Chapter 2: Financial services
The TCA and the end of the transition period
13.The financial services sector is a major contributor to the UK economy. TheCityUK’s December 2020 report, Key Facts About the UK as an International Financial Centre 2020, calculated that in 2019 the UK’s trade surplus in financial services was $77 billion (£55 billion), rising to $102 billion (£73 billion) with the inclusion of related professional services. In the same year, the UK was the world’s largest net exporter of financial services, ahead of the United States (£43 billion), Switzerland (£17 billion) and Singapore (£17 billion). Some 34.3% of UK financial services exports went to EU countries, and 30.2% to the United States. The report noted that the UK’s strength in financial services “is derived not only from the high volume and value of transactions, but also the breadth of services and expertise available—the ‘ecosystem’ effect.”23 Financial services contributed £75.6 billion to public finances in the UK through taxes in 2019/20, amounting to more than 10% of total UK tax receipts.24
14.The TCA’s short section on financial services states that the UK and the EU shall:
- apply internationally agreed standards in the financial services sector;
- permit companies from the other Party to supply any new financial service as they would a domestic company;
- ensure that any relevant self-regulatory organisation observes obligations under other provisions of the TCA; and
- grant access to payment and clearing systems and official funding and refinancing facilities to financial services suppliers of the other Party established in their territories.
15.It also contains a “prudential carve-out”, stating: “Nothing in this Agreement shall prevent a Party from adopting or maintaining measures for prudential reasons.”25
16.The Government told us the TCA “will provide a baseline of rights and protections for financial services firms providing services in the UK and the EU. It enshrines the core non-discriminatory provisions set out under the World Trade Organisation (WTO) into our bilateral agreement, ensuring that financial services firms receive fair treatment.”26
17.In the words of TheCityUK, “For financial services, the TCA and its ancillary texts are relatively non-prescriptive, leaving much to be determined by the attitudes and plans of the parties.” This creates “a degree of uncertainty”, as important decisions about the future relationship remain “relatively open, with room for a spectrum of outcomes for UK financial services suppliers ranging from the favourable to the disadvantageous”.27
18.Miles Celic, CEO, TheCityUK, said “the fact that there is a deal is very welcome”, both because “the people who are covered much more by a deal tend to be our clients”, and because the avoidance of “acrimony” means “we have in place a foundation or platform that we can build on—a launchpad for further engagement”.28 UK Finance similarly described the fact of an agreement as “important, because it provides a governance structure for the services relationship and is the first step to rebuilding the trust and close cooperation that will be important in supporting cross-border trade and investment in financial services”.29
19.The absence of substantial financial services provisions in the TCA is unfortunate but not unexpected. Nick Collier, Managing Director (Brussels), City of London Corporation, described the lack of “more ambition” as “disappointing”.30 Miles Celic noted that “decisions on equivalence and the big ticket decisions on regulation will be taken unilaterally. There is no mechanism for joint decision-making.”31
20.Nick Collier pointed to “some crumbs of comfort” in the TCA, such as the “nice reference … to working together on international standards”, as well as the absence of both a “cross-retaliation mechanism applying to financial services”, and a ‘most favoured nation’ provision, which means that “potentially we can do deeper deals with others now that we have taken back control of our trade policy”.32 The Scottish Government, although broadly critical of the TCA as a replacement for EU membership, described the provision facilitating trade in emerging financial services technologies as something “of interest to the Scottish Fintech sector”, which “may present an opportunity … to maintain opportunities in new and emerging markets”.33
Loss of passporting rights
21.As long ago as December 2016 the European Union Committee warned that equivalence arrangements would be an “inadequate substitute” for passporting rights, whereby an authorisation issued by one EU Member State is automatically recognised by all others.34 Our concern was justified. UK Finance warned that the loss of passporting “sharply narrows the scope for cross-border contracting in EU-UK financial services trade”,35 while Professor Sarah Hall and Martin Heneghan, University of Nottingham, described the loss as “significant because passporting had been an important element in stimulating the export success of financial services.”36 The Loan Market Association warned that “the TCA’s lack of provisions to mitigate” the loss of passporting “will negatively affect the ability of UK financial institutions to lend out to the EU27”, and “may lead to a reduction in the UK’s market share”.37
22.The end of passporting rights means that cross-border trade between UK firms and EU customers and clients will, to cite TheCityUK, “rely principally on the UK securing EU equivalence decisions, which are much less comprehensive, or … complying with Member State market access regimes”.38
Business preparedness
23.The lack of short-term disruption at the end of the transition period is testament to the sector’s extensive preparations. Miles Celic said the sector had “hoped for the best but prepared for the worst”, and had expended “huge amounts of time, resource and effort … working closely with regulators and with government, in the UK and across the EU, to make sure that all the preparations that could be made were made”.39
24.Nick Collier provided some detail on these preparations: “UK-based firms offering services into the EU have all had to seek to set up new licensed entities on the continent, if they did not already have them, and to repaper their EU clients to those entities.”40 The Scottish Government noted that among the financial services providers to have “shifted substantial parts of their business to affiliates established inside the Single Market” were Scottish Widows (Luxembourg), Standard Life Aberdeen (Dublin) and Royal Bank of Scotland (Amsterdam).41
Relocation of financial services activity
25.Although it has yet to fully materialise, we heard continuing concern over the long-term movement of financial services jobs from the UK to EU countries. Miles Celic said job shifts would take place “not at the cliff-edge point at which we left the EU or we left the transition period, but as the implications of the shift in business take place”. Nick Collier noted that the COVID19 pandemic had constrained physical movement, warning: “I do not think we have yet seen the full shake-out of relocations from firms.”42 Conversely, approximately 1,000 EU-based financial services firms without an existing UK presence had applied for permission to operate in the UK since the Temporary Permissions Regime was launched in 2018.43 Of course, the COVID-19 pandemic means that it is difficult to compare inward investment with previous years.
