana (Cannabis sativa L.) was legal in the United States for all purposes industrial and recreational, as well as medicinal until 1937. Today, only eight Americans are legally allowed to use marijuana as medicine. NORML is working to restore marijuanas availability as medicine. Medicinal Value Marijuana, in its natural form, is one of the safest therapeutically active substances known. No one has ever died from an overdose. It is also extremely versatile. Four of its general therapeutic applications include: relief from nausea and increase of appetite; reduction of intraocular (within the eye) pressure; reduction of muscle spasms; relief from mild to moderate chronic pain. Marijuana is often useful in the treatment of the following conditions: Cancer: Marijuana alleviates the nausea, vomiting, and loss of appetite caused by chemotherapy treatment. AIDS: Marijuana alleviates the nausea, vomiting, and loss of appetite caused by the disease itself and by treatment with AZT and other drugs. Glaucoma: Marijuana, by reducing intraocular pressure, alleviates the pain and slows or halts the progress of the disease. Glaucoma, which damages vision by gradually increasing eye pressure over time, is the leading cause of blindness in the United States. Multiple Sclerosis: Marijuana reduces the muscle pain and spasticity caused by the disease. It may also relieve tremor and unsteadiness of gait, and it helps some patients with bladder control. Multiple sclerosis is the leading cause of neurological disability among young and middle-aged adults in the United States. Epilepsy: Marijuana prevents epileptic seizures in some patients. Chronic Pain: Marijuana reduces the chronic, often debilitating pain caused by a variety of injuries and disorders. Each of these uses has been recognized as legitimate at least once by various courts, legislatures, government, or scientific agencies throughout the United States. Currently, such well respected organizations as the National Academy of Sciences (1982), the California Medical Association (1993), the Federation of American Scientists (1994), the Australian Commonwealth Department of Human Services and Health (1994), the American Public Health Association (1995), the San Francisco Medical Society (1996), the California Academy of Family Physicians (1996), as well as several state nursing associations have supported the use of marijuana as a medicine. In addition, anecdotal evidence exists that marijuana is effective in the treatment of arthritis, migraine headaches, pruritis, menstrual cramps, alcohol and opiate addiction, and depression and other mood disorders. Marijuana could benefit as many as five million patients in the United States. However, except for the eight individuals given special permission by the federal government, marijuana remains illegal-even as medicine! Individuals currently suffering from any of the aforementioned ailments, for whom the standard legal medical alternatives have not been safe or effective, are left with two choices: Continue to suffer from the effects of the disease; or Obtain marijuana illegally and risk the potential consequences, which may include: an insufficient supply because of the prohibition-inflated price or unavailability; impure, contaminated, or chemically adulterated marijuana; arrests, fines, court costs, property forfeiture, incarceration, probation, and criminal records. Background: The Marijuana Tax Act of 1937 established the federal prohibition of marijuana. Dr. William C. Woodward of the American Medical Association testified against the Act, arguing that it would ultimately prevent any medicinal use of marijuana. The Controlled Substances Act of 1970 established five categories, or schedules, into which all illicit and prescription drugs were placed. Marijuana was placed in Schedule I, which defines the substance as having a high potential for abuse, no currently accepted medical use in treatment in the United States, and a lack of accepted safety for use under medical supervision. This definition is simply not accurate. However, at the time of the Controlled Substances Act, marijuana had been illegal for more than 30 years. Its medicinal uses had been forgotten and its reefer madness stigma was still prevalent. Salem Witch Trials Essay Marijuanas medicinal uses were rediscovered as a result of the tremendous increase in the number of recreational users in the 1970s: Marijuanas popularity compelled many scientists to study its health effects. They subsequently discovered marijuanas remarkable history as a medicine, inspiring many studies of its therapeutic potential; Many recreational users who also happened to be afflicted with conditions for which marijuana has therapeutic potential inadvertently discovered its medicinal benefits. As the news spread, the number of patients illegally using marijuana medicinally began to increase. Because marijuana is a Schedule I substance, however, doctors were not allowed to prescribe it, and research approval and funding were severely restricted. The Struggle In Court: In 1972, NORML initiated efforts to .

