Future Parliamentary scrutiny of financial services regulations

This is a House of Commons Committee report.

Second Report of Session 2022–23

Author: Treasury Committee

Related inquiry: Future of Financial Services

Date Published: 23 June 2022

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Contents

Report

1. Following the UK’s exit from the EU, UK regulators inherited from the European Commission powers to make detailed rules and regulations in the field of financial services. In the EU, this aspect of the Commission’s rule-making is scrutinised by the European Parliament, largely through its ‘ECON’ Committee.

2. It is widely accepted that the transfer of rule-making powers to UK regulators should lead to enhanced scrutiny by the UK Parliament, to monitor the exercise of those powers. We note a recent speech by the outgoing Chair of the Financial Conduct Authority, Charles Randell CBE, in which he noted that the forthcoming Financial Services and Markets Bill would make “significant changes to the relationships between the Government, Parliament and the financial regulators”. He went on to say that:

Changes are needed, because the power to make some financial regulations is passing to the regulators, when previously it sat with the EU institutions, with accountability through the European and national parliaments. So it’s important that Parliament has more effective oversight of our work. Appearing before the Treasury Committee is not always a comfortable experience, but it’s an essential part of our accountability and we should provide as much support as we can to enable Parliament to scrutinise our work.1

What the Committee has said so far

3. In our Report, The Future Framework for Regulation of Financial Services,2 we considered future Parliamentary scrutiny of regulatory proposals and set out our own proposed approach. We said that:

We believe that a measure of “ex-ante” scrutiny by Parliament is necessary. But we do not believe that it would be proportionate for Parliament or its committees to carry out, as a necessary part of the rule-making process, the detailed and comprehensive textual scrutiny which the European Parliament’s Economic and Monetary Affairs Committee conducts. The European Parliament’s legislative processes, under which the existing acquis of EU financial services rules was created, were designed for a parliamentary system which is quite different from that of the UK Parliament.

In reaching this conclusion, we took into account evidence from Lord Hill, former European Commissioner for Financial Services, who explained why comparisons between the European Parliament Committees and UK committees may not be very useful:

The first and obvious point to make is that our system is fundamentally different from the EU system. [ … ] What that illustrates is the fundamentally different natures of a consensus-building system, which is the European system, and ours, which operates for all of us on the basis of majority. That drives very different behaviour; it drives different attitudes to scrutiny.3

The City of London Corporation described the EU’s process for scrutiny of legislative proposals:

The EU’s model of legislative scrutiny is also designed to balance the interests of 27 Member States. This means that the system is necessarily built on compromise and can fall captive to wider political debates and tensions between groupings in the Parliament. It also means that decision making, or indeed changing legislation that has been passed, can be a time consuming and difficult process. There may be an advantage to the UK that it can now be nimbler in its regulatory approach.4

We believe that there is now an opportunity to put in place a scrutiny process which is less bureaucratic and significantly more nimble.

4. We also concluded in our earlier Report that:

We believe that effective scrutiny of regulatory proposals should be carried out through a targeted approach … If any matter of public interest were to arise that we deemed sufficiently important to scrutinise in more detail, or indeed challenge, we would do so.

We envisage that scrutiny would be both “ex-ante” and “ex post”. “Ex-ante” scrutiny could be based upon expert analysis of draft texts, together with an exploration of representations made by industry stakeholders, consumer representatives and others, with robust challenge to the regulators when warranted. “Ex post” scrutiny might entail reviews of the impact of regulations and an assessment of the balance struck between protection for the consumer and effective operation for the industry.5

5. We also concluded that:

We do not see a clear need for the creation of a new committee or a new independent body to carry out this work. It would seem a more efficient use of Parliamentary resources to use the structures that are already available in both Houses. Although the scrutiny task will be substantial, it will be an extended one as new regulations are drafted, rather than a short-term surge of activity. There is already expertise in select committees in the Commons and the Lords, and both have the power to appoint specialist advisers and commission research.6