26.Miles Celic said that the extent of any shift of wider financial services activity to the EU in the long term would depend “on what happens on decisions on equivalence”, on EU reforms to its “regulatory approach”, and on the Treasury’s approach to “modernising and continuing to make the UK an attractive place to come and invest and do business”.44 He pointed to indications that New York—the other “major international financial centre”, alongside London—”is going to be one of the big winners” and has already started to attract some UK activity.45 Similarly, Barclays CEO Jes Staley said London should focus on competing with “not Frankfurt or Paris … [but] New York and Singapore”.46
27.Financial services are an important part of the UK economy. The sector contributes £132 billion to the UK, amounting to 6.9% of total economic output, and contributed more than 10% of UK tax receipts in 2019/20. While the absence of substantive financial services provisions in the TCA was disappointing, it was not a surprise, and the sector was well prepared for 1 January. But delays to key decisions about the future relationship, particularly on equivalence, mean that financial services remain in a period of uncertainty.
28.The results of the UK’s exit from the passporting regime have included the movement of some activity to the EU and firms facing the challenges involved in navigating different market access requirements in each Member State. We are concerned that it may, over time, lead to a substantial shift of people and assets out of the UK.
Framework for cooperation
29.Alongside the TCA, the Parties published a Joint Declaration on Financial Services Regulatory Cooperation Between the European Union and the United Kingdom, in which they commit to agreeing a memorandum of understanding establishing the framework for structured regulatory cooperation on financial services by March 2021.47 At the time of writing, the memorandum of understanding was yet to be published.
30.The Government told us that future UK-EU cooperation “is likely to involve regular dialogue: both high-level, formal meetings between UK and EU officials, and more regular working-level engagement”. It added: “We are seeking arrangements that reflect the fact that the UK and the EU are large and close financial services jurisdictions and are aligned with what we aim to achieve with other similar jurisdictions.”48
31.We welcome the planned creation of this framework, which the EU Financial Affairs Sub-Committee recommended in its 27 March 2020 letter to the Chancellor.49 Nick Collier described the text of the joint declaration as “very clear” and “very sensible”, and hoped for “consultation with industry on the whole dialogue from both sides”.50 Standard Life Aberdeen, echoing this wish, added that the dialogue should have “a strong focus on equivalence determinations”, and provide “certainty to all investors, including on the granting and withdrawal of equivalence decisions”, by making “decisions on each side as foreseeable and predictable as possible”.51
32.The memorandum of understanding will facilitate regulatory dialogue and cooperation, but Miles Celic stressed the need to be “clear-eyed and realistic about what it is and what it is not”, as it will have “negligible legal effect”. He added that it is “explicitly not a joint decision-making mechanism”. Rather, it is “a necessary but not sufficient part of the longer-term relationship between regulators”, which must “continue to be based on trust and mutual respect”.52 TheCityUK added that the memorandum of understanding “should serve as part of the effort to establish a positive post-Brexit working relationship between the two sides”.53
33.It is clear that regulators participating in this dialogue will do so from a similar starting point, which should provide for smooth cooperation—at least initially. Miles Celic noted: “The regulators know each other on both sides; they have all sat on the same committees and worked on the same legislation.” Nick Collier noted that regulators and practitioners on both sides also face “various common major challenges”, such as pandemic recovery, sustainability and digitisation. He said the EU is confident that it can have “a very positive, deep and fruitful dialogue with its UK counterparts”, and “specifically, that we can have a deeper dialogue than the EU currently has with the US or with Japan”.54
34.Mutual trust will be key to a successful UK-EU relationship in financial services. It would be “deeply regrettable, and absolutely not in the interests of either side”, Miles Celic said, if they were to “end up with an ongoing scratchy, slightly pedantic relationship that goes on for year after year after year, with constant negotiation, renegotiation and bargaining”. UK Finance agreed: “The precise form of this dialogue is less important than the general levels of trust, collaboration and transparency that it should express.” It called for “high-level strategic agenda-setting at the level of Ministers and Senior Commission officials”, accompanied by “a constant stream of activity involving policymakers, regulators, parliamentarians, civil society and firms”.55 The City of London Corporation recommended a “permanent EU/UK Forum … co-chaired by representatives of HM Treasury and the European Commission”.56
