Press

Winter 2014 Tanya Beder teaches class, Policy and Strategy Issues in Quantitative Finance, at Stanford University’s Law School, see Course Description.

Tanya Beder speaks at San Francisco State University’s 2013 FAME (Financial Analysis and Management Education) Conference on the Global Markets Panel. See www.fameconference.com for more details.

Meet Tanya Beder: On Math, Its Applications, and a Bright Future POSTED ON FEB 04, 2013 IN ARTICLES Where’s the Math Appeal? Beder sees potential for the National Research Council to address a growing national need: to make people understand the ever-growing connections between math and all the growth areas in science and business and to make best use of the power of modern mathematics and its applications. As one point of evidence, she notes that the financial engineering course she currently teaches at Stanford cuts across five different departments. Full Article

May 15, 2012: “Why JPMorgan’s Risk Management Failed,” Suzanne McGee, The Fiscal Times Treat financial innovation with skepticism and don’t try to game the models. That, Beder says, may be impossible. Teaching a graduate-level course in financial engineering at Stanford, she introduces her students to VaR, telling them what the rules and what the incentives are. Within minutes, she says, they are gaming the model for all it’s worth. She suggests it’s like telling a driver that the speed limit is 55 miles per hour, but there’s a reward for arriving at a destination quickly. “Then tell them that they won’t be ticketed unless they are driving at more than 65 – really, what do you think is going to happen?” Over the years, as VaR has become more accepted among regulators and within boardrooms of major financial institutions, Beder has seen it become more uncommon for senior managers to ask probing questions about what might go wrong – even after the events of 2008 demonstrated all too clearly that “Black Swan” events were the ones that had the power to devastate an entire financial system. When Beder presents a business plan to a student, a colleague or a client, “they’ll pick it to bits in seconds,” she says. In contrast, present a risk report to a board committee and the response likely is going to be limited to a polite “thank you.” “I’m astounded at the number of times I walk into a boardroom (at a company) where there has been a loss, and there is a misconception that it is too complicated for the directors to understand,” Beder laments.

March 30, 2012 Tanya Beder speaks at the 3rd Stanford Conference in Quantitative Finance OTC fixed income markets, presently the subject of intense scrutiny by regulators, academics, and the private sector, will be the theme of the symposium on the first day of the conference. The symposium, “Evolution of Fixed Income Markets through Transparency, Quantitative Finance and Technology,” will gather experts from both industry and academia for a forensic examination of the corporate bond and credit default swap markets, culminating in a panel discussion about the central role of quantitative finance and technology in their likely evolution. Other key themes of this symposium will include the broader implications of increased information dissemination in fixed income markets, a widely anticipated development in 2012 which has been bolstered by a strong regulatory impetus.

Speakers and panelists will include: Tanya Beder, SBCC Group Peter Cotton and Jim Toffey, Benchmark Solutions Darrell Duffie, Stanford University Tom Eady, US Securities & Exchange Commission Chris Golden, European Bond Commission

March 11, 2012 Occupy protesters greet General Electric CEO Immelt at Stanford dinner By Mark Calvey, San Francisco Business Times As part of that panel, Tanya Beder, chairman and CEO of Wall Street advisory firm SBCC Group, said the next generation of securitization will shift the risks governments took on during the financial crisis into the hands of investors better able to manage that risk.

March 9, 2012 Tanya Beder speaks at Stanford Institute for Economic Policy Research (SIEPR) Conference as a panelist on Financial Innovation and the Economic Crisis Steve Kohlhagen, SIEPR Advisory Board member moderated the discussion on Financial Innovation and the Economic Crisis. He is joined by Myron Scholes, the Frank E. Buck Professor of Finance, Emeritus, at the Stanford Graduate School of Business; Nobel Laureate in Economic Sciences; and co-originator of the Black-Scholes options pricing mode; Tanya Beder, Chairman & CEO of SBCC Group Inc. and Jeremy Bulow the Richard Stepp Professor of Economics at Stanford University. Youtube video of Tanya Beder participating in the panel:

May 9, 2011 Pulling the veil on the veil pullers By Kate Benner "If we don't get at the root of ongoing problems, they become entrenched as players vanish," says Beder. "Then you get the pro-cyclicality problem that we saw during the financial crisis. Everyone was doing the same thing, but no one was doing the right thing."

