Michael Mainelli, Executive Chairman, The Z/Yen Group
Mercers’ School Memorial Professor of Commerce at Gresham College
[An edited version of this article first appeared as "The Compliance Handbook
European Union – Regional Guidance", Governance, Risk And Compliance Handbook, Anthony Tarantino (ed), John Wiley & Sons (2008) pages 613-625.]
A survey of compliance for the 27 European Union (EU) countries and two candidate countries, Turkey and Croatia(as at January 2007), must, of necessity, be shallow. The EU financial services industry is undergoing great changes, and the regulatory and compliance implications are equally great.
The EU has a 20% to 40 % global market share of various financial services. Working from data from the IMF, the World Federation of Exchanges, Bank of International Settlements, the European Fund and Asset Management Association and company reports of the top 100 global reinsurers, the EU estimated the global market shares in commercial bank assets, debt securities, stock market capitalisation, investment fund net assets, life and non-life premiums and non-life net written premiums in reinsurance for the EU in 2004 [see Chart].
Estimates of something as fungible as financial services must be treated cautiously but, overall, the EU financial services industry is comparable to the US. The EU has a larger share of the global banking market (45%) and global reinsurance (nearly 40%), while the US has a larger market share of stock market activities (40%) and investment management (50%) sectors. All these market shares are fluid. Changes in the US, particularly due to regulation, make the EU more competitive for wholesale financial services, while the EU’s fragmented retail financial services serve as a barrier to entry against efficient foreign firms. Given the EU’s population of 480 million in 2007, the EU will remain a major domestic retail financial services market regardless of the skill or incompetence of regulation or compliance, so this chapter will focus on areas where regulation will help the EU to gain or lose significant international business.
EU Share of World Financial Activity 2004 (%)
Source: Commission Of The European Communities, “Financial Integration Monitor 2006”, SEC(2006) 1057, Commission Staff Working Document, Brussels, 26 July 2006, page 6.
The Role of the Single Market
The EU began as a Common Market and in many ways is defined by the members’ desire to eliminate trade barriers and simplify rules to enable individuals, consumers and businesses in the EU to make the most of the opportunities offered to them by having direct access to this enormous market.
The ‘single market’ is based on ‘four freedoms’ enshrined in treaties among the members - the free movement of people, goods, services and capital. Financial services affects all four freedoms. People need payment, savings and protection products that transcend national boundaries. Movement of goods and services benefits from efficient, integrated payment systems. The efficient allocation of capital across the EU should benefit growth for all members. EU policy and strategy in financial services and financial markets tries to promote coherence and consistency among banking, insurance, securities and investment funds, financial markets infrastructure, retail financial services and payment systems. To quote from the EU website:
“From 1999 to 2005, this overarching policy was delivered in the framework of the Financial Services Action Plan (FSAP), and the Commission continues to regularly monitor progress made in implementing the FSAP, for instance through making twice-monthly updates to its FSAP transposition tables. Work also continues on co-ordinating the initiatives driven by the FSAP, including the restructured financial services committee architecture (Lamfalussy approach), the Inter-institutional Monitoring Group and supervisory convergence. In December 2005, the Commission published the White Paper on Financial Services 2005-2010, which sets out the Commission's objectives in financial services policy for the period to 2010.”
EU objectives that affect compliance are threefold. Firstly, the EU intends to remove barriers to financial services, including reducing unnecessary compliance obligations. The EU is looking to allocate capital more appropriately and reduce the costs of financial services. Secondly, the EU intends to enforce existing regulation, balancing the compliance drivers of financial stability and consumer protection with the markets through rigorous impact assessment. Thirdly, EU relations with other global financial marketplaces and strengthening European influence globally require enhancing supervisory cooperation and convergence within the EU. The net impact of this third point is likely to be an increase in compliance obligations.
In 2001, the EU promoted a new approach to financial services regulation, the Lamfalussy Process, named after the chair of the EU advisory committee that created it, Alexandre Lamfalussy. There are four "levels" to the Lamfalussy Process. At the first level, the European Parliament and Council of the European Union adopt new legislation, establish the core values of a law and build guidelines for implementation. The law then progresses to the second level, where sector-specific committees and regulators advise on technical details. At the third level, national regulators coordinate new regulations with other nations. The fourth level consists of compliance and enforcement of the new rules and laws. The Lamfalussy Process is intended to provide more-consistent interpretation in national supervisory practices, and provide better interpretation and application of legislation. A good example of the Lamfalussy Process in action is the current implementation of the Markets in Financial Instruments Directive (MiFID). MiFID is due to be implemented in 2007 and will change significantly trade transparency and ensuring best execution.
