Socialism: give the board the last word on loans, and make every use of it public

Co-Authored-By: Claude Opus 5.5 <[email protected]>
Claude-Session: https://claude.ai/code/session_01QWPs69B8nQZjtPEUXMKzZx

JoshHeaps.Net/Content/Socialism/durability.md

@@ -52,7 +52,7 @@ The things that decide whether the experiment is fair are written into the law t
 - the loan limits and the rules against [political favoritism](pilot-safeguards.md#political-favoritism);
 - **how loans are managed once made.** A loan can be called in early only if payments stop, never for a technicality. The rules for handling a co-op in trouble are filed in advance too.
 
-The board can propose changes to the lending standards, with published reasons. The reviewers then report every result both ways: under the original standards and under the new ones. By law, no official can direct a decision on a particular loan, and any attempt is logged and published.
+The board can propose changes to the lending standards, with published reasons. The reviewers then report every result both ways: under the original standards and under the new ones. By law, nobody outside the bank can direct a decision on a particular loan, except the President through the board he appoints. Every instruction or contact the bank receives about a particular loan is logged and published. The board itself can overrule its staff on a loan, because the Constitution probably requires that, but only in writing and in public ([Who has the last word](#who-has-the-last-word)).
 
 ### Rigging the result
 
@@ -89,13 +89,13 @@ Co-ops in lower-paid work are held to the same line separately ([Who the Bank Le
 
 **Why 1 in 10.** There's no good benchmark for how often a lender wrongly turns away a clear pass, so 1 in 10 is a judgment call, set loose on purpose. Small-business loans are far less standardized than mortgages, and the lottery band already absorbs the close calls. Even so, when a bank is breaking its own rules on more than 1 clear case in 10, it isn't running the test the law describes. For approvals there's loose context: when mortgage lenders re-check loans they've already approved, they find serious errors in about 1.5% of them ([ACES, 2025](https://www.send2press.com/wire/aces-q4-and-cy-2025-mortgage-qc-industry-trends-report-shows-critical-defect-rate-falls-to-annual-low/)). That's a much more routine kind of loan, which is part of why the line here is set far looser.
 
-**Fixing it, not just labeling it.** Every applicant found wrongly rejected, in any year, is offered a new decision within 60 days. It's made on the reviewers' score, and only a disqualifier the reviewers confirm can block it. That undoes most of the damage while the pilot is running. The fix isn't a lending target. It only brings in applicants who met standards the bank filed itself. Loans made this way count in full in both deciding measures. They're also reported separately, since a group that waited a year may not be the group it was.
+**Fixing it, not just labeling it.** Every applicant found wrongly rejected, in any year, is offered a new decision within 60 days. It's made on the reviewers' score, and at staff level only a disqualifier the reviewers confirm can block it. The board can still overrule it in writing, but that counts against the bank in the audit ([Who has the last word](#who-has-the-last-word)). That undoes most of the damage while the pilot is running. The fix isn't a lending target. It only brings in applicants who met standards the bank filed itself. Loans made this way count in full in both deciding measures. They're also reported separately, since a group that waited a year may not be the group it was.
 
 **What "not tested" then takes.** At the final review, the verdict is "not tested" instead of "failed" only if all three of these hold:
 
 1. the pilot failed its test;
 2. the bank failed the audit in at least one year;
-3. the wrongful rejections that were never fixed could have changed the result. Those are the ones where the group turned down the new offer, had broken up, or never got one. The reviewers add them back as if each had done as well as funded co-ops with similar scores. If that would turn the survival result into a pass, the verdict is "not tested." If not, it stays "failed."
+3. the wrongful rejections that were never fixed could have changed the result. Those are the ones where the group turned down the new offer, had broken up, never got one, or had the new decision overruled by the board. The reviewers add them back as if each had done as well as funded co-ops with similar scores. If that would turn the survival result into a pass, the verdict is "not tested." If not, it stays "failed."
 
 Otherwise a fail stays a fail. A pass stands too, since rigging that didn't work doesn't change what the co-ops did. And "not tested" gives the bank no claim to the fast-track vote or to new money.
 
