Category: policy

Poverty reduction and development: it's not either/or

A piece on the Guardian‘s Poverty Matters Blog today sets up one of the oddest, and most pointless, dichotomies I’ve seen in a discussion of development.  To summarize, the post by Rick Rowden argues that a focus on aid effectiveness and poverty reduction

perpetuates a bloated aid industry that doles out millions of dollars each year to legions of contractors and NGOs to carry out projects in dozens of poor countries.

What it does not do, apparently, is work toward any definition of development

In recent decades, earlier notions of development economics have been replaced with meeting the MDGs. But poverty reduction is not development. We seem to have suffered collective amnesia about the history of development, which used to be widely understood as industrialisation – in which poor countries undergo a transformative process out of primary agriculture and extractive industries into manufacturing and services industries with higher value-added over time.

First, this is an absurdly reductionist definition of development.  If Rowden wants to talk down to his readers about the history of development, he’d do well to note that his particular take fell out of currency in the late 1960s because IT DIDN’T WORK.  There is a reason modernization/big push theories fell out of favor (unless you are Jeff Sachs, and then you are forever reviving the corpse of the big push at the community level via the MVP.  Then again, Sachs doesn’t seem to read development history, either).  In short, the borrowing required for industrial ramp-ups almost never paid off with enough revenue to pay off the loans.  To understand why this happened is to understand the country-specific interplay of three key factors.  First, there were (and still are) structural issues in world trade that locked much of the developing world out of key markets.  Second, these policies failed because markets were dominated by large corporate entities operating with very small margins because of their huge economies of scale, basically undercutting any new competitors on price because they had the advantage of a huge head start provided by colonialism.  Third, massive corruption within countries drained the productive capital out of these loans, dooming the projects there were meant to fund.  Countries had to address either two or three of these factors, in varying ratios, at different times.  Modernization theories pushing industrialization had little to offer in addressing them.  This is why we eventually saw the rise of an attention to institutions and governance in development – not just at the level of the state, but also in markets and broader trade arenas.  It is also why so many countries in the Global South found themselves saddled with crushing debt at the end of the last century – many of those debts were the original loans and continued accumulation of interest tied to these failed policies.
The other issue is that industrialization requires resources (to make products) and consumption (to sell them).  At a time when our demand on the natural environment is already beginning to overshoot its capacity to serve our needs, asking countries to take on even more unsustainable activities is an absurdity that will end in failure.  There is nothing sustainable in this pathway – and if you look at the post, you will see that the entire argument is framed in an unlimited world, where the only constraint on development is growth:

If countries are unable to use the industrial policies they will need to transform their domestic industries, diversify their economies and build up their own tax bases over time, how will they ever get off the foreign aid bandwagon? Here the “poverty reduction” discourse is misleading; it neglects to ask how countries are supposed develop without industrialising.

Well, that isn’t totally true unless you take a very, very narrow reading of the poverty reduction discourse.  A lot of us are working in this space to imagine alternatives.  Indeed, there are community level projects that, while not elevating people to the standards of living seen in the Global North, have created sustainable, substantive changes in the quality of residents’ lives.  The examples are out there if people want to look.
Beyond all of this, though, is the larger issue – Rowden clearly has no idea what he is talking about when it comes to development when he dichotomizes poverty reduction and development.  Even if we saw economic growth as the be-all, end-all of development, there is a lot of work out there arguing that endemic poverty is a huge drag on economic growth and therefore has to be addressed as part of a growth package (see the OECD Observer here).  So even in a fairly reductionist view of development, you need poverty reduction . . . and I don’t know anyone who believes that growth adequately addresses poverty.  Not even at USAID.  Really.
So poverty reduction and development are not an either/or proposition, from any reasonable perspective on development.  Rowden’s piece would have been interesting . . . in 1960.  I have no idea what the point was in publishing it today.