6. The Treasury maintains a neutral role on who should carry out scrutiny and how. The Economic Secretary to the Treasury, John Glen MP, said in his response to our report:

Finally, while I note the Committee’s conclusion that they do not see a clear need for the creation of a new committee or a new independent body, I would also like to reiterate that it is rightly a matter for Parliament to consider the appropriate structure for its scrutiny. 7

7. This Report sets out in more detail how we will examine new regulatory proposals for financial services.

The task

8. There are several sources of regulatory texts for financial services. At the highest level, the overall policy framework within which regulators will operate is the responsibility of the Treasury and is set in primary or secondary legislation, which undergoes the scrutiny processes established by Parliament. The other two main sources of regulation are the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA), although the Bank of England itself has regulatory responsibility in certain areas, such as in its role as the UK resolution authority.8

9. Many areas of regulation in financial services are in fields which have been within the competence of UK regulators since before the UK’s exit from the EU. Some such proposals have received scrutiny through the Committee’s regular inquiry work or through accountability sessions with the FCA or the PRA. Previous Treasury Committees have looked at certain regulatory proposals in significant detail, notably Solvency II.9

10. The number of regulatory initiatives will grow as regulators assume responsibility for drafting measures that would previously have been drafted by the European Commission. The FCA expects to inherit responsibility for about 40 “files” (to use EU terminology) or subject areas. The scale of the scrutiny task will depend partly on whether a regulator adopts a largely “lift and shift” approach, adapting existing EU regulation only minimally as necessary, or whether it takes the opportunity to reshape regulation significantly, within the parameters set by Parliament. There will be an initial stage of integration into the existing regulatory framework—and for the FCA at least that will be phased over several years—followed by long-term maintenance and updating.

11. The Treasury, the Bank of England, the FCA, the PRA, the Financial Reporting Council and the Pensions Regulator publish jointly a Regulatory Initiatives Grid every six months, setting out work to develop their regulatory approach, whether through changes to rules or to guidance. The latest issue was in May 2022.10

12. The latest Regulatory Initiatives Grid lists 133 individual strands of work, many of which have been carried over from previous Grids and previous years. Not all of the work strands are led by regulators: some are led by the Treasury and may lead to primary or secondary legislation, which will be subject to the scrutiny processes of both Houses. Some are reviews with no immediate regulatory outcome, or lead to guidance or codes of practice with no legal effect, or are conducted mainly by regulators for which other committees might take the lead in scrutiny (such as BEIS Committee for proposals relating to audit and accountancy, or the Work and Pensions Committee for some proposals relating to pensions regulation).

13. The standard process for significant changes to regulatory texts, or for the evolution of new texts, may fall into three stages:

  • In some cases a discussion paper, describing the field in which the regulator is considering change, setting out the case for change, and testing the water with stakeholders;
  • A consultation paper (maybe a few months later), with draft text for comment, and an explanation of the thinking behind the draft text; and
  • A policy statement, (maybe several months later), setting out the regulator’s decision and a timetable for implementation, so that stakeholders can prepare.

Our approach

14. We have yet to see the full impact of the UK’s departure from the European Union on the flow and volume of regulatory proposals in financial services. However, we are in no doubt that the transfer of responsibility for regulatory proposals from the EU to UK regulators will require a significant new effort in scrutiny by Parliament.

15. We believe that during the period following the transfer of responsibility, each proposal from the FCA, the PRA and the Bank of England which will have legal effect should, at the very least, be assessed for its likely impact upon service providers and consumers. Each proposal, including those where the regulator appears to have taken a largely “lift and shift” approach, should be considered from a number of perspectives:

  • Is the policy justified and desirable? Is the balance between service providers, consumers and others the right one? Do the benefits outweigh any drawbacks?
  • Is the regulator acting within their delegated power?
  • Is the drafting of the necessary standard?