April 21, 2011, University Endowments Build Better Risk Management Practices, by Frances Denmark “Risk has changed significantly at endowments,” says Tanya Beder, founder and chairman of advisory firm SBCC Group in New York, where she heads the global strategy, risk, derivatives and asset management practices. “The aftermath has been so painful, there’s a sea change in how people are approaching risk management.”

February 14, 2011 Have Women Been Successful in the Male-Driven Hedge Fund Industry? Guest Article The question is no longer if women have been successful in a particular industry, but to what degree. Women success stories abound in all manner of commercial enterprises, especially in the financial services industry. However, the Hedge Fund sector of financial services has at times appeared to be the last bastion of male domination to be overcome. A recently published report seeks to shed light on this very topic. The Hedge Fund Journal, in association with PricewaterhouseCoopers, has produced a report entitled, “50 Leading Women in Hedge Funds.” In its first sentence, the author admits, “In an industry that celebrates the accomplishments of alpha males, it is often overlooked how many successful women are working in key roles in hedge funds. But despite estimates that women manage only 3% of the $1.5 trillion invested in hedge funds, a growing number of entrepreneurial, innovative and accomplished women now work in a variety of roles with funds, service providers and investors.” ….The report singles out fifty professional women that have achieved success as responsible

leaders in this slice of the financial services industry. Here are few from the top of the list: …Tanya Beder – Founder and CEO, SBCC Group – New York: With over 25 years of market experience, Ms. Beder founded SBCC Group in 1987. In 2004, she was recruited to establish Tribeca Global as its CEO and manage seed capital of $2.5 billion. At the time, she was one of a handful of women successfully managing a multi-billion dollar hedge fund. She returned to SBCC in 2006.

October 15, 2010 Tanya Beder speaks at New York University’s Leonard N. Stern School of Business on Derivatives and Proprietary Trading in the New Regulatory Regime:

http://iafe.org/html/documents/CMIB_IAFE_Paper.pdf Sept. 2010 IAFE Survey in cooperation with SunGard Adaptiv AFTER THE CRISIS: Re-engineering Risk Management? Thoughts for market experts including senior fellows and members of the board of directors of International Association of Financial Engineers (IAFE) In general our commentators were in favour of specific, well thought out technical improvements. For example, most of our risk panel supported moving standardized OTC transactions towards central clearing parties (CCPs) even though doubting that it would be a panacea. Some of our commentators noted that complexity was always conditional on the ability of our systems and processes to handle it, and that too often, different parts of the

system had not developed at the same speed as the front office, and that management ultimately had to take responsibility. For example, Tanya Beder noted: “The infrastructure, supervisory oversight and governance within firms lagged the market (without excuse on the part of firms themselves, regulators should be allowed some lag due to staffing and resource constraints). In my opinion it is the responsibility of senior management and boards to ensure that firms engage in activities that are in accord with their abilities, capabilities and infrastructure.” [Beder]

July 9, 2010, Risk of a 'Raining Decade,' for Markets: SBCC Global Chairman, by Gennine Kelly http://www.cnbc.com/id/38169374/Risk_of_a_Raining_Decade_for_Markets_SBCC_Global_Chairman

Risk of a 'Raining Decade,' for Markets: SBCC Global Chairman By Gennine Kelly Corporations are being "prudent" and holding onto historic levels of cash for good reason—to buy "insurance against further crisis," Chairman of the consulting firm SBCC Group Tanya Beder told CNBC today… Beder thinks this could be a "raining decade," with the market in an "extended sideways up and down period." Take the big downturn in the early 70's: the period between 1972 and 1982 "started and finished in the same place," she said.

Feb 5, 2010, Top 50 Women in hedge funds, by William Hutchings http://www.efinancialnews.com/story/2010-03-05/top-50-women-in-hedge-funds-1 A new list revealing the 50 most important women in the hedge fund industry has been published, just three months after research showed female hedge fund managers have performed substantially better than men.