@@ -112,9 +112,35 @@ Otherwise a fail stays a fail. A pass stands too, since rigging that didn't work
 Unlike the Export-Import Bank, this bank can't be frozen by leaving board seats empty. It uses ordinary delegation, which keeps the President in charge:
 
 - **Standing authority for smaller loans.** The board appoints senior credit officers and gives them authority to approve loans up to $1 million under the filed standards. That authority doesn't lapse when board seats go empty. Any board can take it back, publicly, but it can't disappear by default.
-- **No quorum means an acting chair, not no one.** If the board can't meet, the Treasury Secretary, or an acting official named under the normal federal vacancy law, can act for it on loans too big for staff.
+- **No quorum means an acting chair, not no one.** If the board can't meet, the Treasury Secretary acts for it, but only on loans too big for staff and on reviewing staff decisions. The bank's own law has to say so. The general federal law on acting officials doesn't cover seats on the board of a government corporation ([5 U.S.C. § 3349c](https://www.law.cornell.edu/uscode/text/5/3349c)). Every rule on the board's own overrules ([below](#who-has-the-last-word)) applies to the Secretary too, and every decision made without a quorum is flagged in the results. The Secretary can't change the lending standards, and can take away a credit officer's authority only for cause, in writing.
+- **Emptying the board concentrates power. It doesn't hide it.** A president who fires the board and names no one puts its review power in one cabinet officer's hands. That's better than a freeze, and every use of it is public, but it's a single point of control. The results report how long each vacancy lasted and whether the quorum was lost through firings or through terms running out.
 - **Applications can't be buried.** A complete application gets a decision within 120 days, yes or no, with reasons. The clock pauses once, while the applicant answers the bank's one round of follow-up questions ([below](#who-can-go-to-court)). The rule forces an answer, not a yes.
-- **A second check during vacancies.** Any loan over $500,000 approved while the board lacks a quorum is cleared by the independent auditor before any money goes out.
+- **A second check during vacancies.** Any loan over $500,000 approved while the board lacks a quorum is checked by the independent auditor before any money goes out. If the auditor objects, the loan waits for the Treasury Secretary's written decision, which is published with the auditor's objection. If the Secretary hasn't decided within 30 days, the loan doesn't go out. It counts as a rejection by the bank, including in the rejection audit if the applicant scored above the lottery band.
+
+### Who has the last word
+
+The Constitution limits how far a lender like this can be insulated from the people the President appoints. Anyone who makes final decisions for the government has to answer, at some level, to officials the President appointed and the Senate confirmed. In 2021 the Supreme Court struck down a rule that stopped the head of the Patent Office from reviewing decisions by the judges below him, because "the unreviewable authority" of those judges was "incompatible with their appointment" as lower-level officers ([United States v. Arthrex, 2021](https://www.law.cornell.edu/supremecourt/text/19-1434)). The bank's credit officers hold permanent jobs with the power to commit up to $1 million of federal money on their own signature. Courts might well treat them the same way. That case was about officials deciding disputes, not lenders, and the credit officers might instead count as ordinary employees. The design below works either way.
+
+So the design gives the last word to the board, and makes using it visible:
+
+- **The board appoints the credit officers.** The board of a freestanding federal body likely counts as the "head of a department" that can appoint lower-level officers ([Free Enterprise Fund v. PCAOB, 2010](https://www.law.cornell.edu/supremecourt/text/08-861)). That case was about the SEC. Whether the board of a government corporation counts the same way hasn't been decided.
+- **The board can review any staff decision,** approvals and rejections alike. A staff decision isn't signed for 15 days unless the board waives review of it in writing. Those days count inside the 120-day deadline, and inside the 60 days for new decisions after the audit. That way the board never has to cancel a signed loan.
+- **Every overrule has names on it.** It's a recorded vote showing how each member voted, with reasons given file by file, never one memo for a batch. It's published along with any outside contact about that file. Loans the board decided over its staff's heads are reported as their own group. A board rejection of an applicant who scored above the lottery band counts in the [rejection audit](#when-rejections-mean-not-tested) like any other. A board approval of an applicant who scored below it, outside the lottery, counts in the approval check and falls under the rules against [political favoritism](pilot-safeguards.md#political-favoritism).
