is investing without a conscience….

comments equate a decision to support the genocide proxy as the equivalent to not supporting tobacco companies, companies that are global friendly….taking a human beings life for a difference of views or opinions or where they come from is not equivalent to these analogies. Would you remain in an index fund that supported North Korea’s regime, or the atrocities of Hitlers regime? All for the sake of ‘having the right exposure to the market?’

Index funds don’t have any policies built in to encourage ethical and moral behavior. Companies, as we have seen, can create products that contribute to the collapse of the financial industry (credit default swaps as one), can evade taxes, embezzle funds, promote illegal practices in their organization, and yet an index fund will continue to invest because the company represents the market.


Something is inherently wrong in our society when there are no consequences for unethical and immoral behavior on a massive level such as indexing.

Vanguard..Dan Wiener ‘I noticed some very, very curious numbers’

a highlight from Dan Wiener’s newsletter, see page 12 for full comments: Adviser201710 ( you can subscribe for a fee)


“Here’s what got me thinking about this: Going over the semiannual reports for the Vanguard funds reporting for the six-month period from November 30, 2016 to May 31, 2017, I noticed some very, very curious numbers. Under the line items for “Reports,” Convertible Securities’ costs jumped 230%, from $10,000 to $33,000, in just six months, even though assets fell 7.4%. Wellington’s costs for reports jumped 221% for its Investor shares and 148% for its Admiral shares, though Investor share assets only grew 2.7% and Admiral share assets grew 8.9% over the period. And then there were these crazy numbers: New Jersey Long-Term TaxExempt’s “report” costs soared 533% for its Investor shares and 1,167% for its Admiral shares. Meanwhile, assets grew just 1.5% and 4.0%, respectively, for the two share classes over the period. And don’t even ask about New Jersey Municipal Money Market, where report costs soared from $4,000 to $126,000, a 3,050% increase. I could go on and on. The numbers are all over the map. “


“What do we know? Well, Vanguard has been under pressure to get its accounting house in order ever since a former employee, lawyer David Danon, filed suit claiming (among other things) that the company has avoided paying taxes on billions of dollars in income.” (THE IRS IS STILL INVESTIGATING THIS CASE GOING ON 5 YEARS)

IRS..Vanguard..Sarah Bloom Raskin….Ask Questions

Sarah Bloom Raskin, is on Vanguard’s upcoming proxy vote to be a new Board member, please see her background, click here, Sarah Bloom Raskin

To view the full press release click here, Vanguard Files Proxy Seeking Shareholder election of trustees and approval of policy changes.

The treasury oversees the IRS. This would put a person with significant regulatory experience, and Treasury experience, on the board to make sure Vanguard complies with IRS/regulatory rules  in the future. It doesn’t appear any of the prior board members had any legal experience.

From Vanguard’s press release July 13, 2017:

Election of trustees

Vanguard is asking shareholders of each fund to elect a board of trustees. In selecting trustee candidates, the independent nominating committee considers the overall composition of the funds’ board to ensure it reflects an optimal combination of professional experience and expertise. The trustees are responsible for setting broad policies for the funds; monitoring fund operations, performance, regulatory compliance, risk management, and costs; reviewing and approving advisory contracts; nominating and selecting new trustees; and selecting fund officers.

Questions that may need an answer in the near future;

did the former prior board commit an oversight of colossal significance by overseeing a company that engaged in a historically massive tax evasion?

Should the board have any accountability if/when the IRS rules in the Vanguard tax evasion case that has been open going on over four years?

What specifically is the Board’s role and responsibility in seeing that Vanguard has complied and is complying to IRS/SEC/FINRA rules, guidelines and standards?

What are the consequences for not living up to the expectations in a role of being a Board member of Vanguard?


Vanguard CEO McNabb to be stepping down….

In the news today;

Vanguard CEO McNabb steps down, Buckley is the new boss, July 13, 2017

William McNabb of fund giant Vanguard to step down, the NYT, July 13, 2107

Vanguard CEO McNabb to step down, Bloomberg, July 13, 2017

This individual is being asked to serve on Vanguard’s board,



Sarah Bloom Raskin (Born April 15, 1961) is an American attorney and regulator, who was formerly a member of the Board of Governors of the Federal Reserve System and former United States Deputy Secretary of the Treasury. Previously, she served as Maryland Commissioner of Financial Regulation.,

Vanguard is not a non-profit

Dan Weiner makes that point clearly in this article in the Philly Inquirer today, Vanguard partnership profits up 15% over 2016, by Erin Arvedlund. A few interesting notes,


*Wiener estimates current CEO William McNabb takes home between $12 million and $21 million, based on how partnership units were awarded to previous leaders such as Bogle and Jack Brennan.