Jan 25, 2010, The smoldering hedge fund, by Katie Benner http://money.cnn.com/2010/01/22/news/companies/plainfield_holmes_long.fortune/index.htm The smoldering hedge fund By Kate Benner The period of 2005--08 may go down in history as the easiest in which to raise money in America. If you had the words "hedge fund" anywhere in your prospectus, it seemed, investors would fall over themselves to give you great wads of cash. It's no surprise that investors handed Plainfield $1 billion within months of its founding in May 2005… Little was left for investors or borrowers -- by the end of 2008, 93% of Plainfield's assets were illiquid -- and Plainfield was compelled to prevent investors from leaving. For his part, Holmes was forced to endure the agony of being unable to invest during the big recession opportunity he had long awaited. Plenty of hedge funds "gated" investors in the panic of 2008. But few continued charging the sorts of fees Plainfield is imposing. "A lot of managers have had total forbearance on fees while liquidating or while they have gates up," says Tanya Beder, whose firm advises institutional investors. Charging fees, she says, "isn't going to give investors a warm, fuzzy feeling."

On Dodd’s Mark, Get Set, Go – Wall Street Reform Process Really Begins By Rich Blake August 3, 2010

I posed the too-big-to-fail question to Tanya Beder, Chairman of SBCC Group, who once ran a hedge fund group, Tribeca, for Citigroup:

“What can be done to end too big to fail? This is a sticky wicket given that “too big” could be a very small firm, so context is critical. Frankly, with what the world has been through with the credit crisis, it is conceivable that a small failure could be “read” to have a larger than life meaning. Given the jitters, such an action by a key regulator could be construed as meaning something quite different when traders and the man on the street read the tea leaves—rumors could swirl and a chain reaction could result. After September 11th, many New Yorkers were terrified of loud noises; the post-traumatic stress syndrome of veterans is well-documented. The markets and their participants (including the man on the street) have been through serious trauma. As for what should be done? … what will be done? I feel strongly that the answer is in

retooling the accountability and knowledge of senior management and boardrooms plus giving regulators better tools. I’m definitely a believer in functional oversight rather than oversight by “type” of firm. Further, I don’t think it’s possible to put the genie back in the bottle, i.e. to limit the activities of financial firms relative to their competitors around the world. The financial sector is too important to the central nervous system of the economy.”

Prospects for multi-strategy hedge funds brighten Harriet Agnew

02 Aug 2010

On fees, multi-strategy firms have long faced the issue of what remuneration model to adopt. Some, such as Och-Ziff Capital Management Group, have one profit and loss account for the whole fund. Tanya Beder, chairman of investment consulting firm SBCC Group, said she thought this was the best model. She said: “If you do not have everyone feeding into one P&L, then you have to deal with the netting risk.” Other funds pay traders a percentage of their individual profits, rather than those of the overall fund. The danger here is that traders are allocated more money when they perform well. Beder said: “You cannot afford to have all your eggs in one manager or strategy because no trading strategy works in all markets or lasts for ever. Moreover, star performers come with a whole different set of management challenges.”... Beder added: “In the multi-strategy model there is more flexibility in moving capital around. Multi-strategy funds should have an ability to shine on a relative basis if they’re disciplined about allocating capital.”

Wall Street Eyes Moving Trading to Switzerland

Banks, Concerned Over Proposed Derivatives Restrictions, Weigh Moving Trading Operations Offshore

May 25, 2010 Rich Blake

“Financial reform passed in the Senate last week; a companion version of the bill already passed in the House in December…Among the most controversial Senate provisions is one that would force Wall Street banks …to cordon off certain derivatives, or “swaps,” businesses into separate subsidiaries…’Who wants to be remembered as the politician who knocked the legs out from under the global financial engine?’ countered industry member Tanya Beder, CEO of

SBCC Group, a trading risk management firm in New York.

Could a piece of Wall Street move to Bermuda?

June 7, 2010

The US Congress is working through new financial regulation legislation that could put restrictions on banks' trading activities. Tanya Beder, Chief Executive of SBCC Group, a trading risk management firm in New York, and a former trading executive at Citigroup, told ABC: "If the reform is too onerous, banks will either move their trading businesses offshore or invent new ways of circumventing the rules. The genie is out of the bottle."

Geithner Tempts Investors With Loans, 25% Returns

By James Sterngold, March 24th

The U.S. government’s plan to rid banks of toxic assets may attract investors with financing that helps generate returns as high as 25 percent, fund managers and analysts said. “This makes the U.S. government a hedge-fund manager,” said Tanya Styblo Beder, chairman of risk-management adviser SBCC Group in New York. “Investors in hedge funds do so voluntarily, after performing due diligence on the skills of the manager. But taxpayers aren’t doing this voluntarily.” “The logjam in the markets is phenomenal,” she said. “The illiquidity is breathtaking and this is a non-temporary phenomenon. Big measures are necessary, but you have to look at all these issues. Hasty implementation may have huge unintended consequences.” Beder said she also worried about a program that had private investors putting up capital with the government because it left no one clearly in charge.