35.We welcome the plan for structured regulatory cooperation in financial services, which we hope will be a solid foundation for future UK-EU relations. However, this dialogue will be worth little if it is not based on transparency and trust. We urge the Government and regulators to pursue as deep a level of cooperation, predictability and information sharing as possible. The Government should consult regularly to ensure it is representing the UK financial services sector’s interests and priorities in the dialogue.
Equivalence
36.By granting equivalence in a certain area of financial services, the European Commission or UK Government affirm that a foreign jurisdiction’s rules and supervision are equivalent to their own and that providers of financial services from the other Party can therefore benefit from the same market access as domestic providers. This is a unilateral decision that sits formally outside any bilateral negotiations. The Government has long argued in favour of comprehensive mutual equivalence findings between the UK and the EU, based on the broad outcomes produced by the other Party’s rules rather than a line-by-line replication of those rules. On 9 November 2020, HM Treasury announced that the UK would grant equivalence to the EU in a wide range of areas.
37.The Commission maintains that, having “assessed the UK’s replies to the Commission’s equivalence questionnaires in 28 areas”, it requires “further clarifications” about “how the UK will diverge from EU frameworks”, as well as “how it will use its supervisory discretion regarding EU firms and how the UK’s temporary regimes will affect EU firms”.57
38.The Joint Declaration on Financial Services Regulatory Cooperation Between the European Union and the United Kingdom states that, within the framework for structured regulatory cooperation on financial services, the UK and the EU will “discuss, inter alia, how to move forward on both sides with equivalence determinations between the Union and United Kingdom, without prejudice to the unilateral and autonomous decision-making process of each side”.58
Equivalence for UK central counterparties
39.In recent years, the EU has granted a number of financial services equivalence decisions to other jurisdictions, such as Australia (17 decisions), Canada (18) and the United States (21).59 But the only two positive equivalence decisions the EU has so far granted the UK are an 18-month extension for central counterparties (CCPs), which take on the credit risk between the parties to a transaction and provide clearing services for trades in various financial products, and a six-month extension for central securities depositories, which hold securities such as shares to facilitate transfer of ownership. A Communication on 19 January hinted that the Commission would prefer to avoid granting indefinite equivalence to UK CCPs, stating that “there is a clear expectation that Union clearing members reduce their exposures to UK CCPs”, and that “EU CCPs need to build up their clearing capability”.60
40.At present, a large proportion of euro-denominated clearing takes place through UK CCPs, which therefore remain of great importance to the EU. London Stock Exchange Group told us that any policy to deny recognition of UK CCPs “would have detrimental effects on EU financial stability” and “increase systemic risk for EU firms and damage their competitiveness”. For example, it would “undermine the European Commission’s and ECB’s efforts to increase the international role of the Euro” and “discourage the clearing and overall use of the Euro on international markets, creating fragmenting clearing and potentially leading to more regionalised use of the Euro”.61
41.The interconnectedness of the financial services sector is such that most parts of it would benefit from further positive equivalence determinations. For example, Standard Life Aberdeen that said while it is “not directly dependent on any element of the EU’s equivalence regime for continuity of our operations”, the absence of equivalence “creates complexities in market infrastructure which impacts the routing of trade flows and regulatory reporting”.62
EU reluctance to grant equivalence
42.Witnesses agreed that the EU making further positive equivalence determinations in the short term was desirable but unlikely. Any further decisions are likely to be in areas where the EU judges UK equivalence to be in its own interest. Nick Collier expressed hope that regulatory cooperation might “unlock” some equivalence decisions, but warned that “it is not an automatic linkage”.63
43.There appear to be at least two reasons for the EU’s reluctance to grant equivalence in more areas. The first is the Commission’s apparent expectation that the UK will diverge from the EU rules it inherited at the end of the transition period. Miles Celic said there was “misplaced concern” in the EU that the UK “will go down some bonfire of regulations route”.64 Recounting a meeting in late 2020 at which “a very senior EU official” said the UK was “going to diverge from EU rules”, Miles Celic said that he did not expect divergence to be “particularly radical, certainly not in the short term”, though there may be “greater shifts” in areas such as “fintech, data and green—the future areas of the industry that we are evolving into”.65