EU policy normally divides the financial services sector into three major areas: banking, insurance, and investment & securities. However, there are two distinct areas of compliance within the EU for all three areas, i.e. another divide is between retail financial services and wholesale financial services.
Divide and Conflict – Retail and Wholesale
Retail financial services are characterised by a tremendous amount of national legislation about how products can be sold, marketed or distributed, ostensibly for consumer protection. With 27 countries and numerous regulators in many countries, there are several hundred regulatory organisations involved. EU or national interpretations of international regulation, e.g. anti-money laundering, can have a significant effect on retail financial services. EU legislation has removed interest rate controls, capital controls and segregated markets, e.g. allowing banks to offer insurance. But implementation is frequently patchy and inconsistent, for example on the Second Money Laundering Directive, “the failure of 2MLD to provide for the establishment of competent authorities in each Member State to monitor and enforce compliance with the directive requirements means that compliance varies widely, not only between Member States but also across business sectors within Member States”.1
Wholesale financial services are global, thus compliance is complicated where national, EU and international regulation meet each other, ranging from International Financial Reporting Standards (IFRS) to Basel I & Basel II or anti-money laundering regulations. Many of the European wholesale markets are recent. London’s “Big Bang”, the removal of barriers to entry for its capital markets, was as recent as 1986. Wholesale financial services are mobile and, for a variety of reasons, increasingly centred around London as one of the two global financial centres alongside New York City.2 Because wholesale markets are competing globally and mobile, a lot of debate focuses on whether or not London remains competitive with non-EU wholesale markets, particularly when retail and wholesale regulation conflict, for instance with national capital markets legislation or the treatment of corporations or anti-money laundering. Discussions with numerous wholesale market firms indicates that several are beginning to see “effective implementation of compliance” as a competitive tool. If they can implement credible systems that prove to regulators they comply with regulations before their competitors, they shift the burden of regulation to the competition. For example, considering MiFID “best execution” requirements (though RegNMS “best execution” requirements in the USA are comparable), firms have been discussing how they might develop generalised compliance systems that would apply to anticipated new regulation using dynamic anomaly and pattern recognition techniques.3
At the retail level, the introduction of the Euro (€) since 2000 has accelerated moves towards more standardisation of retail regulation, both because products are more comparable and because a common, stable currency has increased the mobility of capital. The EU continues to push for further currency integration in the form of a single euro payments area (SEPA). SEPA aims to enable European citizens to make payments in the euro area as securely, quickly and efficiently as payments within national borders. Service levels for domestic and cross-border retail payments are to be identical by 2010. The introduction of IFRS4 across 7,000 listed firms in the EU is leading to pressure to align IFRS accounts with corporate tax returns. Disclosure quality is increasing and, in turn, this is leading to increasing pressure for the harmonisation of taxation conventions, and perhaps increasingly for a harmonisation of taxation rates across the EU.
London versus Brussels
At the wholesale level, the most important discussions seem to be between Britain’s Financial Services Authority (FSA) and the EU – London versus Brussels. Britain’s move to a unitary regulator for all financial services, wholesale and retail, international and domestic, insurance and banking, was controversial when it began in the 1990’s. However, the FSA is widely seen as, on balance, a success. The FSA has particular support from the wholesale financial services industry who view it as an ally both in dealings with the EU in Brussels and with other regulators abroad. In particular, the FSA is seen as a strong ally in discussions with the large range of US wholesale finance regulators.
Despite all the good words about the regulatory system in the UK, the FSA does have a track record of ‘super-regulating’ and the implementation of several European Union (EU) directives has been more rigourous in the UK than in other EU member states. The 3rd Anti-Money Laundering Directive and the Insurance Mediation Directive are two recent examples of FSA super-regulation in relation to other European jurisdictions. The British Institute of International and Comparative Law recently noted5 that the Insider Dealing & Market Abuse directive is another example of different levels of regulation resulting from the same directive.
The FSA is, however, now gaining a reputation for the rigour with which it undertakes impact assessments and cost/benefit analyses of proposed regulation and as the European Policy Forum notes:6
The EU Directors of Better Regulation Group has analysed the way in which RIAs operate in ten member states. It has noted that overall best practice is found in the United Kingdom.