To TALF, or not to TALF

The long-awaited Federal Reserve program aimed at thawing the frozen credit markets got underway this week.

Will it work?

By David Ellis, March 18, 2009

The Fed is hoping that TALF will push banks and other finance companies to keep making new loans…Many believe that the participation of private investors, such as hedge funds, private equity firms and mutual funds, could very well determine the success or failure of the program. There has been widespread speculation that investor interest may be relatively robust, but there are stumbling blocks…Tanya Beder, chairman of advisory firm SBCC Group, which focuses on the financial services industry, said there is still a lack of certainty about the value of the assets backing the securities that buyers are expected to purchase.

"There is a terrific degree of uncertainty surrounding cash flows and what instruments are worth right now," said Beder.

Top officials have also warned in recent months that there is a risk that Fed could accept securities that have been overvalued.

BUSTED

by Edmund L. Andrews

Unfortunately, and contrary to what investors had come to believe, shifting the risk from one spot to another didn’t mean it had disappeared. “It’s the law of conservation of misery,” said Tanya Beder, head of SBCC Group, a consulting firm that specializes in securitization. “You can move the misery around, but it never goes away.”

Congress To Examine Mark-to-Market Modification on Thursday

The House Financial Services Committee will hold a much-anticipated hearing on Thursday that examines mark to-market accounting. Speakers will include:

James Kroeker, acting chief accountant for the Securities and Exchange Commission

Robert Herz, chairman of the Financial Accounting Standards Board

Kevin Bailey, deputy comptroller for regulatory policy in the Office of the Comptroller of the Currency

Tanya Beder, chairman of SBCC Group;

Accounting rule a 'hot potato' in Congress

Colin Barr, March 12, 2009

Regulators should expand the toolbox banks can use to place a value on hard-to-sell assets, market experts told a congressional panel Thursday. But some legislators said they want more sweeping action now.... Critics, including two prominent former regulators who testified Thursday, say the fair value rules have worsened the financial crisis by forcing companies to recognize steep paper losses on bonds that in many cases are still paying interest and principal. Beder is among those who believe the rules must be made more robust.

SEC Accountant Testifies Thu To House Panel On Mark-To-Market

By Sarah N. Lynch

WASHINGTON (Dow Jones)— “We cannot allow for fantasy accounting that wishes away bad assets by merely concealing them. As a result, we will seek at this hearing to engage in a constructive, thoughtful conversation with a diverse range of viewpoints aimed at identifying fair-minded, incremental, and achievable fixes to this problem." … Following testimony from the SEC, OCC and FASB, lawmakers will also hear from industry members including Tanya Beder, Chairman, SBCC Group

More writedowns ahead?

Apr. 7 - Risk management group SBCC says writedowns at banks from the subprime crisis could total $500 billion dollars, double what has already been reported. Tanya Beder, speaking at the 2008 Reuters Hedge Fund and Private Equity Summit in New York on Monday, says the fallout from the mortgage meltdown may become more clear after September when more subprime mortgages will reset to higher interest rates.

Speaker:

Tanya Beder

Chairman, SBCC Group

“Perfect Storms” – Beautiful & True Lies In Risk Management

Tanya Beder, a celebrity derivatives and risk professional, once observed that financial markets represent “the Great Risk Hunt”. This is a party game that many can play. There is the hunt where traders, corporations and investors comb markets in search of that elusive treasure, the next lucrative profit opportunity. Then there is the hunt for risk, where risk managers identify and measure the risks of trading, trying to profit from the opportunity along the way. Finally, there is the hunt for knowledge. This particular quest usually follows some unexpected and (inevitably) large loss, as analysts examine the entrails to understand “what happened”.

DealZone April 7th, 2008

Hedge funds are ready to set records this year, but not necessarily the good kind. The bubble has popped and there is going to be a lot of pain. There will be a massive reassessment of where money should go. Many investors including Tanya Beder, Chairman of SBCC Group, expect the $1.8 trillion industry’s estimated 10,000 funds to be winnowed down by a few thousand in a few years.