16. We believe that the most effective point for us to intervene in the development of financial services regulatory proposals would normally be the consultation paper stage, when proposals have crystallised into draft texts but when there is still scope for influence through amendment (or indeed pressure to abandon the proposal).

17. We would take a decision, in each case, on whether the proposal merited close examination, probably through a call for written submissions, oral evidence and perhaps leading to a report; or whether we might begin with written questions to the regulator; or whether we might cover the proposal in the course of other work (such as a general “accountability session” with the relevant regulator). In some cases, we might decide that we need not undertake detailed scrutiny but would nonetheless be alert to concerns raised by stakeholders about possible flaws in the proposal.

18. We noted in our Report, The Future Framework for Regulation of Financial Services,11 that we have been consistent in our regular monitoring of the work of the Financial Conduct Authority and of the Prudential Regulation Authority, the extent to which they meet the objectives set for them by Parliament, and their responsiveness to consumer expectations. We concluded that there is a strong logic in aligning the scrutiny of draft regulations and policy proposals with that of policy implementation and the day-to-day work of the regulators. We will therefore continue to integrate scrutiny of regulatory proposals into our mainstream work, when relevant.

19. We are commencing this scrutiny effort with immediate effect. We are currently developing our existing sifting processes, so as to identify regulatory proposals which should be prioritised for scrutiny; and we will for example examine in detail the proposal by the Prudential Regulation Authority for a “Strong and Simple Framework”.12 This would be a major change in prudential policy applying to banks and building societies: it would seek to “simplify the prudential framework for non-systemic domestic banks and building societies, while maintaining their resilience”. We plan to invite written submissions and to take oral evidence on the proposal before the Summer Recess.

20. We will also establish a sub-committee to take the lead on scrutiny of regulatory proposals. The sub-committee would have the power to “send for persons, papers and records” and could seek written evidence and take oral evidence; and it could agree reports, which would then be reported to the full Committee which would consider them in turn. The sub-committee will take a view on what form of scrutiny is appropriate for each regulatory proposal, and will normally be the forum for oral evidence when that is merited. In order to allow maximum flexibility, we will initially appoint all members of our Committee to the sub-Committee, with the sub-committee chaired by the chair of the main Committee.

Resources for scrutiny

21. Work on scrutiny of financial services regulatory proposals will be a substantial addition to our existing programme of work. It will impact upon both members and staff of the Committee, and it is likely that we will need to call on more staff support, to assist in the analysis of proposals and their likely consequences.

22. Each select committee has its own staff team offering specialist support, and there is capacity within our existing staff team to assist in scrutiny of financial services regulatory proposals. But there are other sources of support from cross-cutting staff units with expertise in financial and legal matters, and in EU scrutiny. The Office of Speaker’s Counsel has confirmed that it is also able to assess proposals and to provide advice on whether regulators were acting within their powers, and on any deficiencies in drafting.

23. We also have the power to appoint Specialist Advisers and without any limit, who will be able to provide detailed and expert knowledge of the field, and who could assist in analysis of proposals.

24. We will bring together these sources of expertise and analytical skill into a Financial Services Scrutiny Unit, which will assess each regulatory proposal, and offer advice to the Committee on its likely impact and fitness for implementation and on what level of scrutiny might be appropriate. The Unit will also serve as a single contact point for stakeholders. The Unit could be expanded as required, as demand becomes clearer through time.

25. In due course, and in the light of experience of the volume and flow of new regulatory proposals, we will need to take a view on whether the House should recruit new permanent staff to assist in the scrutiny effort. In making any case for new resources, we would point to the fact that the Committee is expanding its role in examining regulatory proposals and is taking on a function formerly carried out by the European Parliament and its ECON Committee.