+- **What that protects.** A board can block good loans or push weak ones, one at a time, but each is public. Enough blocked loans can make a fail "not tested," and pushed loans that go bad show up as broken standards if the [emergency stop](pilot-spec.md#the-decision-rule) fires. That protects the record, not the co-ops turned away. "Not tested" ends the bank just as a fail does.
+- **Credit officers can be fired only for cause,** such as misconduct or breaking the filed standards. Only the board can fire them, with written findings that are published. For 140 years the Supreme Court has let Congress limit the firing of officials appointed by a department head ([United States v. Perkins, 1886](https://www.law.cornell.edu/supremecourt/text/116/483)). In July 2026 a federal trial court in Virginia held that this survives *Slaughter* (*Comans v. Executive Office of the President*, [reported by Lawfare](https://www.lawfaremedia.org/article/inferior-officers-protections-post-slaughter)). That's one court, and it binds no other.
+  - The administration argues the rule covers only officers with "limited duties and no policymaking or administrative authority," a line from [Seila Law v. CFPB, 2020](https://www.law.cornell.edu/supremecourt/text/19-7). Officers who can commit $1 million on their own signature may not fit that, so losing is at least as likely as winning.
+  - If it's lost, credit officers can be fired at will. Either way, the board can take back any officer's lending authority at any time, in public.
+- **The President supervises through the board.** The law can't stop a president directing the board he can fire, or replacing it with people who need no instructions. What it can do is put a duty on the bank's side. Board members and staff log and publish every instruction or contact they get from anyone in the executive branch, the White House included, about a particular loan, applicant or group of applicants. Contacts from members of Congress are handled the same way.
+  - What this can't catch: orders given by phone and never mentioned, or a board replaced with people who agree. A law requiring the President's own messages to be published could also run into executive privilege. This rule catches careless pressure, not careful pressure.
+
+**The same goes for the outside referees.** The reviewers and the auditor are private contractors. Private bodies can advise the government, but they can't have the final say over what it does. In 2025 the Supreme Court upheld a private body's role in the phone-subsidy program because its recommendations "cannot go into effect without an agency's say-so" ([FCC v. Consumers' Research, 2025](https://www.law.cornell.edu/supremecourt/text/24-354)). So:
+
+- **The reviewers' score binds the staff, not the board.** Suppose the rejection audit finds an applicant was wrongly turned away. The new decision is made by a credit officer on the reviewers' score, following a rule the law sets for them. It then goes through the same 15-day board review as any other decision.
+  - The board can overrule it, in writing. The overrule counts as a wrongful rejection in the audit unless it names a disqualifier on the filed list, and the reviewers confirm the file backs it.
+  - That count is a report, not a veto. It measures whether the filed standards were applied, whoever applied them.
+  - A court might hold that even this gives the reviewers too much say. Then the score becomes advice to the staff, and a staff refusal simply counts in the audit the same way.
+- **The results are reports. The board adopts them.** The reviewers' "failed" or "not tested" is what the record says, and on its own it orders no one. New lending ends on the date the law sets. Within 60 days of the final report, the board formally adopts the result. It can reject the reviewers' calculation only by publishing the specific error in how the filed rule was applied, which the auditor then checks in public. Once the result is adopted, a fail starts the loan sale, and a pass gives Congress its fast-track vote. Carrying out the sale after a fail is a duty with a deadline, so a court can order it. A friendly board could still refuse a fail on a made-up error, but only in writing, with the auditor's answer beside it.
+- **Restarting after an emergency stop is up to the board.** The board decides in writing within 30 days of the reviewers' report. If the report says restart and the board refuses, it has to say so in public. A hostile board can end lending this way, and that can't be closed without taking the last word away from the board.
 