44.The second reason, as implied in the Commission’s stance on CCPs, is that the EU seeks to attract UK financial services activity to its own shores. Our witnesses viewed this as politicisation and, in Miles Celic’s words, “a market location policy rather than a market efficiency policy”.66 It was reported in February that Amsterdam had overtaken London as Europe’s leading share-trading venue,67 but this shift is unlikely to have a significant direct effect on UK or EU investors. In such areas, Nick Collier told us, it is “essentially a political decision not to grant equivalence to the UK platforms … not a technical decision”, and “where there is clearly a political push to onshore activity, particularly in euro assets, to build up the international role of the euro”, the EU is “using the lack of equivalence to force a lot of that business onshore”.68 He added that, in so doing, the EU would be blocking its own access to “all the international markets where London is very strong”, such as trade in commodities, international securities or foreign exchange derivatives.69
45.A third potential explanation for the EU’s stance on equivalence is that it may be seeking concessions in other, officially unrelated, areas. Miles Celic highlighted “the attempt to use equivalence, in the way the EU often does, as a further form of leverage in negotiations”.70 It is difficult to state with any certainty whether such concerns are well-founded.
Limitations of equivalence
46.While EU equivalence decisions are of great importance to the UK in some areas, such as CCPs, in others they are less essential, particularly because equivalence provides far less certainty and market access than UK financial services providers enjoyed before the end of the transition period. The Scottish Government observed that “equivalence provides firms with much less certainty” than passporting, because “it is normally granted for a limited duration and can be revoked at 30 days’ notice”.71 Moreover, some industries, such as insurance intermediaries, are not covered by an EU equivalence framework, which TheCityUK said leaves them “reliant on local law in each EU Member State”.72
47.The longer the UK is without EU equivalence decisions, the less important they become. Miles Celic warned that “the longer we do not have equivalence on the EU side, the more the concrete will set”. As companies incur the costs associated with securing regulatory licences and moving people and capital, he said, equivalence becomes less of a concern.73 Professor Sarah Hall and Martin Heneghan agreed that “equivalence is a perishable good and its value for UK financial services will decline over time”, as the potential costs of reversing contingency measures increase.74 In such a situation, it is conceivable that ‘accidental’ divergence will occur, with both Parties adopting regulatory measures suited for their own market without considering the impact on equivalence—although, as Miles Celic said, there is not currently much evidence of it, “because everybody is so sensitised to the relationship on both sides”.75
Future divergence
48.Divergence will take place on the EU as well as the UK side. Nick Collier stressed that the EU—”a giant sausage-making machine for legislation”—will itself “diverge from the status quo of today”. Indeed, on securities “it looks likely that the EU will deregulate and take out one of the tough rules on research unbundling that the UK put in, so they are diverging—downwards”.76 Miles Celic similarly cautioned that the EU “is also going through a process of changing its regulation”.77
49.Andrew Bailey, Governor of the Bank of England, has repeatedly stated that the UK should not “become a rule-taker”. On 6 January, he said that equivalence is not “the be-all and end-all” and that, “if the price of this is too high, I am afraid we cannot just go for it whatever”.78
Reforming the equivalence framework
50.Looking further ahead, witnesses hoped that the EU would reform its approach to equivalence. Nick Collier pointed out that provisions “built into many pieces of EU legislation were not designed for the UK. They were designed for recognising credit rating agencies in Asia or in the US, for example.”79 The bloc’s approach “is increasingly out of line with the international thinking”, which favours “relying on others’ rules that are not necessarily identical”. This was “surely the right way forward”.80 The Parties, he argued, should seek to “lock in some kind of mutual dependency” by using “deference”81—a more outcomes-based and less prescriptive approach.82
51.Miles Celic said there was recognition in the EU that it “will want to look at” the 30-day notice period for withdrawing some forms of equivalence, and consider introducing “some form of mechanism that recognises the reality that it is a process”. This may include, for example, a warning to third countries that they are close to diverging too far to maintain equivalence, giving them time to amend their legislation if necessary.83 Standard Life Aberdeen also saw merit “in encouraging both sides to warn the other about early concerns around determinations and providing an opportunity to respond to those concerns”.84
52.The UK financial services sector opposes the EU’s line-by-line approach to equivalence and supports the Government’s outcomes-based approach. We agree that broad positive equivalence determinations would best meet the needs of practitioners in both the UK and the EU, but recognise that in many areas the EU is unlikely to grant these without the UK sacrificing more decision-making autonomy than equivalence is worth.