Posted on by Ed 9

Development isn't impossible, just hard to understand

A few comments on the blog related to some earlier posts on a Grand Challenge for Development have gotten me thinking a bit about development (the concept and the project) and if it is achievable.  There are those who would argue it is not, that development is an ill-conceived idea that invokes pathways of change that are now closed due to the changing global political economy, and treats life in the advanced economies as the apotheosis of human existence toward which everyone else is (and should be) marching.  To the extent development is taken to mean this sort of change, I agree completely – development is unattainable and meaningless.  There are not enough resources on Earth to allow everyone to live the way we do in the advanced economies, so the idea of a march toward that standard of living as a goal is gone regardless of how one might feel about it morally/ethically/etc.
But that does not mean that change cannot happen, that things cannot improve in a manner that is appreciated by people living in particular places.  Certainly, a shift from a post-subsistence income of $1 a day to $5 a day is a huge change that, in many parts of the world, would enable very different standards of health, education and well-being.  Surely this is worth striving for – and certainly, the people with whom I have worked in Ghana and Malawi would take that kind of a change over no change at all – and they would much rather than kind of change, than endless, pride-killing aid dependence. There is no doubt that this sort of change can be attained in many, if not most places.  Indeed, it has been accomplished.  Further, there are places where life expectancy has risen dramatically, infant mortality has fallen, nutrition and education levels have improved, and by any qualitative measure the quality of life has improved as a direct result of aid interventions (often termed development, but this should only count as development if the changes are sustained after the aid ends).  The real question at hand is not if it can be done, but why the results of our aid/development efforts are so erratic.
You see, for every case of improved life expectancy, there is the falling expectancies in Southern Africa.  For every case of improved nutrition and food availability, there are cases of increasing malnutrition and food insecurity (such that in sub-Saharan Africa, the balance has tipped toward less food availability per capita than two decades ago), and so on.  What works in one place often fails in another.  And the fact is that we don’t understand why this is in a systematic way.  I am a geographer and an anthropologist, so I am quite sympathetic to the argument that the local specificity of culture and society have a lot to do with the efficacy of particular interventions, and therefore explain a lot of the variability we see in project outcomes.  However, “local specificity” isn’t an answer, it is a blanket explanation that isn’t actionable in a specific way.  We persist in this answer because it pushes development (and aid) failure into the realm of the qualitative, the idiosyncratic.  And this attitude absolves us, the development community, from blame when things don’t work out.  Your project failed? Ah, well, who could have known that local land tenure rules would prevent the successful adoption of tree crops by women?  Subtly, we blame the victims with this mentality.
What it comes down to, I think, is a need to admit that we have at best a shaky idea of what works because in many areas (both geographic and technical) we really don’t understand what it is we are trying to transform when we engage in aid and development work.  We are better in some areas (health) because, frankly, they do a better job of gathering data and analyzing it than we do in, say, rural development (hey, don’t take my word for it – read some Robert Chambers, for heaven’s sake!).  But, in the end, we are driven by our myths about how markets and globalization work, how development/aid is linked to change, and how the problems we claim to address through development and aid came about in the first place.  This argument is the heart of my book (Amazon link here) – and I spend the first half using the story of two villages in Ghana to lay out how our assumptions about the world and how it works are mostly wrong, the next quarter explaining why this is a major problem for everything from economics to the environment, and the last quarter thinking about how to change things.
My take is but one take – and a partial one at that.  We need more people to think about our assumptions when we identify development challenges, design programs, and implement projects.  We need to replace assumptions with evidence.  And we need to be a lot more humble about our assumptions AND our evidence – so we stay open to new ideas and evidence as they inevitably flow in.

Posted on by Ed 3

Oh, Ghana!

For any of you who might have spent time in Ghana, you’ve likely heard that shout: “Oh, Ghana!”  It is a good-natured expression of frustration with the everyday annoyances that make life what it is in Ghana.  Power cuts out in the middle of a World Cup match? “Oh, Ghana!”  Traffic completely stops in Cape Coast because the local herd of cattle have gotten into the road? “Oh, Ghana!”  Anyway, you get it.
Well, today’s “Oh, Ghana!” moment comes courtesy of Ghanaian President John Atta Mills, who has taken a particularly depressing stance on the turmoil in Ghana’s neighbor, Cote d’Ivoire:

“Ghana is not taking sides,” he said, pointing out that “We have about one million Ghanaians living in Ivory Coast who could be victims of any military intervention.”