Aspiring financial centres can learn a great deal from the contrast between UK and USA financial services regulation. It was not always like this. Back in the late 1990s – when the arguments over whether Britain should join the single European currency were raging – the City was seen as a trump card by pro-Europeans. Lord Levene stated in 1998 that if Britain stayed out of the euro for too long: “London’s business will, in time, be eroded.” The British government was worried enough to make the impact of the euro on the financial services industry one of the “five tests” that would decide if the UK joined the euro. The idea that the City of London and Brussels were natural allies seemed to make sense. Few markets are as global as the wholesale financial markets of the City of London. Almost 25% of its employees are citizens of other countries. Yet gauging the City’s attitude to Brussels is difficult. Open Europe, a Eurosceptic lobby group, and Business for New Europe, a Europhile group, can both identify City sponsors. There is more talk of “London versus Brussels” as the UK being out of the Euro zone has had little detrimental effect, the City increasingly attracts non-EU business and the City’s preference for light legislation over the “one size fits all markets” approach of Brussels.
London’s unitary regulator might be a liability if, driven by the breadth of its remit, it allows specific competitive centres to ‘pick off’ specific sub-sections of the financial services industry, e.g. insurance captives, private banking or hedge funds. Further, one can anticipate more of the extra-territorial regulatory disputes that have already been seen over subjects such as the acquisition of European exchanges by American exchanges or the Unlawful Internet Gaming Enforcement Act.
The Vested Interests
As in so many other areas of policy by the EU’s national members, the simple and seductive argument for national champions starts with “finance is so important that it must be treated differently.” There are legitimate concerns justifying special treatment, particularly consumer confidence, which despite the common market remains astonishingly parochial; taxation, where financial services support taxation collection; and pensions, where an underfunded industry would lead to significant future demands on a Member State.
Financial cartels, such as the various national retails banks or national fund industries, do not like liquid markets that turn financial services into commodities. Numerous studies have lamented the lack of competition for retail financial services within Member States.7 The top 5 banks in most EU Member States hold over 50% of the market. Only in Germany do the top 5 banks hold less than 25% of the market. “Despite all the laws and rules enacted since the mid-1980s to give the European Union a single market in goods and services, including banking and finance, banks have obstinately gone on getting bigger within their home countries. They have merged at home much more enthusiastically than they have merged or branched or sold services across borders.”8
In the wholesale markets, two antithetical models complicate things for regulators. The first model is that financial services needs vertical integration in order to achieve efficiency, e.g. linking trade execution through to clearing and settlement, e.g. Deutsche Börse. The second model is that of horizontal competition at various strata in the supply chain, e.g. London Stock Exchange competing with Euronext on trading, while Euroclear competes with SegaInterSettle on clearing and settlement. The two models conflict and raise conflicting monopoly control issues, e.g. preventing the London Stock Exchange from owning Crestco, or hampering financial exchanges’ mergers and acquisitions.
Looking at progress in core financial services can be disheartening. Change is slow. However, in other areas the EU financial services industry is undergoing rapid change. One example is private banking where, for example, legislative changes are bringing wealth management services back onshore in Belgium. Another example is gambling, particularly onshore gambling. The scale and influence of gambling in Europe is often not appreciated, particularly in the USA.9 Firstly, gambling is a large market in its own right – in less than a decade Betfair in the UK has become, arguably, the largest exchange in terms of transaction volumes. Secondly, gambling in financial instruments is an important link from consumers to wholesale financial markets, for a variety of tax and regulatory reasons. Because of the USA’s 2006 Unlawful Internet Gambling Enforcement Act, which effectively outlaws online gambling in the USA, European online gambling regulation and compliance is in turmoil as many of its customers are from the USA and many payment systems rely on USA providers.
International Regulatory Competition
Cities around the world compete to have businesses locate in their city. Wholesale financial services is an attractive business sector because it is both “hot” – financial services has been a rapidly growing and successful sector for the past quarter of a century - and because it is highly mobile – therefore potentially influenced significantly by policy and planning. The importance of financial services as a topic for government officials and regulators can be felt in this excerpt from a a UK HM Treasury Report :10
… London is, on many counts, the world’s leading financial centre … London is unambiguously the world’s largest centre for international financial services because, unlike the domestic focus of other large financial centres, it dominates key international financial markets and, for example, has more foreign banks than any other financial centre. Britain’s other important financial centres, primarily in Edinburgh and Leeds, contribute to London’s international reputation and strength ... London’s competitiveness across a wide range of international wholesale markets is based around its three key strengths:
scale: the size of London’s markets creates genuine liquidity, the cornerstone of an efficient market;
scope: nowhere else in the world has London’s range of services, or London’s record for innovation in new services like derivatives and Islamic finance; and
internationalism: London has a tradition of openness with regard to foreign ownership and participation, historical links with emerging markets in Asia and the Middle East, and a strong transatlantic relationship.
