- takes as its starting point the widely questioned and somewhat unproven ideas of Commission co-chair Hernando de Soto;
- accordingly attaches excessive importance to legal exclusion and downplays the many other legal and non-legal factors that perpetuate poverty;
- ignores prior research and experience that take broader though more modest views of legal empowerment;
- pays inadequate attention to gender;
- proposes a top-down approach to what it nevertheless claims is bottom-up development;
- implies that rational persuasion trumps political power and self-interest; and
- adopts often inconsistent assumptions and recommendations
However, Stephen does give credit to the UN, and proposes a focus on lessons learned and channel funding to locally based NGOs:
"The Commission on Legal Empowerment of the Poor has made a considerable contribution to the international development community by focusing attention on concrete legal needs of impoverished populations. As such, it constitutes a fine start for international, regional and domestic efforts to pull together a legal empowerment agenda...
Going forward, it is important to build on the Commission’s good start, but depart from its false and even counterproductive steps; the international community should instead draw on successful country-specific legal empowerment experience from diverse contexts. This features increased investment in civil society efforts to make the rule of law a reality, since such initiatives have a better track record than government-centered programs that mainly rely on elite good will. It more specifically involves enhanced long-term funding for domestic and international NGOefforts, both in the form of legal services for the disadvantaged and by integrating such services into broader socioeconomic development programs. The international community should also support impact-oriented applied research and move toward establishing a Millennium Development Goal for legal empowerment"