Super, the head of state of the most legitimate democracy in West Africa, and arguably all of sub-Saharan Africa, has decided not to cash in any of that legitimacy to help resolve a fairly clear electoral situation right next door.  Of course, this ignores the fact that there are many millions more Ghanaians living along the border with Cote d’Ivoire that could be affected if things go badly, or that cross-border flows of Ivorians trying to escape conflict could pour into Ghana, which lacks the capacity to adequately address their needs.  Further, Mills’ response to the crisis is . . . prayer.  Prayer is fine, but it is no substitute for working in this world for a solution.  No, Mills’ stance is a depressing bit of hedging one’s bets.
The good news, I suppose, is that there is nothing inherently Ghanaian about this attitude toward the situation in Cote d’Ivoire.  Nana Akufo-Addo, the New Patriot Party’s (NPP) presidential candidate in 2008 (and likely in 2012), issued a statement earlier this week that more or less addressed the absurdity of Mills’ position.

“Much as most of us Ghanaians believe in the efficacy of prayer, prayer cannot be a replacement of or substitute for an active policy of Ghanaian diplomacy and engagement. It is said that heaven helps those who help themselves.”

Amen.  Now go, Ghana.  Do something now.

Posted on by Ed 0

Lemonade from low earth orbit lemons

Right, so George Clooney is part of an effort to use satellite imagery to cast a light on any atrocities that might take shape as the Sudan referendum goes forward.  In short, this project aims to use hig-res commercial satellite imagery, gathered on a pretty regular basis, to document evidence of genocidal or other criminal behavior.  The idea is, as they put it, to create a form of “antigenocide paparazzi” that will bring unwanted attention to atrocities.  As Clooney argues:

“This is as if this were 1943 and we had a camera inside Auschwitz and we said, ‘O.K., if you guys don’t want to do anything about it, that’s one thing,’” Clooney says. “But you can’t say you did not know.”

This is genius marketing, even if you dislike the idea (those of us with good ideas really do need to take marketing more seriously).  And a lot of people dislike the idea.  Blogger Laurenist has a critique under the hilarious title “In Space, no one can hear you say “WTF”?” (genius marketing, people).  A lot of this critique is focused on the fact that the imagery will probably not bring about the sorts of accountability necessary to actually get people to stop unwanted behaviors, at least in part because the imagery is fairly low-res.  Indeed, it is – actually lower-res than the article about the story quotes – 50 centimeter imagery is not 50 square centimeters, but 50 centimeters a side (I work with this stuff).  So it is hard to even see people in these images, unless it is at a time of day where you can pick up their shadows.  It is also focused on the fact that “just knowing” about a problem isn’t good enough to spur action – after all, it is now well documented that the international community was well aware of what was going on in Rwanda right before and during the genocide, and did nothing.  Fuzzy imagery certainly won’t change that.
I agree with this assessment.  However, there is a way to make lemonade out of this particular batch of lemons, because these images could be retasked for something much more useful.  One of the likely points of conflict post-referendum is along the corridors through which various groups move their livestock in the course seasonal migrations for food and water (if you want to drop a big word for it, say “transhumance”).  There are two things this sort of imagery can do for us – it can tell us about the biophysical situation in those corridors – are they still able to support this migration, are they ecologically unbroken or fragmented, are there barriers to movement?  Second, it can tell us how many people and animals are using these corridors, which we can use to measure local carrying capacity, and estimate the challenges that might emerge if these corridors are closed or otherwise challenged.  This would allow for effective humanitarian intervention in areas where these pastoral groups (who are typically left behind by aid and development, and hated by the state, because they won’t stay put and like crossing borders).  Hell, if they are going to drop big dollars on the images, we may as well use them for something useful and actionable.
George, you interested?  I can help set this up . . .

Posted on by Ed 2

Birthers, Cote d'Ivoire and the abandonment of logic

The people looking for a birther conspiracy behind our (very minimal) support for the rightful winner of a democratic election in Cote d’Ivoire are more or less totally unhinged at this point – and they are making insane leaps of logic that are internally contradictory.  They are also issuing astonishing ad hominem attacks (for example, here).
So, to review this logic.  The very minimal support from the United States for Outtara in Cote d’Ivoire is an indication that Obama is helping one of his Muslim buddies take over a good Christian nation.  However, our rather engaged and substantive support for the Sudanese referendum that will almost certainly lead to a new African country next week – and a country that will be Christian and animist dominated, no less, doesn’t count for anything.
Wow.
So apparently our minimal support for the rule of law in Cote d’Ivoire is not a problem because the guy we’d have to support is Muslim.  Because of that, we can forget that Gbagbo clearly stole the election, or that he has mobilized issues of citizenship to disenfranchise a large percentage of the Ivorian population.  Good news, Christian dictators – you are free to toss democracy, just keep the Muslims out.  Does anyone hear the echoes of US Cold War policy re: communism?  Anyone?
One of my favorite twitterers, @bill_westerly, is right: “some enemy: fight wit honner und sword uf reason. some enemy: immune to reason, just kick in duh goolies und laff.”