Some of the analysis spills over into almost a parody of determinism or Haeckel’s belief that “ontogeny recapitulates phylogeny”, i.e. to develop as successfully as London, a city must be London:
An economic legacy of freedom, flexibility and openness: London’s historic legacy is one of internationalism and of trade. Its financial markets provide a bridge between the timezones of Asia and America. While English has become the unquestioned global business language, clarity and certainty of English law has meant that it has also become the legal language of choice for much international commerce. British attitudes to trade and foreign ownership are founded in traditions of openness and fair play, and policies towards migration and temporary foreign workers are some of the fairest and most flexible in the world.11”
HM Treasury, “The UK Financial Services Sector: Rising to the Challenges and Opportunities of Globalisation”, (March 2005).
Comparative financial centre research interests journalists seeking to create a story of rivalry between London and New York City. In many articles on both sides of the Atlantic the see-saw of competitiveness is seen as tilting in London’s favour due to regulation:
New York City View 12:
“The city's [New York City’s] Economic Development Corporation said yesterday it is hiring McKinsey and Company for $600,000 to formulate a strategy for New York City to maintain its title as financial capital of the world … The hiring comes as London has gained ground on Wall Street in recent years, experts say, with expanding European markets, an explosion of activity in the hedge fund business and an increasing number of companies that are choosing to go public on the London Stock Exchange, as opposed to in New York. Some say that London is benefiting from America's Sarbanes-Oxley Act of 2002, sweeping legislation that created new corporate governance, financial disclosure, and public accounting standards for companies. Critics said the legislation increased the cost of doing business here.”
London View 13:
“London is overtaking New York and is re-establishing itself as the world’s financial centre for the first time since the days of Empire”.
One Word – Regulation, Regulation, Regulation
Much research has reported fears about over-regulation, such as the Centre for the Study of Financial Innovation’s14 (CSFI) banking survey in 2005:
“The UK Government has taken financial services for granted, and any unwarranted tightening of regulation will kill the golden goose. The regulatory industry has grown bigger without growing smarter.”
In the 2005 Z/Yen study for the City of London Corporation15, more than 80% of respondents saw the regulatory environment as Very or Critically Important. Respondents from outside the UK placed greater emphasis on the regulatory environment, with 57% considering it Critically Important compared with 39% in the UK. Just over 60% of international bankers saw the regulatory environment as Critically Important, compared with 35% of UK bankers. The regulatory environment is considered much better in London and New York City than it is in Paris and Frankfurt. Over 90% of respondents rated the regulatory environment in London as Good or Excellent.
Many economists have long talked about potential competition between regulatory regimes. A continuing debate in financial services in Europe has been between those who believe that lighter regulation will increase the scale of the business versus those who believe that stronger regulation will increase the scale of the business. Both sides have invoked both versions of Gresham’s Law – “good money drives out bad” and “bad money drives out good” [Mundell, 1988]. It must be gratifying for economists to see the cause of potential relocation attributed so directly to regulation:
London’s Mayor Ken Livingstone recently visited New York City, trolling for businesses that might relocate jobs and investment activity from the United States to Great Britain. Asked what he considered London’s competitive advantage over New York, he replied, "Sarbanes-Oxley".16
One of the reasons that London is a direct competitor of New York City is the regulatory environment in the two cities.
Some would like the SEC (the Securities and Exchange Commission in the USA) to become more like Britain’s super-regulator, the Financial Services Authority (FSA). The FSA has won plaudits for an approach based more on principles rather than hard rules. It prefers to nudge rather than bully. Moreover, it is widely considered to be better at analysing the potential costs and benefits of proposed regulatory changes.17
The regulatory environment is second only in importance to the availability of skilled personnel when locating wholesale financial services. There are two sides to the regulatory environment, the quantity and rigour of the regulations themselves, and the way in which firms are expected to comply. Many people are critical of the USA’s heavy-handed approach to regulating financial services. Some regulators, such as the SEC, adopt a prescriptive, ‘rules based’ approach whilst the FSA has a less prescriptive ‘principles based’ approach. As the Economist reports:
In 2004 the Financial Services Authority responded [to concerns about regulation] by setting up a separate division for wholesale and institutional markets, headed by Hector Sants, previously an investment banker. “We recognise, says Mr Sants, “that good regulation is a key component of a successful marketplace”. The FSA is now highlighting the need for regulation to be based on principles rather than detailed prescriptions.18
John Tiner, the chief executive of the FSA, states:
We probably already have too much regulation. What we need to head towards is better regulation.19
Whilst many in London still think the FSA is heavy-handed in its approach, the UK almost certainly benefits from the FSA’s comparatively mature approach. The Economist argues14 that there are two serious regulatory problems facing the USA. First, the SEC is good at enforcing regulations but has lost sight of its other goal – to ensue that markets run smoothly and efficiently. Second, the regulatory structure has too many agencies. There are four separate banking regulators and the multiplicity of state and federal regulators continuously “tread on each other’s toes”.