 ### Where the money sits
 
@@ -143,7 +169,7 @@ Recent cases show the risk. In 2025 the Supreme Court said claims to restore can
 
 **What a court can order.**
 
-- **Only duties with a deadline.** The law says the bank *must* decide a complete application within 120 days, and must make each new decision the audit calls for within 60 days. Courts can order an agency to take a specific action the law requires of it ([Norton v. Southern Utah Wilderness Alliance, 2004](https://www.law.cornell.edu/supremecourt/text/03-101)). A court checks whether the duty was met on time, never whether a rejection was right. The reasons are checked by the [rejection audit](#when-rejections-mean-not-tested), not by judges. The one exception is a new decision after the audit. The law already says the answer there is yes unless the reviewers confirm a disqualifier, so a court can order the bank to follow that rule.
+- **Only duties with a deadline.** The law says the bank *must* decide a complete application within 120 days, and must make each new decision the audit calls for within 60 days. Courts can order an agency to take a specific action the law requires of it ([Norton v. Southern Utah Wilderness Alliance, 2004](https://www.law.cornell.edu/supremecourt/text/03-101)). A court checks whether the duty was met on time, never whether a rejection was right. The reasons are checked by the [rejection audit](#when-rejections-mean-not-tested), not by judges. The one exception is a new decision after the audit. The law already says the staff's answer there is yes unless the reviewers confirm a disqualifier, so a court can probably order the staff to follow that rule. The board keeps its 15-day review of the result, and a written overrule by the board stands. It's counted in the audit instead.
 - **No endless paperwork.** Whether an application is complete is judged against the bank's published checklist. The bank gets one round of follow-up questions, and the application is complete once the applicant answers them. Otherwise the 120-day clock could be stopped forever and there'd be nothing for a court to order.
 - **Signed loans, from money that's still there.** A borrower can make the bank pay out a stage of a signed loan once that stage's written conditions are met. Those conditions have to be objective and written into the contract, not left to the bank's judgment. The court can order payment only from the bank's own capital. If a later law, including a rider in a spending bill, bars the payment, no court can order it ([OPM v. Richmond, 1990](https://www.law.cornell.edu/supremecourt/text/496/414)). That's the same line drawn [above](#loans-already-made-keep-their-terms).
 - **The right court.** The law lets the government be sued for these duties in federal district court, which can order the bank to act, not only award money, even where the general rules would send the case to the Court of Federal Claims. Congress decides where the government can be sued and for what. It hasn't been tested, and a later Congress could repeal it, but only by passing a law.

JoshHeaps.Net/Content/Socialism/open-problems.md

@@ -19,7 +19,7 @@ An honest list of what the model hasn't solved yet, most dangerous first.
 
 5. **Scale.** *(Partly answered.)* Even a total success at pilot scale leaves most workers in conventional firms. The labor-market effect needs a sector large enough to move wages, and nobody knows how long growth to that size takes, if it happens at all. That's the price of not forcing it. [After a Pass: How Big, How Fast](scale.md) works through the numbers: even growing at twice the recent pace every year, co-ops would take about 19 years to reach 1% of today's private jobs. Growth after a pass comes in capped stages sized to demand the reviewers certify, and the labor-market effect gets its own test, by lottery, in local markets where co-ops could become a large share of one kind of work. Still open: the closest evidence cuts both ways (big retailers paying more didn't lift other employers' pay; hospitals hiring nurses did), the local test can only find fairly large effects, and co-ops may never become a big enough share anywhere to find out.
 
-6. **Political durability.** *(Partly answered.)* Gradual construction invites gradual repeal. [Making It Last](durability.md) builds the bank to survive a hostile government: the lending standards and the test are fixed in law, board vacancies can't freeze lending, the verdict says "not tested" rather than "failed" if the bank turns away applicants who meet its own standards (every rejection is re-scored, the line is more than 1 in 10 clear passes turned away, and the result has to be one those applicants could have changed; see [the line](durability.md#when-rejections-mean-not-tested)), and repeal can't unlock the co-ops. Still open: after the Supreme Court's 2026 ruling any president can replace the bank's board; money not yet lent can be taken back in a budget bill; the lock's bankruptcy protection depends on a federal law that can be repealed; and at pilot scale the sector has no real constituency. The 1-in-10 line is a judgment call with no benchmark behind it. The bank's law lets applicants and borrowers sue to enforce its deadlines and signed loans ([Who can go to court](durability.md#who-can-go-to-court)), but that's untested, lawsuits are slow, and if the Justice Department won't defend the law itself, the people left to defend it may not be allowed to.
+6. **Political durability.** *(Partly answered.)* Gradual construction invites gradual repeal. [Making It Last](durability.md) builds the bank to survive a hostile government: the lending standards and the test are fixed in law, board vacancies can't freeze lending, the verdict says "not tested" rather than "failed" if the bank turns away applicants who meet its own standards (every rejection is re-scored, the line is more than 1 in 10 clear passes turned away, and the result has to be one those applicants could have changed; see [the line](durability.md#when-rejections-mean-not-tested)), and repeal can't unlock the co-ops. Still open: after the Supreme Court's 2026 ruling any president can replace the bank's board; money not yet lent can be taken back in a budget bill; the lock's bankruptcy protection depends on a federal law that can be repealed; and at pilot scale the sector has no real constituency. The 1-in-10 line is a judgment call with no benchmark behind it. The bank's law lets applicants and borrowers sue to enforce its deadlines and signed loans ([Who can go to court](durability.md#who-can-go-to-court)), but that's untested, lawsuits are slow, and if the Justice Department won't defend the law itself, the people left to defend it may not be allowed to. The Constitution probably requires that the board have the last word on each loan, so the board can overrule its staff, only in writing, by named vote and in public ([Who has the last word](durability.md#who-has-the-last-word)). Whether the credit officers can keep protection from being fired after *Slaughter* is unsettled, and a president who empties the board hands its power to the Treasury Secretary.
 