Posted on by Ed 3

Is the Aid/Development divide the Grand Challenge for Development?

A few conversations on the blogs over the past two weeks have me thinking about the divide between aid/relief work and development – one of those minor issues I am supposed to be addressing in my current job.  I am nothing if not ambitious.  However, as folks have tried to clarify the difference between aid and development, I’ve become more and more uncomfortable because I really think these two areas need more blending, not more distinction.
And so now I am wondering if, in fact, the gap between aid and development is part of the reason so many “development” projects don’t work out.  I put development in quotes there for a reason – most of these projects never actually get to the development phase.  Take my ongoing rants about the Millennium Village Project.  Here is an ambitious program of interventions that is meant to be a development project.  However, at this point it is really an aid project – at least by the definitions I am seeing circulate.  The MVP is still completely dependent on external interventions and expertise for its outcomes.  Where it seems to me the MVP falls down is in the transition from the aid phase to the development phase, when these changes in people’s lives become self-sustaining, and engender new changes that do not require any sort of external intervention.  In short, the MVP seems to assume that with enough aid over enough time, change becomes self-sustaining and the processes necessary to bring about well-being spontaneously emerge.  This is what I like to call the “then a miracle happens” moment.  As in:
Dump money, aid and material into a place over a series of years –> then a miracle happens –> change is self-sustaining
The MVP is hardly the only project guilty of this – hell, this thinking is endemic to development.  We can back up to Rostow’s Stages of Growth in the 1950s (at least) and find the exact same fallacy.  Big push/modernization theories, the Washington Consensus, basically every program founded on the core idea that economic growth drives everything else, they all suffer from this fallacy.  This, ladies and gentlemen, is your grand challenge for development – the “big question” that could really change how we do what we do.  We need to articulate how our initial interventions, our “aid”, is/can be transformed/built upon/leveraged/instrumentalized/whatever to result in the self-sustaining changes we see as development.

Posted on by Ed 11

On Aid and Development

An interesting post at Blood and Milk yesterday led a commenter to note that we shouldn’t use the terms “international development” and “aid” interchangeably – that the “real big story about development is exactly that it is NOT all about aid, but about domestic elites establishing pro-growth rules.”
For me, this raises two issues – the first is about the relationship between aid and development, and the second about the character of development itself.  Alanna Shaikh, who writes the Blood and Milk blog, added a new post today that addressed the first.  In this post, Shaikh argues “You can, and do, get development without aid. I’m pretty sure you don’t get it without economic growth.”  Well, sort of.  I currently work in one of the world’s largest development/aid organizations.  I am the climate change coordinator for the Bureau most directly responsible for our aid activities (as opposed to our development activities).  This puts me in something of an odd position – I am a development/environment person tasked with thinking and program-building for the long-term in an aid organization that is often reactive in its programming and its mandate.  Why, then, did I take this position?  Because of the need to better connect aid to development (and vice versa).  Right now, aid and development exist in very different worlds – even in the same building, there is little communication or coordination between these two missions.  This galls people on both sides of the divide, from leadership down the line.  The vision of an agency like mine is that aid should transition to development, ideally seamlessly (though at this point we would take any sort of transition).  Adaptation to climate change is one area where such transitions can be created out of existing programs – our aid teams work on hydrometeorological disaster risk reduction (DRR), and our development side works on adaptation to climate change.  These are very similar areas of work, differentiated largely by timeframe.  One of my jobs over the next few years will be to better connect our hydromet DRR and adaptation programming to build one connection between aid and development – a thread that we might use to close other aid/development gulfs (such as in food aid and agricultural development).
Aid may not be the same thing as development, but it should not be seen completely separately from development – my Bureau sees its constituency as that component of the population that is largely left behind by economic growth programming.  Nobody debates that a significant percentage of the population slips through the cracks of economic development programming – our job is to ensure that those who slip through the cracks do not remain there, but have an opportunity to recover and participate in society, politics and the economy.  So, when I hear someone argue that there can be development without aid, I strongly disagree – at least at the national scale (communities are a different issue).  At the national scale, you cannot have socially or environmentally sustainable development that abandons a significant portion of society to its fate.  Aid is critical to development – or it should be, if only we could better coordinate aid and development efforts.
Second, I am deeply concerned by the continued connection of development to economic growth.  The linkages between human well-being and economic growth are shaky at best (most correlations can be readily challenged and dismantled) – largely because development, globalization and growth do not really work the way people seem to think they do (my book is an exploration of this point).  Further, economic growth cannot be eternal.  3% growth per year for everyone forever is simply beyond the physical capacity of the planet.  I’m pretty sure that development is going to have to detach itself from economic growth (ironically, this would mostly entail simply acknowledging the reality of what’s been happening around the world for the last 60 years) if it is ever to accomplish its end goal – the improvement of the human condition in this world.
Finally, a thought on the two metastories of development that Shaikh raises at the end of her post.  I agree that development is neither all success or all failure – it plays out differently in different places, and we have better understandings of why in some areas (health, for example) than in others (transportation development, for example).  I would argue that this is a symptom of a larger problem – we really don’t understand what is happening in the Global South most of the time, and as a result we are often measuring and analyzing the wrong things when we do project scoping or evaluation work.  Our assumptions about how the world works shape the way we frame our questions about the world, and the data we gather to answer those questions.  The problem, simply put, is that we are often asking the wrong question.  Sure, every once in a while our assumptions align with events on the ground, and a project works.  But the rest of the time, our assumptions do not align with reality, and we run into difficulty understanding what is happening in particular places, and why particular projects fail.  The end result?  A seeming random set of project outcomes, where things work in one place but not another for reasons that seem hard to discern.  There are more fundamental metanarratives of development out there than success or failure – they are narratives about how globalization works and how development works that shape our very ability to assess success or failure.  And those narratives actually misinform many of our best efforts.

