Disclaimers – If You’re Not Speaking For Your Institution, Why Am I Listening To You?

Disclaimer: The views expressed herein are my own and do not represent the views or opinions of my current or any past employer.

Greg Baer, President and CEO of the Bank Policy Institute, spoke at a Women in Housing and Finance policy lunch hosted on Sept. 27, 2021. The title of his prepared remarks was Making Stablecoins Stable: Is the Cure Worse than the Disease? Mr. Baer had some very good points to make about stablecoins (most were not in favor of stablecoins), but what caught my eye was his opening paragraph:

“I’ll begin with something of a disclaimer.  As an aside, I should note that when I hear people from government agencies or major organizations begin their remarks by saying that they don’t represent the views of their organization, I always think either, “Then why the hell am I listening to you?” or “You’re clearly lying; of course you speak for your organization!”  So, I generally resist the urge to issue disclaimers.  But in this case, not only have I not consulted my members yet but also I’m not even sure if I’m right.  So, if it turns out I am right, and even prescient, then these were in fact the views of BPI; if I turn out to be wrong, these are the views of my administrative assistant, Emily Harris, who clearly corrupted the file.”

So it’s not just me that when I hear people from government agencies or major organizations begin their remarks by saying that they don’t represent the views of their organization, I always think “why the hell am I listening to you?” or “Bullshit – of course you are!”. I’m not as polite as Greg.

And even more insidious than a disclaimer at the beginning of a speech or article is a disclaimer buried in a footnote, or even worse, an endnote. In a November 17, 2021 speech titled “Reflections on Stablecoins and Payment Innovations” at “Planning for Surprises, Learning from Crises” 2021 Financial Stability Conference, cohosted by the Federal Reserve Bank of Cleveland, Federal Reserve Board Governor Christopher J. Waller buried his disclaimer in an endnote at the end of the opening sentence in the third paragraph of his prepared remarks: “My remarks today focus on ‘stablecoins,’ the highest-profile example of a new and fast-growing payments technology. Endnote – These views are my own and do not represent any position of the Board of Governors or other Federal Reserve policymakers.”

Frankly, I have no interest in hearing the views of private citizen Chris Waller. I am, though, interested in the views of Federal Reserve Board Governor Christopher J. Waller. In this case, he was introduced as a Federal Reserve Governor, and his remarks were the Keynote Address of the conference. He was even introduced by the President and CEO of the Federal Reserve Bank of Cleveland, Loretta J. Mester. So a speech given by a Federal Reserve Governor at a conference hosted by a Federal Reserve Bank should, in fact, represent the positions of the Federal Reserve Board of Governors and all other Federal Reserve policymakers. Otherwise … why bother?

Here’s my proposed solution to the disclaimer problem. The President should issue an Executive Order requiring all federal government agencies to ditch the disclaimers in their speeches and articles. If you are going to represent an agency, then your words should represent the agency, also.