 7. **Growth and dilution.** *(Partly answered.)* Softened by the tenure ramp, not eliminated, and federal tax law softens it less than the founding plan expected: by default, the part of a share new members haven't reached goes to the reserve, not to other members ([How a Locked Co-op Is Taxed](taxes.md#the-tenure-ramp)). In steady state, an equal split per head still means a marginal hire must generate the average surplus to break even for incumbents. Capital-intensive expansion into lower-margin lines will face internal resistance conventional firms don't have. [When Growing Means Sharing](growth.md) makes Mondragon's answer the standard path: a lower-margin line becomes its own locked co-op, funded from the parent's reserve as a finite, voteless investment, under rules that stop it being used to push existing workers out or move money through insider deals. Still open: growth that can't be split off still dilutes, spin-offs create richer and poorer co-ops (the groups can pool profits, but don't have to), and the evidence comes from co-ops that could hire non-members, so it probably understates the problem under the lock.
 

JoshHeaps.Net/Content/Socialism/pilot-safeguards.md

@@ -77,7 +77,7 @@ This page lists the ways someone could cheat [the pilot](pilot-spec.md), or sabo
 
 **The rules:**
 
-- **Fraud doesn't end the experiment.** Under the [emergency stop](pilot-spec.md#the-decision-rule), lending restarts once the reviewers confirm the specific gaps are closed. Losses that are later recovered are credited back.
+- **Fraud doesn't end the experiment.** Under the [emergency stop](pilot-spec.md#the-decision-rule), lending restarts once the reviewers confirm the specific gaps are closed and the board signs off. Losses that are later recovered are credited back.
 - **The staged payouts and middleman caps above** limit how much any ring can take before it's noticed.
 
 ## Rigging the review
@@ -104,4 +104,4 @@ This page lists the ways someone could cheat [the pilot](pilot-spec.md), or sabo
 
 - **Every loan is public:** the borrower, the amount, the rate and the terms.
 - **Every contact from an elected official or their staff about a specific loan is logged and published.**
-- **The board answers to elected officials. Individual loans don't.** The President can appoint and remove the bank's board at will. But by law no official can direct a decision on a particular loan, loan officers are bankers, not appointees, and a new board can't change the filed lending standards without the results being reported both ways (see [Making It Last](durability.md#what-a-new-board-cant-change)).
+- **The board answers to elected officials. Individual loans don't.** The President can appoint and remove the bank's board at will. But by law nobody outside the bank can direct a decision on a particular loan except through the board, the board can overrule its staff only in writing and in public ([Who has the last word](durability.md#who-has-the-last-word)), loan officers are career bankers the board hires and can fire only for cause, not political appointees, and a new board can't change the filed lending standards without the results being reported both ways (see [Making It Last](durability.md#what-a-new-board-cant-change)).

JoshHeaps.Net/Content/Socialism/pilot-spec.md

@@ -192,14 +192,14 @@ At year 12, both measures must pass:
 
 **If both pass:** the charter triggers a fast-track, up-or-down vote in Congress on a second capitalization, with no amendments and no committee bottleneck. It can't be automatic, because no Congress can bind a later one's spending. A fast-track vote is the most that can honestly be promised. If the bank is later allowed to borrow, its debts carry **no federal guarantee**, written into the charter. Fannie Mae and Freddie Mac needed a taxpayer rescue in 2008 partly because markets had always assumed the government stood behind them. This bank shouldn't be able to create that assumption.
 