An effort across Parliament

26. We anticipate that others across Parliament will want to devote time to scrutiny of individual regulatory proposals, or of the overall approach taken by regulators. We would strongly welcome and encourage such scrutiny by other select committees in both Houses, where relevant within their remit. We noted in our report on the Future Framework for the Regulation of Financial Services, published in July 2021, that there is a very significant body of relevant expertise in both the House of Lords Economic Affairs Committee and the House of Lords Industry and Regulators Committee.13 Some proposals in the Regulatory Initiatives Grid produced twice-yearly by the regulators fall within policy areas for which departments other than the Treasury hold responsibility, and for which Commons select committees other than the Treasury Committee might take a lead in scrutiny.

27. In some cases, joint working may be the most appropriate vehicle for scrutiny. The House’s Standing Orders already offer the scope for this: Standing Order No. 137A enables a committee or a sub-committee to meet concurrently with any committee or sub-committee of either House of Parliament for the purposes of deliberating or taking evidence; and it also enables a committee to invite individual members of other Commons select committees14 to attend meetings and (at the discretion of the Chair) ask questions of witnesses and otherwise participate in proceedings.

28. Clearly, our approach to scrutiny of regulatory proposals will evolve over time and with experience, and we will maintain a flexible approach.

29. This report is a statement of our intentions, to inform Parliament. It contains no observations or recommendations which require a response by a Government department or by any other body.

Formal minutes

Monday 13 June 2022

Members present:

Mel Stride, in the Chair

Rushanara Ali

Harriett Baldwin

Anthony Browne

Gareth Davies

Emma Hardy

Kevin Hollinrake

Julie Marson

Alison Thewliss

Draft Report (Future Parliamentary scrutiny of financial services regulations) proposed by the Chair, brought up and read.

Ordered, That the Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 29 read and agreed to.

Resolved, That the Report be the Second Report of the Committee to the House.

Ordered, That the Chair make the Report to the House.

Ordered, That embargoed copies of the Report be made available, in accordance with the provisions of Standing Order No. 134.

Adjournment

[Adjourned until Wednesday 15 June 2022 at 2.00 pm


Witnesses

The following witnesses gave evidence. Transcripts can be viewed on the inquiry publications page of the Committee’s website.

Wednesday 27 January 2021

Lord Hill of Oareford, Former EU Commissioner for financial services, European Commission; Baroness Bowles of Berkhamsted, Former Chair of ECON Committee, European Parliament; Dr Kay Swinburne, Former Member of ECON Committee, European Parliament, Vice Chair of Financial Services, KPMGQ1–55

Monday 26 April 2021

Edwin Schooling Latter, Director of Markets and Wholesale Policy & Supervision, Financial Conduct Authority; Vicky Saporta, Executive Director of the Prudential Policy Directorate, Prudential Regulation AuthorityQ56–121

Wednesday 26 May 2021

John Glen MP, Economic Secretary to the Treasury, HM Treasury; Gwyneth Nurse, Director of Financial Services, HM TreasuryQ122–196

Monday 13 September 2021

Richard Dudley, CEO Global Broking Centre, Aon UK; David Sansom, Chief Risk Officer, Lloyd’s of London; Charlotte Clark CBE, Director of Regulation, Association of British Insurers (ABI)Q197–244

Chris Cummings, CEO, Investment Association; Sir Douglas Flint CBE, Chairman, Abrdn; Philip Reed, General Counsel, Independent Franchise Partners LLPQ245–282

Monday 25 October 2021

Anne Boden, Chief Executive Officer, Starling Bank; John Collins, Chief Legal and Regulatory Officer, Santander UK; Matthew Conway, Director for Strategy and Policy, UK Finance; David Livingstone, Chief Executive Officer, Europe, Middle East and Africa, Citigroup; Nigel Terrington, Chief Executive Officer, Paragon Banking GroupQ283–339

Monday 06 December 2021

Christian Faes, Chair, Fintech Founders, Executive Chairman and co-founder, LendInvest; Michael Moore, Director General, British Private Equity and Venture Capital Association (BVCA); Stuart Williams, President, ICE Futures EuropeQ340–416