Serious Play: How the World's Best Companies Simulate to Innovate

By Michael Schrage

Beder and other sophisticated modelers warn in particular against letting models become a substitution for the marketplace. The result is a “mark to model” pathology: the firm believes that as long as the model is behaving according to its Dealers thing they are marking their positions to market when all they are really doing is marking them to the assumptions built into the model. “At least six disparate models are used to price many common derivatives”. Beder has observed. “Given the same raw data input a wide variance of results exists when mark-to-market is calculated.”

The Monster That Ate Wall Street How 'credit default swaps'—an insurance against bad loans—turned from a smart bet into a killer. Matthew Philips | NEWSWEEK Published Sep 27, 2008 From the magazine issue dated Oct 6, 2008 The Tale of the Beast Credit default swaps have evolved-and-become more toxic-since their creation. 1994 -1997: First CDS deals done by JP Morgan, Swiss Bank Corp., and Bankers Trust. 1999: Commercial Banks and insurance companies are now able to trade CDS contracts. 2003: First credit derivative index is created, standardizing a major aspect of the market.

2004 - 2008: CDS deals used to hedge mortgage-backed securities; market peaks at $62 trillion. 2008: AIG nears default on $14 billion of CDS policies and is bailed out by the government. Source; SBCC Group

HEARD ON THE STREET SEPTEMBER 22, 2008

Hedge Funds May Endure Frayed Ties

By LIAM DENNING

The strange relationship between hedge funds and the banks that provide prime-broker services is taking another twist… Relationships may become warier. Prime brokers will think twice about lending against some complex securities. Tanya Beder, head of risk-advisory firm SBCC Group, sees a return, at least short term, to a more "plain vanilla" business.

INVESTING August 14, 2008,

The Future of Investing: A 2020 Vision

What will the world of stocks, bonds, and funds look like in the next decade? BusinessWeek asked experts for their predictions

by Ricky McRoskey

With the recent upheavals in equity and fixed income markets, the financial industry is left to ponder: What change is next? What will the financial world look like in 2020? … BusinessWeek asked financial professionals and academics their thoughts on what the financial landscape will look like in the year 2020. The experts foresee a world where "A lot of the frameworks and walls built because of the old financial world we grew up in will come down," says Tanya Styblo Beder, chairman of the SBCC Group and a member of the board of directors at the International Association of Financial Engineers….There will be greater trading transparency…but actively managed funds won't disappear because there will always be a need for packaged financial products, says SBCC's Beder, since "a lot of people can't access the full range of products in a

market."

Florida Hires Hedge Fund Expert to Help in Probe

Mon Feb 25, 2008 5:28pm EST

BOSTON, Feb 25 (Reuters) - Florida has hired two experts, including one with a long track record in hedge funds, to examine how a local government investment pool was nearly wiped out late last year, state legislators said on Monday.

Tanya Styblo Beder... will investigate the Florida Local Government Investment Pool to make sure the fund is not vulnerable to another run, said Marco Rubio, speaker of Florida's House of Representatives.

Late last year, the fund lost more than $10 billion as news circulated that it owned risky securities that had been downgraded in the wake of losses on mortgage market securities and amid worries about broader housing market losses.

Florida House picks 2 to evaluate pool

Posted: February 25, 2008, 3:57 PM EST

The Florida House of Representatives hired risk management consultant SBCC Group and Tew Cardenas, a law firm with expertise in financial transactions, to evaluate the Florida State Board of Administration’s Local Government Investment Pool, said Jill Chamberlin, communications director of Florida House Speaker Marco Rubio. State Rep. Carl Domino, a longtime investment manager, will lead the House review, which is designed to determine if new legislation “is needed to support best investment practices,” according to a statement from Mr. Rubio.

Equity Analysts Facing New Quant Challenge

May 31, 2007- Dane Hamilton

NEW YORK (Reuters) - …At an increasing number of Wall Street investment banks, hedge funds and elsewhere, computers are churning out investment analyses culled from enormous pools of data.

"Given the same set of factors, it will always produce the same result," said quant industry veteran Tanya Beder of quantitative analysis. "Its signals are pure and systematic."