Posted on by Ed 1

Where accountability goes to die

The subtle airbrushing of market manipulation out of the public consciousness continues apace.  Despite clear evidence from IFPRI that market manipulation is creating the conditions of uncertainty that are driving up global food prices, nobody seems to want to address this in a forceful manner – and heaven forbid you raise this in any food security discussions in a development agency.  People will blindly argue that there is no evidence (except, of course, there is), and then when confronted with the IFPRI study will make absurd arguments like the uncertainty is creating the appearance of manipulation because, you know, IFPRI wouldn’t bother to make sure they had the causality going in the right direction before they published.*  So, we will just keep plugging away at the issues of supply to address global food issues, because why address the only factor that IFPRI could identify as having a causal effect on the rising food prices in 2008?
And now we see the same blindness spreading into our discussions of the financial markets.  In the January issue of Wired Felix Salmon and Jon Stokes return to the Flash Crash, the sudden near-600 point drop in the Dow that occurred back in May.  The regulatory agencies assigned to policing market manipulation more or less abdicated their responsibilities and absolved everyone of blame in their report.  This was absurd, and doesn’t hold up to the slightest bit of logic.  Now Wired is on board, running a “blame the algorithms” story that uses the flash crash as exhibit A.  They argue that Waddell and Reed (the managers of the mutual fund that made the trade)

used an algorithm to hedge its stock market position.  The trade was executed in just 20 minutes – an extremely aggressive time frame, which triggered a market plunge as other algorithms reacted, first to the sale and then to one another’s behavior

Sure – this is exactly how it played out.  But the issue here is not that the algorithms themselves were to blame.  Someone had the PROGRAM THE ALGORITHM FOR THE FIRST TRADE.  The algorithm did not decide to dump all of those futures contracts in 20 minutes.  The person who designed the algorithm (or, more likely, his/her employer) made that decision.  Once set in motion, I have no doubt that this trade cascaded through other, more conventionally designed algorithms, triggering all sorts of “irrational” behavior as they tried to adjust to the rapidly-changing market conditions.  I also have no doubt that whoever set up the original algorithm had some idea that this is exactly the sort of chaos that would ensure from their insane trade.  Everyone is now focused on events after the initial trade, and how trading algorithms might need more controls or oversight.  I think that is a reasonable position, but it does nothing to address the behavior of individuals willing to initiate market chaos by setting up insane trades.
Incidentally, nobody in their right mind would set up an insane trade for no reason.  I wonder if the SEC spent any time looking into who was short on the Dow that day and made out big (including people who made out huge before a bunch of trades later in the crash were invalidated), and then examined the connections those folks might have had to Waddell and Reed.  Then again, it seems few folks in major development agencies want to seriously examine market manipulation and its impact on food security.
At what point does willful obliviousness turn into criminal negligence?
*these were actual arguments raised when a colleague of mine attempted to address the issue of market manipulation at a meeting in one of our major development agencies.  Really.  How the hell, exactly, does uncertainty create the appearance of manipulation?