Monday 17 January 2022

Martin Coppack, Director, Fair By Design; Claire Tunley, Chief Executive, Financial Services Skills Commission; Professor David Aikman, Director, Qatar Centre for Global Banking and Finance, Professor of Finance (Practice), King’s College LondonQ417–532

Monday 21 February 2022

Vicky Saporta, Executive Director, Prudential Policy Directorate, Prudential Regulation Authority; Sheldon Mills, Executive Director, Consumers and Competition, Financial Conduct Authority; Edwin Schooling Latter, Director of Wholesale Markets, Financial Conduct Authority; Christina Segal-Knowles, Executive Director for Financial Markets Infrastructure, Bank of EnglandQ533–616

Wednesday 02 March 2022

John Glen MP, Economic Secretary, HM Treasury; Gwyneth Nurse, Director General, Financial Services, HM Treasury; Guy Opperman MP, Minister for Pensions and Financial Inclusion, Department for Work and PensionsQ617–724


Published written evidence

The following written evidence was received and can be viewed on the inquiry publications page of the Committee’s website.

FFS numbers are generated by the evidence processing system and so may not be complete.

1 Aikman, Professor David (Director, Qatar Centre for Global Banking and Finance; and Professor of Finance (Practice), King’s College London) (FFS0094)

2 Aldermore Bank (FFS0007)

3 Amigo Loans (FFS0060)

4 Anonymised (FFS0001)

5 Anonymous submitter (FFS0026)

6 Anonymous submitter (FFS0070)

7 Anonymous submitter (FFS0056)

8 Aon UK (FFS0035)

9 Association of British Insurers (FFS0062)

10 Association of Investment Companies (FFS0010)

11 Aviva (FFS0049)

12 Aviva (FFS0009)

13 BVCA (FFS0072)

14 Bank of England (FFS0080)

15 Barclays (FFS0066)

16 Bavoso, Dr Vincenzo (Senior Lecturer in Commercial Law, Law School, University of Manchester) (FFS0023)

17 ClientEarth (FFS0077)

18 Confederation of British Industry (FFS0025)

19 Consumer Credit Trade Association (CCTA) (FFS0029)

20 Coppack, Martin (Director, Fair By Design) (FFS0093)

21 Credit Suisse (FFS0091)

22 Cummings, Chris (Chief Executive, The Investment Association) (FFS0087)

23 Envestnet Yodlee (FFS0011)

24 Euroclear UK & Ireland Limited (FFS0028)

25 FCA Practitioner Panel (FFS0037)

26 Federated Hermes Inc. (FFS0003)

27 Finance & Leasing Association (FFS0002)

28 Finance Innovation Lab (FFS0031)

29 Financial Conduct Authority (FFS0096)

30 Financial Conduct Authority (FFS0027)

31 Financial Inclusion Centre (FFS0073)

32 Financial Inclusion Commission (FFS0075)

33 Financial Services Skills Commission (FFS0034)

34 Finanical Services Consumer Panel (FFS0064)

35 Fintech Founders (FFS0092)

36 Fintech Founders (FFS0041)

37 Funding Circle (FFS0059)

38 Hall, Professor Sarah (Professor of Economic Geography and Senior Fellow, University of Nottingham and UK in a Changing Europe); and Dr Martin Heneghan (Research Fellow, University of Nottingham) (FFS0032)