It would appear that the USA has scored another regulatory own-goal with Sarbanes-Oxley legislation. The London Stock Exchange has been a big beneficiary of the legislation with international firms flocking to list in London (either on the main market or on AIM) rather than listing in the regulation-bound USA (London hosted 172 international listings in the first nine months of 2006 compared with 134 in New York20).
It is possible to overstate the detrimental effect of one piece of legislation and forget other sources of competitive disadvantage. A detailed study into the cost of raising capital in various markets21 reported recently that, although significant, the cost of Sarbanes-Oxley compliance was not the biggest cost involved in raising capital. The biggest cost was the high fees charged by Wall Street banks (6.5% to 7% of the value of shares offered against a typical level of 3% to 4% in Europe).
The Future of Regulation
Regulation within financial services is generally the result of a knee jerk reaction to an acknowledged problem that is perceived to be facing the industry. There are generally two forms of financial regulation: legal and self-regulated. Legal regulation emanates mostly from EU directives being made into national laws, though member states still add local requirements. Compliance imposed with the general support of the regulated, but without legal sanction –self regulation – has been out of favour, but is returning as regulators and the financial services industry realise that “one size fits all” harms competition and consumers.
Regulation is important. Business is transacted where regulators permit, but also where people trust the regulators. Over time, regulators either gain the skills to regulate international financial transactions and institutions, or lose credibility by being too intransigent or too lax. Sooner or later, certain regulatory regimes pull away from the pack or, sometimes more accurately, others drop away.
The financial services industry has been at the centre of regulation for centuries. Given this level of experience in compliance and regulation it would be nice to be able to say that regulation was generally well thought through and fit for purpose. Unfortunately this is generally not the case. A short review of EU regulation cannot begin to explain the intricacies of regulations in, for example, retail lending, data protection, competency requirements, capital requirements, market access, marketing and websites disclosure or reporting requirements.
A ‘New Approach’
Quality in products and services is now a widespread European expectation. Third party conformity assessment services have been steadily growing in response to the increasing need for impartial and transparent demonstration of the conformity of products and services exchanged in the European market. Regulators, industry and society place confidence in these services particularly through meeting the requirements of European Directives and Regulations. A Council Resolution (2003/C 282/02) in November 2003 acknowledged the importance of New Approach and Global Approach directives that place much more reliance on conformity assessment as opposed to regulation, along with the need for clearer framework for accreditation and conformity assessment. This approach may have important implications for financial services.22
Since 1987 some 25 directives, outside of financial services, have been adopted on the basis of the New Approach and the Global Approach. These directives have the dual purpose of ensuring the free movement of goods through technical harmonisation of entire product sectors, and of guaranteeing a high level of protection of public interest objectives referred to in Article 95 paragraph 3 of the EC Treaty. Innovative features of this legislative technique include the definition of mandatory essential requirements, the setting up of appropriate conformity assessment procedures and the introduction of CE marking. Business and industry are given a wide choice of how to meet their obligations. The European standards bodies have the task of drawing up technical specifications which offer one route to complying with these essential requirements.
“Where Member States decide to operate accreditation, they shall establish or have established and maintained under their jurisdiction a national accreditation body. Where accreditation is not operated by the public authorities themselves, Member States shall entrust the national accreditation body with the operation of accreditation as a public authority service and grant it formal recognition on behalf of government, authorising it to operate accreditation under the authority of the public authorities. Considering the added value of accreditation to serve as the last and authoritative level of control of conformity assessment activities with regard to technical competence in order to create mutual confidence, Member States shall ensure that accreditation operates free from commercial competition and shall entrust its operation to a single national accreditation body.”