-**If either fails, the shutdown happens by itself, with no further vote needed.** No new loans. The remaining loans are offered at fair value to co-op and community lenders, who keep the same repayment terms. Whatever they don't buy is collected by the Treasury on the original terms until paid off. None of it goes to distressed-debt buyers. The money goes back to the Treasury. The co-ops stay co-ops, because [the lock](the-lock.md) is in their own charters, but they're on their own.
+**If either fails, the shutdown happens by itself, with no further vote needed.** The board formally adopts the reviewers' result, and after a fail it has to start the loan sale by a deadline the law sets ([Who has the last word](durability.md#who-has-the-last-word)). No new loans. The remaining loans are offered at fair value to co-op and community lenders, who keep the same repayment terms. Whatever they don't buy is collected by the Treasury on the original terms until paid off. None of it goes to distressed-debt buyers. The money goes back to the Treasury. The co-ops stay co-ops, because [the lock](the-lock.md) is in their own charters, but they're on their own.
 
 **There is no "inconclusive, keep going" option.** If the evidence doesn't clearly show co-ops holding their own, that counts as a fail. The burden of proof is on the co-ops, which is where a skeptic would put it.
 
 **The emergency stop.** If net losses ever pass 20% of the capital ($70 million), new lending freezes (the [buyout track](buyouts.md) has its own stop, at $20 million), and the reviewers report within six months on the cause:
 
 - **A recession:** lending restarts only if the SBA's own loans from the same years lost money at a similar rate. That's a fixed comparison, not a judgment call.
-- **Fraud:** lending restarts once the reviewers certify the specific gaps are closed and recovery has been pursued. Otherwise one organized fraud ring could end the experiment on purpose (see [Guarding the Pilot](pilot-safeguards.md)).
+- **Fraud:** lending restarts once the reviewers certify the specific gaps are closed and recovery has been pursued, and the board signs off in writing. Otherwise one organized fraud ring could end the experiment on purpose (see [Guarding the Pilot](pilot-safeguards.md)).
 - **Bad lending decisions:** no restart. That's a result.
 
 ## What this pilot can't tell you

JoshHeaps.Net/Content/Socialism/the-bank.md

@@ -17,7 +17,7 @@ Mondragon's history supports the first half of the premise. For decades, apart f
 
 - **Charter:** lends only to firms that meet the [co-op definition](worker-ownership.md) and accept [the lock](the-lock.md). The bank can't widen its own charter. Mondragon's bank drifted into ordinary lending after a change in the law, and America's co-op bank drifted toward the safest co-ops once nothing held it to its target (see [Has This Been Tried?](precedents.md)). A charter can't stop Congress from changing it, but the fixed measures and deadline in [The Test](the-test.md) mean a mission change can't happen quietly. Drift inside the charter, toward the safest co-ops, is handled by money set aside for co-ops in lower-paid work and results published by group ([Who the Bank Lends To](who-gets-loans.md)).
 - **Priced at market rates.** This is deliberate. The bank's edge must be *willingness* to underwrite a firm structure other lenders refuse, not *cheap money*. If it lends below market, every result is unfalsifiable: success gets dismissed as "free state money," failure gets dismissed as "hobbled by the lock." At market rates, survival and returns mean something.
-- **Professional, insulated underwriting.** Loan officers are bankers, not appointees. Lending decisions are walled off from legislators the way monetary policy is walled off from Congress. A bank that funds whichever co-op has the best-connected sponsor fails the experiment and deserves to. Since 2026 the Supreme Court has made clear that any president can replace a board like this one at will, so the protection lives in what the board can't change, not in who sits on it (see [Making It Last](durability.md)).
+- **Professional, insulated underwriting.** Loan officers are career bankers hired by the board, not political appointees. The board can overrule them only in writing and in public. Lending decisions are walled off from legislators the way monetary policy is walled off from Congress. A bank that funds whichever co-op has the best-connected sponsor fails the experiment and deserves to. Since 2026 the Supreme Court has made clear that any president can replace a board like this one at will, so the protection lives in what the board can't change, not in who sits on it (see [Making It Last](durability.md)).
 - **Self-sustaining by design.** One-time capitalization, then it lives on its loan book. Losses are public and published. A permanent appropriation would turn it into a subsidy line, and subsidy lines get captured.
 - **Full transparency.** Portfolio data (default rates, survival, wages, productivity, member retention) published annually, so anyone can check the result, including critics.