39 Hannaford Associates Ltd (FFS0019)

40 Independent Franchise Partners LLP (FFS0085)

41 Innovate Finance (FFS0052)

42 Intercontinental Exchange (FFS0058)

43 International Regulatory Strategy Group (FFS0048)

44 Investment & Life Assurance Group (FFS0054)

45 Lane Clark and Peacock (FFS0012)

46 Legal & General Group (FFS0020)

47 Lloyd’s (FFS0086)

48 Lloyd’s (FFS0047)

49 Loan Market Association (FFS0021)

50 London Market Group (FFS0084)

51 London and International Insurance Brokers’ Association (LIIBA) (FFS0042)

52 Lyddon Consulting Services Limited (FFS0017)

53 Mid-sized banks (FFS0083)

54 New City Initiative (FFS0014)

55 Office of the City Remembrancer, City of London Corporation (FFS0069)

56 Office of the City Remembrancer, City of London Corporation (FFS0045)

57 Paragon Banking Group (FFS0088)

58 Pension Insurance Corporation plc; and New Financial LLP (FFS0036)

59 Positive Money (FFS0044)

60 PwC (FFS0050)

61 Quoted Companies Alliance (FFS0022)

62 Quoted Companies Alliance (FFS0015)

63 Saporta, Vicky (Executive Director, Prudential Policy Directorate, Prudential Regulation Authority) (FFS0095)

64 ShareAction (FFS0061)

65 Spotlight on Corruption (FFS0079)

66 Swiss Euro Clearing Bank (FFS0016)

67 The Consumer Council (FFS0030)

68 The Investment Association (FFS0081)

69 The Money Charity (FFS0038)

70 The True and Fair Campaign (FFS0074)

71 TheCityUK (FFS0068)

72 Third Generation Environmentalism (E3G) (FFS0063)

73 Turnbull, Dr Shann (Principal, International Institute for Self-governance) (FFS0043)

74 Tyfield, Sam (FFS0013)

75 UK Finance (FFS0055)

76 UK Sustainable Investment and Finance Association (UKSIF) (FFS0051)

77 United Kingdom Shareholders’ Association (UKSA); and UK Individual Shareholders Society (ShareSoc) (FFS0067)

78 Vanguard Asset Management, Limited (FFS0024)

79 White, Martin (Director, United Kingdom Shareholders’ Association (UKSA)) (FFS0082)

80 Zurich Insurance (FFS0078)


List of Reports from the Committee during the current Parliament

All publications from the Committee are available on the publications page of the Committee’s website.

Session 2022-23

Number

Title

Reference

1st

Future of financial services regulation

HC 141

Session 2022–23

Number

Title

Reference

1st Special Report

Defeating Putin: the development,implementation and impact of economic sanctions on Russia: Government Response to the Committee’s Twelfth Report of Session 2021–22

HC 321

Session 2021–22

Number

Title

Reference

1st

Tax after coronavirus: the Government’s response

HC 144

2nd

The appointment of Tanya Castell to the Prudential Regulation Committee

HC 308

3rd

The appointment of Carolyn Wilkins to the Financial Policy Committee

HC 307

4th

The Financial Conduct Authority’s Regulation of London Capital & Finance plc

HC 149

5th

The Future Framework for Regulation of Financial Services

HC 147

6th

Lessons from Greensill Capital

HC 151

7th

Appointment of Sarah Breeden to the Financial Policy Committee

HC 571

8th

The appointment of Dr Catherine L. Mann to the Monetary Policy Committee

HC 572

9th

The appointment of Professor David Miles to the Budget Responsibility Committee of the Office for Budget Responsibility

HC 966

10th

Autumn Budget and Spending Review 2021

HC 825

11th

Economic crime

HC 145

12th

Defeating Putin: the development, implementation and impact of economic sanctions on Russia

HC 1186

1st Special

Net Zero and the Future of Green Finance: Responses to the Committee’s Thirteenth Report of Session 2019–21

HC 576

2nd Special

The Financial Conduct Authority’s Regulation of London Capital & Finance plc: responses to the Committee’s Fourth Report of Session 2021–22

HC 700

3rd Special

Tax after coronavirus: response to the Committee’s First Report of Session 2021–22

HC 701

4th Special

The Future Framework for Regulation of Financial Services: Responses to the Committee’s Fifth Report

HC 709

5th Special

Lessons from Greensill Capital: Responses to the Committee’s Sixth Report of Session 2021–22