Accreditation will in future provide the basis for the recognition of conformity assessment bodies attesting conformity to the requirements of European Directives and Regulations. The European Commission’s New Approach is that accreditation will be defined as a service of general interest, representing the last authoritative level of control of the conformity assessment services delivered both in the voluntary sector, and in the future, in the regulated sector. The European Commission expects increased transparency, coherence and cooperation in both the regulatory and voluntary areas, for New Approach directives.
New Approach directives are based on the following principles:
harmonisation is limited to essential requirements;
only products fulfilling the essential requirements may be placed on the market and put into service;
harmonised standards, the reference numbers of which have been published in the Official Journal and which have been transposed into national standards, are presumed to conform to the corresponding essential requirements
application of harmonised standards or other technical specifications remains voluntary, and manufacturers are free to choose any technical solution that provides compliance with the essential requirements.
manufacturers may choose between different conformity assessment procedures provided for in the applicable directive.
It may well be that the Lamfalussy Process will be subsumed within the New Approach being used for other products and services. In such a complex, federal structure, the future of regulation and compliance within the EU will never be straightforward. Nevertheless, there is clear recognition that a balance in regulation is needed to ensure vibrant markets, that legislation is not the only answer, and that the regulatory system must continue to evolve wherever possible by applying principles with pragmatic enforcement. When contrasted with the legalistic and rules-based approaches in the USA, the EU has a lot to inspire other regulatory regimes.
1. The British Institute of International and Comparative Law, “Comparative Implementation of EU Directives (II) – Money Laundering”, City of London Corporation Research Series Number 10, (December 2006).
2. Mark Yeandle, Michael Mainelli and Adrian Berendt, The Competitive Position of London as a Global Financial Centre , Corporation of London, 67 pages, (November 2005).
3. Michael Mainelli and Mark Yeandle, "The Best Execution: Trader or Client?" , Fund AIM, Volume 1, Number 1, pages 43-46, Investor Intelligence Partnership (January 2007).
4. Holger Daske and Günther Gebhardt, “International Financial Reporting Standards and Experts’ Perceptions of Disclosure Quality”, Abacus, Volume 42, Number 3/4, pages 461-498.
5. British Institute of International and Comparative Law, ‘Comparative Implementation of EU Directives (I) – Insider Dealing and Market Abuse’, Corporation of London (December 2005).
6. European Policy Forum, “Rebalancing UK and European Regulation”, Corporation of London, (April 2005).
7. Stephen Martin and Michael Mainelli, "Why Bother to Be Better? Strategically Stagnant Personal Current Accounts", Journal of Strategic Change, Volume 12, Number 4, pages 209-221, John Wiley & Sons (June-July 2003).
8. The Economist, “Survey: International Banking - What single market?”, (18 May 2006).
9. Michael Mainelli and Sam Dibb, "Betting on the Future: Online Gambling Goes Mainstream Financial" , Centre for the Study of Financial Innovation, Number 68, 34 pages, ISBN: 0-9545208-5-8 (December 2004).
10. HM Treasury, “Financial Services in London: Global Opportunities and Challenges”, (March 2006).
11. HM Treasury, “The UK Financial Services Sector: Rising to the Challenges and Opportunities of Globalisation”, (March 2005).
12. David Lombino, “Firm Hired To Boost City's Competitive Edge versus London”, The New York Sun, (27 September 2006).
13. John Arlidge, “The Golden Gateway”, The Sunday Times Magazine, (pp 60-70 3 December 2006).
14. Centre for the Study of Financial Innovation, “Banking Banana Skins”, Centre for the Study of Financial Innovation (2005).
15. Mark Yeandle, Michael Mainelli and Adrian Berendt, The Competitive Position of London as a Global Financial Centre , Corporation of London, 67 pages, (November 2005).
16. Kathryn Wylde, President and CEO of the Partnership for New York City, New York Post (3 August 2006) –
17. The Economist, “Down on the Street” A special report on America’s capital markets, (page 97, 25 November 2006).
18. The Economist, “Capital City”, (pages 99 & 100, 21 October 2006).
19. The Daily Telegraph (13 September 2006).
20. The Economist, ‘How to Protect an Industry’, (page 13, 21 October 2006).
21. Oxera Consulting Limited, “The Cost of Capital: An International Comparison”, Corporation of London, (June 2006).
22. Michael Mainelli, "Standard Differences: Differentiation Through Standardisation?" (ISO9001, SAS70 and management systems), Journal of Risk Finance, The Michael Mainelli Column, Volume 6, Number 1, pages 71-78, Emerald Group Publishing Limited (January 2005).
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