…’In his latest newsletter, Wiener writes: “Since its first year, the Partnership Plan’s dividend has risen 62 times. The value of one share of 500 Index has, with all distributions reinvested, grown 27 times over the same period. The takeaway for a Vanguard investor is pretty clear:  Vanguard is not, and has never been, a nonprofit, though much of the language around ‘operating at cost’ does, at times, make it sound as though it is. The company is exceedingly profitable, and hence has the ability to pay its captains millions of dollars every year,” he writes, adding that 90 percent of the top executives’ compensation comes as dividends from the Partnership Plan.”

Vanguard is a for profit company .

Vanguard in the news.. …..

Joe DiStefano says  in the opening sentences, ‘Who knew that a mutual fund company, like a political campaign, is seeking to hire lawyers to do opposition research, searching for questionable activity by rivals, in hopes of using it against them? Vanguard did just that. Click here to read the full article, Vanguard’s novel want ad sought lawyer to dig up dirt on its rivals’, Joe DiStefano, June 7, 2017

another ad for a Vanguard position in Arizona , among other human-relations duties, the company seeks applicants willing to “support the involuntary termination process for crew members,” and to “recommend and conduct termination as needed.” “Crew members” are what Vanguard calls its 15,000 employees.’


Posting that was removed:

Associate Counsel, Marketing

Malvern, PA, US

June 5, 2017

Keep Me In Mind

Add to Cart

Vanguard is a leading provider of financial products and services to individual and institutional investors worldwide. In addition, Vanguard is an employer of choice that continually invests in the growth, development and success of its employees over the course of their Vanguard careers. Known for its strong ethical business practices and client focus, Vanguard fosters a collaborative, team-oriented environment that rewards and recognizes its attorneys for providing business-focused legal solutions, with a strong emphasis on excellent client service and relationship management skills. Vanguard is seeking an attorney to partner with the business and Compliance to provide legal advice on all aspects of marketing and brand management issues.

Specific Responsibilities:

  • Provide thought leadership on all marketing, advertising and brand management issues.
  • Advise the business on the creation of a holistic brand management strategy and a marketing rules-based framework.
  • Coordinate with PR on brand management issues and assist with positioning of content.
  • Serve as a legal resource for our Advertising Compliance Group.
  • Create guidelines to differentiate between marketing and servicing communications, and create appropriate processes to evaluate these different materials.
  • Provide legal advice on all aspects of Vanguard’s use of social media.
  • Advise on marketing campaigns at their inception to ensure campaigns are consistent with all relevant laws, including FINRA marketing regulations.
  • Provide legal advice with respect to FINRA inquiries on Vanguard marketing materials.
  • Review competitors’ campaigns for possible FINRA violations; advise the business on whether to raise matters with FINRA.
  • Draft regulatory comment letters related to FINRA advertising rules.

Qualifications and Experience:

  • Minimum 5-10 years of relevant professional experience; excellent undergraduate and law school academic credentials
  • In-house experience required, preferably in a global organization
  • Demonstrated ability to influence business leaders and impact decision-making
  • Demonstrated track record of providing business-focused solutions that combine excellent judgment, creativity, risk-taking, and technical expertise
  • Demonstrated expertise in the use of data and digital market trends
  • Shares Vanguard’s values, including unmatched ethical standards, teamwork, client service, work ethic and positive attitude

Vanguard is not offering visa sponsorship for this position


And here is the other posting:

Specialist, Crew Relations and Compliance

Scottsdale, AZ, US

June 6, 2017

To provide timely and objective advice and counsel to Vanguard crew throughout their lifecycle with the organization, and to mitigate risk through the effective resolution of crew-related issues.Duties and Responsibilities