HC 723

6th Special

The appointment of Professor David Miles to the Budget Responsibility Committee of the Office for Budget Responsibility: Government response to the Committee’s Ninth Report

HC 1184

7th Special

Autumn Budget and Spending Review 2021: Government Response to the Committee’s Tenth Report

HC 1175

8th Special

Economic Crime: responses to the Committee’s Eleventh Report

HC 1261

Session 2019–21

Number

Title

Reference

1st

Appointment of Andrew Bailey as Governor of the Bank of England

HC 122

2nd

Economic impact of coronavirus: Gaps in support

HC 454

3rd

Appointment of Richard Hughes as the Chair of the Office for Budget Responsibility

HC 618

4th

Appointment of Jonathan Hall to the Financial Policy Committee

HC 621

5th

Reappointment of Andy Haldane to the Monetary Policy Committee

HC 620

6th

Reappointment of Professor Silvana Tenreyro to the Monetary Policy Committee

HC 619

7th

Appointment of Nikhil Rathi as Chief Executive of the Financial Conduct Authority

HC 622

8th

Economic impact of coronavirus: the challenges of recovery

HC 271

9th

The appointment of John Taylor to the Prudential Regulation Committee

HC 1132

10th

The appointment of Antony Jenkins to the Prudential Regulation Committee

HC 1157

11th

Economic impact of coronavirus: gaps in support and economic analysis

HC 882

12th

Tax after coronavirus

HC 664

13th

Net zero and the Future of Green Finance

HC 147

1st Special

IT failures in the financial services sector: Government and Regulators Responses to the Committee’s Second Report of Session 2019

HC 114

2nd Special

Economic Crime: Consumer View: Government and Regulators’ Responses to Committee’s Third Report of Session 2019

HC 91

3rd Special

Economic impact of coronavirus: Gaps in support: Government Response to the Committee’s Second Report

HC 662

4th Special

Economic impact of coronavirus: Gaps in support: Further Government Response

HC 749

5th Special

Economic impact of coronavirus: the challenges of recovery: Government Response to the Committee’s Eighth Report

HC 999

6th Special

Economic impact of coronavirus: gaps in support and economic analysis: Government Response to the Committee’s Eleventh Report

HC 1383


Footnotes

1 Speech delivered on 20 May 2022 at Queen Mary University, London. See Listening up to level up – regulating finance for the whole of the UK | FCA

2 Treasury Committee, Fifth Report of Session 2021–22, The Future Framework for Regulation of Financial Services, HC 147, para 77

3 Oral evidence taken before the Treasury Committee on 27 January 2021, HC (2021–22) 147, Q5 [Chair]

4 Office of the City Remembrancer, City of London Corporation (FFS0045)

5 Treasury Committee, Fifth Report of Session 2021–22, The Future Framework for Regulation of Financial Services, HC 147, paras 78 and 85

6 Treasury Committee, Fifth Report of Session 2021–22, The Future Framework for Regulation of Financial Services, HC 147, para 86

7 Treasury Committee, Fourth Special Report of Session 2021–22, The Future Framework for Regulation of Financial Services: Responses to the Committee’s Fifth Report, HC 709

8 Bank of England: Statement on operational independence of the resolution and supervision functions of the Bank of England, January 2021

9 Treasury Committee, Third Report of Session 2017–19, The Solvency II Directive and its impact on the UK Insurance Industry, HC 324

10 Financial Conduct Authority, Regulatory Initiatives Grid, May 2022

11 Treasury Committee, Fifth Report of Session 2021–22, The Future Framework for Regulation of Financial Services, HC 147, para 88

12 Bank of England, The Strong and Simple Framework: a definition of a Simpler-regime Firm, Consultation Paper 5/22

13 Treasury Committee, Fifth Report of Session 2021–22, The Future Framework for Regulation of Financial Services, HC 147, para 84

14 With the caveat that the Standing Order applies only to committees that have the power to send for persons, papers and records. In practice, this encompasses almost all Commons select committees.