On July 24, the Securities and Exchange Commission announced Bryan Wood as the new director of its Office of Legislative and Intergovernmental Affairs. While the hiring of the OLIA director is always noteworthy (because this office coordinates with Congress and other government entities on behalf of the SEC), Wood’s hiring marks a first, specifically the first time the SEC has hired a millennial to run an office at the agency.
Millennials are leading a financial services revolution as changemakers, consumers and innovators. Meanwhile, millennials — who are the largest generation of Americans, numbering approximately 83.1 million, and are set to inherit over $59 trillion in assets over the coming decades — mostly remain a glaring blind spot at the federal financial regulators.
Millennials, especially the oldest ones, have been front and center in the decadeslong struggle to hold Wall Street accountable. Only in their 30s, the oldest ones have already witnessed multiple market meltdowns and scandals for the ages, including the Enron collapse, the dot-com bubble, the Great Recession and bank bailouts, Bernard Madoff’s guilty plea, and the ongoing Wells Fargo retail banking scandal. And these are the same Americans who graduated, often with significant student debt, exactly as the Great Recession began.
Perhaps not surprisingly, mounting evidence across industry sectors shows that many millennials want to bank and invest differently than their parents. In one survey, 73% of millennials said they “would be more excited about a new offering of financial services from nontraditional financial institutions like Google, Amazon, Apple, PayPal or Square, than from their own commercial bank” and “71% would rather go to the dentist than listen to what banks are saying.” Another study showed that 86% of millennials are interested in socially-responsible investing and millennials are twice as likely to invest in a stock or a fund if social responsibility is part of the security’s value-creation thesis.
Millennials, in addition to driving demand for 21st-century banking and socially-conscious investing, are creating the next generation of products and services. Of the 60 founders that Forbes named in its 2016 list of the top 50 fintech companies, nine founders were under age 30, 32 founders were under 40, and the average age of the founders was 38.
But for the most part, the federal financial regulators have not caught up to these developments, both in terms of their staffing and programming. Setting aside the Federal Reserve, which does not report employee age demographics through the U.S. Office of Personnel Management, as of March 2017, only 18.6% of federal financial regulatory employees were 34 or younger. By comparison, in fiscal year 2014, the percentage of millennials across the federal workforce averaged nearly 30%.
Among these regulators, the Office of the Comptroller of the Currency had the highest percentage of millennial employees at 28.1% (still below the federal workforce average) and the Commodity Futures Trading Commission had the lowest at 10.6%. CFTC Chair Chris Giancarlo has criticized his own agency for remaining in “a 20th-century time warp.” Millennial representation at the other agencies was as follows: the Consumer Financial Protection Bureau (26.3%), Federal Deposit Insurance Corp. (18.1%), National Credit Union Administration (16.2%), Financial Crimes Enforcement Network (15.9%), Federal Housing Finance Agency (12.3%) and SEC (12.0%).
Relatedly, federal financial regulators such as the CFPB, CFTC, Fed and SEC maintain advisory committees comprised of leaders from industry, academia, nonprofits and elsewhere. A mere scan of the member biographies for those advisory groups suggests they lack meaningful representation from America’s largest generation. Indeed, the SEC appears to have only one millennial on its advisory committees, Michael Pieciak. He is a nonvoting member on the Advisory Committee on Small and Emerging Companies.
From a programmatic standpoint, some financial regulators appear more focused on younger Americans than others. In recent years, for example, the CFPB has unveiled research, educational, enforcement-related and other initiatives focused on students and young consumers.
But the agencies could still do much more.
The SEC, for instance, has committed more resources for programs focused on senior investors than those for millennial investors. This includes an ongoing high-priority effort to protect senior investors from abusive sales practices and investment frauds. While the SEC has participated in investor education events focused on millennials, the SEC has never conducted a public sweep or other initiative focused on millennials. This is notwithstanding calls from Rick Fleming, the SEC’s investor advocate, for the commission to better consider millennials as the SEC conducts its work, including rulemakings.
The good news is that these federal agencies have the authority to take corrective action immediately. For example, each agency could discuss whether to create a Millennial Advisory Committee similar to the one created by the mayor of Philadelphia, or whether to include more millennials on existing advisory committees as members step down or new committees are created. Of note, SEC Chair Jay Clayton recently called for a new advisory committee on fixed income market structure, thus providing an opportunity to include younger voices. Moreover, each agency could task staff with identifying new initiatives focused on millennials, or ways to incorporate more focus on younger Americans into existing workstreams.
For federal financial regulators, how to fix their millennial blind spot is an important $59 trillion question.