  • Provide site, division, or case-based insights to Crew Relations & Compliance CoE leadership to assist with design of strategies, frameworks, policies, and processes.
  • Support the involuntary termination process for crew members.
  • Support consistent policy interpretation and application of HR policies globally. Identify divisional or regional nuances in addressing crew-related issues and suggest potential process improvements to address these nuances while maintaining compliance with local regulations.
  • Work with managers and crew as needed to understand, monitor, and resolve crew complaints and conduct investigations as needed. Partner with Crew Relations & Compliance Leads and HR Policy & Risk Management Lead to address sensitive matters as needed while mitigating risk.
  • Provide objective coaching and counseling services to managers and crew. Clearly guide managers through the appropriate steps to be taken for corrective action due to crew disciplinary or performance issues. Recommend and conduct termination as needed.
  • Recommend appropriate programs for specific crew situations. Identify and highlight benefit programs provided by the Total Rewards CoE with the highest impact to crew due to utilization and/or perceived value. Suggest ways to optimize program value.
  • Partner with Crew Relations & Compliance Leads, HRBPs, and Talent Management CoE to lead and/or facilitate performance differentiation sessions in the business. Assist with fostering broad dialogue across the talent spectrum during differentiation sessions and identifying key performance-related trends. Provide guidance to managers in addressing performance-related issues.
  • Conduct in-person exit interviews for voluntary departures. Partner with Crew Central to efficiently process voluntary departures. Provide criteria for exit interview analysis and assist in analyzing exit interview data to mitigate risk and identify trends.
  • Provide leaders in the business with consultative support throughout the progressive investigation process by facilitating the process for either a disciplinary or performance-related issue. Provide dedicated support to both crew and leaders as needed.
  • Support educational initiatives for HR crew on internal and external compliance requirements and related process controls.
  • Conduct new manager assimilations as appropriate.
  • Facilitate the unemployment process as needed. Represent Vanguard at hearings as needed.
  • Assess, monitor, and manage crew trends for book of business.
  • Partner with other service organizations regarding crew matters as appropriate including Fraud, Information Security, Physical Security, Compliance, Audit, etc.
  • Participates in special projects and performs other duties as assigned.


  • Undergraduate degree in related field or equivalent combination of training and experience. Masters Degree and or HR professional certifications preferred.
  • A minimum of three to five years previous employee relations experience.
  • Employee relations and/or compliance experience preferred
  • Ability to remain poised and professional under potentially contentious situations
  • Sensitivity in working with confidential information
  • Proven teamwork capabilities
  • Strong oral and written communication skills
  • Excellent project management skills, including planning and organizational skills
  • Attentive to details and deadlines; ability to manage multiple initiatives
  • Ability to effectively work independently and identify when to engage others

Additional information: 

  • This position will report to Ruby Gilchrist.
  • Vanguard is not offering visa sponsorship for this position.

Bogle, Index concentration concerning, future impact uncertain…

Jack Bogle made these comments speaking to a group today, Vanguard’s Bogle tells CFA Institute…., by Erin Arvedlund, May 23, 2017

“index-fund management is heavily concentrated among three giant, trillion-dollar money managers that together hold some 20 percent of U.S. stocks,” Bogle said. “The impact of all this concentration remains to be seen.” . He speculated that concentration could even invite scrutiny from regulators.

The three firms are, ‘ Blackrock, State Street Global Advisors and Vanguard, with a total of about 21 percent of the entire indexing market.’  please take a minute to see who really owns Blackrock, and State Street, and so you can drill down into better understanding providing links, and if you don’t know Wellington and Vanguard go back to Bogle’s beginnings, Blackrock, PNC, State Street. T.Rowe Price, Discover Financial Services….. is there an antitrust issue here, (United States antitrust law is a collection of federal and state government laws that regulates the conduct and organization of business corporations, generally to promote fair competition for the benefit of consumers. )



SEC files Amicus Curiae Brief on behalf of David Danon

The Security and Exchange Commission filed an Amicus Curiae Brief October 16, 2016 to the Third Circuit Court of Appeals on BEHALF of David Danon.

What is an ‘amicus curiae brief’, this is a brief presented by someone interested in influencing the outcome of a lawsuit but who is not a party to it.

Specifically in the brief, on page 4. under Statement of the Case you will find the following; ‘the securities laws recognize that internal company reporting by employees and others is important for deterring, detecting, and stopping unlawful conduct that may harm investors.’