Posted on by Ed 0

Too little, too late . . .

The US has finally imposed sanctions on the Gbagbo government in Ivory Coast.  This won’t accomplish anything.  Take the response of the Ivorian Interior Minister (via allAfrica.com):

A top adviser to Gbagbo has said the sanctions are “a threat” to Cote d’Ivoire and his interior minister told RFI the measures “make me smile.”

Of course they do – this is just what Gbagbo and his people wanted – now they have evidence of “outside interference” in Ivorian affairs which they can mobilize as a rallying point for patriotism – and in so doing, relegitimize Gbagbo as the defender of the country.
While it is interesting that Deputy Assistant Secretary for African Affairs William Fitzgerald is leaving military intervention on the table as an option, note that he has effectively ruled out US military engagement:

He said it was unlikely that U.S. troops would participate if that option was taken and that it was more likely to be an African force.

This is not a threat.  ECOMOG, the armed monitoring group of ECOWAS (the Economic Community of West African States), was able to retake Freetown in Sierra Leone during that civil war, but could do little else.  And that was a relatively successful intervention in a much smaller country.  This is like threatening to hit someone, but only with a nerf bat – annoying, but not really terrifying.
This has gone too far down the road now – someone is going to have to commit real troops to this conflict, and quickly – the UN peacekeepers won’t be able to hold the line much longer.

Posted on by Ed 0

Well, this should be interesting . . .

Ah, The Leaks that Shall Not Be Named (if you work for the US Government, at least) seem to have some amusing data on one of our banks here in the US.  This is not new news – Assange mentioned this last month.  But I like this piece on DealBook on who really is freaked out by this . . . turns out it is the government, again.  I agree completely with the author – pretty much nothing that is dumped would surprise me or much of the public anymore.  We know we got screwed . . . well, at least some of us have figured this out.  The rest of the population seems to be preoccupied by . . . well, honestly I have no idea what the hell people are looking at anymore.  Where is the collective rage?  Why hasn’t Congress rammed serious regulation of the financial industry through in fear of a pitchfork-wielding constituency?  Oh, right, Simon Johnson covered that . . .
All that aside, as the piece in DealBook points out this new dump of documents might shed some light on just how close the relationship between the financial industry and the government really is.  If, as Johnson claims, the financial industry has more or less captured the government in a sort of quiet coup, there may well be evidence of this – such as clear instances of regulators ignoring evidence of illegal acts, or warning institutions to change their behaviors before the regulators were forced to act.
Who knows what is in the documents . . . but given the remarkable Officer Barbrady impression pulled by the SEC in the “flash crash” case, I have a feeling something ugly is in there.  I just don’t believe the regulators are that blind, or that stupid . . .
But here’s what I am wondering – and I’ve not seen it raised yet: what if these documents contain evidence of the conscious manipulation of wheat pricing that triggered the 2008 global food price spike, and appears to be behind at least some of the current food price increases we are seeing.  It is one thing to screw around with financial instruments until you collapse the economy . . . but it is entirely another to quite literally starve people to death for profit.  It would be interesting to see if such behavior qualified as a crime against humanity.  It damn well should.
This strikes me as especially pertinent because the document dump, by placing the documents in the public realm, makes them usable by various governments (including our own) in prosecutions of criminal acts.  While the documents were illegally obtained, they were not obtained at the behest of the government (I think we can all agree that Assange and the US Government are not colluding on much of anything these days) and therefore may not be “fruit of the poisoned tree.”  Would regulators/the Justice Department dare ignore evidence there for all to see?  Would the ICC get involved?  And how ugly would this get, if indeed there was evidence of collusion between the regulators and the financial institutions?  Are the regulators liable for actions in commodities markets if they allowed manipulation to take place?

Posted on by Ed 0