transparency in consultation and the privilege of trade association membership May 6, 2010
Posted by Bradley in : consultation , comments closedIf a standard-setter publishes responses to its consultative documents online, as the EU does, and the BIS has, for example on Strengthening the resilience of the banking sector and International framework for liquidity risk measurement, standards and monitoring, why would the writer of a response locate the same document on its own web pages behind its membership wall? The Loan Market Association’s comments are available for all to view on the BIS website, and from the EU Commission’s consultation pages, but its own website states:
The LMA has responded to the European Commission’s consultation on reforming the Capital Requirements Directive (CRD4) and the Bank of International Settlements’ consultative document — ‘Strengthening the resilience of the banking sector ‘.
The LMA welcomes these papers as constructive approaches to macro and micro-prudential risk management and the creation of a more resilient financial sector. To read the LMA’s response, which outlines the issues that the LMA feels should be considered, please logon to the Members’ Area and select Market Information/Regulation/Submission to Regulators.
In fact, the content of the responses is visible in the LMA press release. And in any case, it’s not as if there’s anything very surprising in the LMA’s comments, except perhaps that the comments to both bodies are basically the same, including this paragraph which seems more appropriately directed to a regional body like the Commission than to a global body like the BIS (though given the US attitude to implementation of Basel II perhaps not):
…it is important, given the global nature and interconnectivity of financial markets, that coordination with other regulators, supervisors and governing bodies is undertaken at both the development and implementation stages, so as to ensure clarity of message and avoid any risk of ‘regulatory arbitrage’. Policy should be aligned with other regions, particularly the United States of America.
But if it’s about making the LMA members feel they are getting more for their membership contributions than the lobbying itself, perhaps we should be getting (more) worried about the loan market?
odd lobbying effort… May 5, 2010
Posted by Bradley in : financial regulation , comments closedHow can a state be “genetically anti-business”?
strangely useful parliamentary equipment … April 27, 2010
Posted by Bradley in : risk , comments closed“vandal” bankers April 13, 2010
Posted by Bradley in : financial regulation , comments closedThere’s a European day of action on April 24.
group of experts in banking issues April 6, 2010
Posted by Bradley in : financial regulation , comments closedThe call for expression of interest (original closing date Feb. 28, 2010) doesn’t seem to have been too successful. Today there’s an addendum to the web page:
With reference to the call for expression of interest to participate in the Group of Experts in Banking Issues (GEBI), the Commission would like to clarify that although in principle, no reimbursement is guaranteed, the Commission may decide on the merit of reimbursing travel and subsistence expenses for certain members.
and now the election is happening… April 6, 2010
Posted by Bradley in : governance , comments closed.. UK Government Departments won’t be updating their websites in line with this guidance.
weird election strategies March 31, 2010
Posted by Bradley in : britishness , comments closed
(via the Guardian)(dateline should read April 1)
the uk government’s reaction to the robin hood proposal March 21, 2010
Posted by Bradley in : financial regulation , comments closedA coalition of charities has launched a campaign calling for a tax on global financial transactions, the so-called Robin Hood tax. This has led to a number of enquiries from members of the public for information on a transactions tax and the Government’s policy on the issue.
At the heart of the charities’ campaign is the belief that banks – who have benefited from significant public support in recent years – should make a fair contribution to society. This is a belief that is shared by the Government.
The Prime Minister raised the issue at the meeting of G20 Finance Ministers in St Andrews in November. He called for a better economic and social contract to reflect the global responsibilities of financial institutions to society.
The G20 nations have asked the International Monetary Fund to explore these issues further. They are looking at a range of options including contingent capital, systemic levies and transactions taxes. The IMF will deliver an interim report to G20 Finance Ministers at their next meeting in April, with a final report due in June.
The UK will continue to work for a global agreement to see banks contribute their fair share to society. Any work to raise awareness of this issue is to be welcomed.
very complicated…. February 10, 2010
Posted by Bradley in : financial regulation , comments closedconsulting the “general public” February 8, 2010
Posted by Bradley in : consultation , comments closedThe EU’s consultation on information sharing between the EU and the US, which purports to invite responses from stakeholders, including the “general public” doesn’t really seemed geared to generating responses from the public at large. It’s full of jargon and probably only makes sense to people who know quite a lot about the subject matter already (although the consultation page does provide links to relevant documents):
Should the agreement provide for modalities and consequences of “accountability”, e.g. internal and external review procedures? Should the agreement notably provide for a joint review mechanism?.. If there is no possibility to directly access one’s own personal data for justified reasons, should the agreement provide for the possibility of indirect verification through an independent authority responsible for the oversight of the processing in the sending or recipient country?.. Should the modalities for transparency and assistance to data subjects by US and EU data protection supervisory authorities be spelled out in the agreement?