Tuesday, May 5, 2020

Essay Topic Drawing from Current Literature Example For Students

Essay Topic: Drawing from Current Literature Drawing from Current Literature, Discuss the Relationship Between Pay and Performance Motivation. By antennas The effectiveness of an organization leans on a lot of forces. One really important force is the work team. The work team is the people who work for the production. So, we can easily understand that to achieve an organization their goals have to collect the right workers (persons who have the right knowledge and skills) for a specific work position and to train them correctly, seeing that the organization use the right systems Of organizing. But there is another important force that he businesses must not forget: its the persons disposition to attribute. We talk about I can and want. A basic part Of managerial executive is to make their collaborators to be in mood to want to attribute. The need of incitement for the workers flow from the incident that the work sometimes may be boring, without interest. The central meaning of the word incitement is the motivation. Motivation is an internal power that becomes from the needs. B. Barbells and G. Steiner appoint the meaning of motivation as an internal state which activate and direct the behavior to objectives, The above definition make us understand hat motivations its a decisive element. There is important to Launderettes that motivations have an immediate relevance with the human behavior and it is much more complex than many people believe. But throughout the motivations we can not explain the human behavior. The humanity has been characterized from a huge number of motivation- needs that specify not only from humans nature, but also from the environment where they live and develop. The point is how hard people strive to understand their work tasks, together with the factors that can have an effect on their hard work. In this report we are going to analyze how pay can be a motivation in a work context and the relationship between pay and performance motivation. The payment for a business has a decisive role. First Of all helps the organization to attract the competent candidates, and after that, to keep them in the business. Secondly, the payment its a very strong force because has a great influence at workers attribution. Payment considers every kind of reward to the worker with exchange his tries to achieve the organization goals. Payment consists of: I _ The immediate economical eve: its about the salaries, wages, and the bonuses. . The indirect economical eve: its about the profits like the payments for vacations, permissions and life safeties. Every kind Of business to have the control Of the labor cost, need to use a clear payment system. All the organizations regardless of the payment system that use strive to some specific Objects: Have competitive wages and salaries, to attract the most suitable candidates. To control the labor costs. To pay good attribution stages. To observe the legislative layouts. To decrease the rates of retirements. The policy of salaries or wages and the payment system for every business ecocide the higher administration. But responsible for that policy (that must be fair, competitive, and prompt the workers) is the human resource management. When a person decides to wo rk the reason why is not only economical but also for their social and psychological needs, But can a person cover his social, physical, psychological needs with his salary? Is the payment equal to his work? The workers estimate their salary as a meter of their good attribution. So we can say that the payment for them its a goal, that they try to achieve, and they are waiting from their managers to recognize their work. However the payment lassies the person to the society. Its a criterion for persons value. As much as a person deserve, so much its his payment. By telling a person deserve we mean his accomplishments: knowledge, experience, skills. All the businesses and usually the private sector, in their try to actuate and reward their workers for a specific result attainment, they provide them motivations and bonuses. Language Literature Coursework: Shakespeare; Romeo Juliet EssayPay can provide a positive motivation it the organization use it in the right way and under the right circumstances. That happens not only because people need money to satisfy their personal needs, but also because money may provide recognition. Furthermore any kind of reward and motivation must reflect the changes in culture that an organization is accept. But in some cases pay may be a strong denominator, if the money package is poorly constructed or the organization are not introduce it, in the right way. For this reason motivations must be clear constructed and quantitative. V-Rutherford, when a motivation system is selected, the organization must identify which point the employees can inflect the measure of performance And if a motivation is furlong then no other motivation will work. That happens because then, the employees feel that their targets it is unattainable. Summing up, in this report, we analyze two really important definitions, and the relationship between them. We talked about pay; a decisive force not only in a work context. Every person determines in a different way the importance of his/ her salary. However, it is clear that everyone via the financial amount that he defeats tend to satisfy some needs. We can classify that needs to basic (for example the survival need) and to personal- psychological (for example the need for recognition or acceptance). Conscious or not, every person classifies him/ her self in a position to the society where he/ she lives proportional to the height of his/ her salary, From the above, we can easily understand how important and complex is tort a cuisines to appoint a persons salary (with base the human element). However, its also important for an organization. First of all, the organization examines the height of the salary, which can offer, proportional to a specific job position, Also, another important term that we analyze is the motivations. A company, usually, introduced a motivation system, strive to the persons maximum productivity. Every business can choose the way of incitement from financial motivations (like bonuses) or benefits (for example the promotion of an employee). In my personal opinion, the extra money is the biggest motivation, and its ally attractive for an employee. For sure every person has different standards and different expectations. Money hasnt the same importance for everyone. Someone may be more interested in important personal elements, which we said before, and that does not mean that this person is not interested in money. Yet, believe that nowadays, even we want to accept it or not, the factor that thrust the person to work is money. Especially, when the company offers rewards to the employees. Then the person may be selfish and more competitive to his, her colleagues than he/ she has to be. I just think that everyone of us can moderate it, with basic advantage the mature. There are also important goods that somebody could strive to his/ her work, such as the development of his/ her knowledge or to work with the task that he/ she likes, regardless of the money. In my opinion, if somebody achieve this, the personal needs and the feelings could be more important than that which could otter him/ her a financial amount. Day by day the environment where we live and develop, make us more materialist. So, it would be really helpful our manipulation, and see more realistic the situation which we create.