Beder, who built the quant trading division of top-performing hedge fund Caxton Associates LLC and was chief executive of Citigroup's Tribeca Global Management in 2006, estimates that quantitative analysis and trading "drives one-third of the market" on any given day....

Hedge funds, which are often early adopters of new investment methods, are spurring the development of quantitative strategies, which trade using mathematical, or algorithmic, models. Many such strategies were spawned at the internal trading desks at banks, notably Goldman Sachs.

February 12, 2008

...a new fund-of-funds manager Lasair Capital will invest in hedge funds, infrastructure and timber securities for institutional investors…GE Asset Management reportedly is backing Lasair Capital. GE Asset’s former CEO, John Myers, is advising the new firm, along with Tanya Styblo Beder, Chairman of SBCC...

Excerpts From “One-on-One” Featured Interview:

FEN: How do you define risk?

Beder: Risk is what a rational investor should seek at the right price. Good risk selection follows a few tenets. The first tenet is that you must properly define the risk in order to limit the probability of surprises. The second is that you size it properly. The third is that you are compensated for it properly. Some people think that risk should be eliminated. I disagree. Risk

should not be hunted down and exterminated. Instead, an investor should take risks he or she can afford at the right price.

FEN: Are there particular events or controversies that changed the way you think about risk?

Beder: I have a lot of religion that one size doesn’t fit all. I spent 13 years of my life as a consultant, cleaning up financial train wrecks. These include what happened with the derivatives and structured securities losses at many Wall Street firms during the Fed rate hikes in 1994, working through the Orange County disaster, working through the downfall of the Asian currencies in 1997 and 1998, and the operational risk failures that have plagued many financial firms.

All of these events were quite different but they were all important in terms of learning about risk management. One key lesson is that managers should not feel they can sleep at night just because someone calculated some risk numbers. Understanding what the numbers do—and what the numbers do not do—is critical in avoiding surprises.

Blank Cheques and Balances Sep 28th 2006 | NEW YORK From The Economist Print Edition Lenders to hedge funds need to think harder about the risks

Both tasks are tricky. For one, hedge funds routinely use several prime brokers—and each broker sees only the securities he lends against. Hedge funds also increasingly invest in esoteric derivatives that are often illiquid and difficult to value. Moreover, the “quality” of collateral is not static. It deteriorates—and lending must be reduced—if, say, a trade or strategy is popular with other investors (a “crowded trade”); liquidating such trades in times of market stress is exceedingly difficult. This means, says Tanya Beder, an investment-management expert who resigned as the head of one of Citigroup's in-house hedge funds two weeks ago, that big prime brokers can benefit from “informational economies of scale”: they see more data and so can better discern market trends. Still, the sophisticated computer models that banks use to crunch data have limits; a model is only as good as the inputs it gets.

Banks Fumble At Operating Hedge Funds Eager Foray Turns Into Billions Lost, Marred Client Ties

By GREGORY ZUCKERMAN and JENNY STRASBURG

May 31, 2008; Page B1But on the heels of a run of recent embarrassments for banks that operate their own hedge funds, or buy stakes in funds, the foray is raising questions.”There's a luxury that exists for the funds to take concentrated risk because they don't usually have the same capital at stake as someone who starts a hedge fund," said. Tanya Beder, chairman of SBCC Group, who advises hedge funds…

BondsTied to Mortgages Have Hope

By LARRY LIGHT

May 10, 2008; Page B1Maybe there's away to thrive in the howling wasteland that is the home-loan market. Bonds backed by mortgages look like a buying opportunity, assuming a new spate of defaults doesn't send their prices tumbling again.

What this means is that mortgage bonds are still cheap, with many selling below face value -- and that investors, now less scared by them, no longer need large yield premiums as an enticement to buy."We seem to be headed back to the spreads we used to see," says Tanya Beder, who heads New York financial advisory firm SBCC Group.

HedgeFunds Mature From Risque to Respectable By Mark Gilbert

June 10, 2005 -- Now that they have passed the $1 trillion mark, hedge funds are ossifying. They are becoming boring. Dull. Respectable, even. “Institutions,while they accounted for only 20 percent of hedge fund investors in 2000, will represent 80 percent of the market in 2010,'' said Tanya Styblo-Beder, chief executive officer of New York-based Tribeca, “Institutional investors will want to see the scale and robustness and transparency and disclosure that they require.''