53.We regret that the extension of equivalence for UK central counterparties (CCPs), which continue to provide an important service for EU practitioners, is time-limited. A longer-term equivalence decision for UK CCPs would better serve the interests of both Parties.
54.While recognising that this remains a unilateral decision, we believe the long-term interest of both the UK and the EU lies in a less prescriptive policy on market access, whether a reformed approach to equivalence or something closer to the non-discriminatory, outcomes-based deference model increasingly favoured globally.
Divergence, competitiveness and standards
55.The UK can now decide on its own model for financial services regulation, but witnesses were clear that the Government should not seek widespread and sudden change. Indeed, in evidence to the Committee in 2020, the Government itself insisted it would not seek a “bonfire of regulations” after the transition period.85
56.Jes Staley agreed that the UK should “not burn one piece of regulation” as it seeks to compete with global financial centres such as New York and Singapore.86 Miles Celic and Nick Collier said the financial services sector in the UK supports the approach the Government appears to be taking, which Miles Celic characterised as follows:
“You take a part of the rulebook that we have taken on board, or part of the directives or regulations that we have onshored, and say, ‘Great, this worked fantastically for a market of 28 countries, which was predominantly focused on its internal dynamics, but how do we tweak it? How do we fine-tune it? How do we get the screwdriver out and tighten one screw here and slightly loosen another screw there to meet the needs of a market of 66 million people that has a world-beating, very successful financial services industry, and help to drive that from the point of view of international competitiveness, hard-wiring that into the economic relationship with other countries?’”87
57.Such an approach, he argued, must “strike a balance between competitiveness, consumer protection, standards and so on”, as well as taking into account socioeconomic and sustainability factors.88 The UK should take advantage of “nimbler” regulation to innovate in emerging areas such as financial technology (fintech), “where the UK can absolutely take a leadership role”.89 Nick Collier concurred, stating that a more flexible UK “can and should move faster than the EU” in such areas, “doing the right thing more quickly and, hopefully, in a more expert way”.90
58.Seeking to attract more business to the UK by lowering standards would be a dangerous and counterproductive approach. As Miles Celic said, “You do not win through a race to the bottom. London is, and needs to remain, a kitemark of quality.” He added that there is “very little support in the industry” for the idea that “we can deregulate our way to success”.91
59.We welcome the Government’s assurance that there will be no bonfire of financial services regulations. We recognise that the UK and the EU will seek to change their regulatory regimes where it is in either Party’s interest, but call on the Government not to disregard the value of a close UK-EU relationship in financial services. Changes should be transparent and designed to enhance the attractiveness and competitiveness of the UK’s financial services sector.
The future regulatory landscape and parliamentary oversight
60.The relationship between Government, Parliament and regulators in the UK’s post-EU regulatory landscape is yet to be determined. The Government has started consultation on the future regulatory landscape and says it will set out a package of proposals later in 2021. It told us its proposals will see “a return to the practical use of [regulators’] existing rule-making powers under the Financial Services and Markets Act 2000”, which “has been eroded over the past twenty years as the EU has increasingly set very detailed, prescriptive requirements for FS [financial services] firms in legislation”. The Government considered that “independent, expert regulators, one of the key strengths of the UK framework, should be responsible for developing and maintaining the UK’s technical regulatory standards”. This should be balanced with “appropriate strategic policy input from Government and Parliament”, and “a greater role” for Parliament in holding the regulators to account. It added, though, that “the exact structures for this further scrutiny are first and foremost for Parliament to consider”.92
61.Nick Collier expressed support for a return to “principles-based regulation”, with “a lot of the details of regulation being delegated downwards”. Similarly, Miles Celic said that asking a UK parliamentary committee to assume the technical, granular role of the European Parliament’s Committee on Economic and Monetary Affairs “would be trying to hammer a square peg into a round hole”.93
62.Miles Celic called instead for a joint parliamentary committee drawing together Members of both Houses with financial services expertise, to provide “clear democratic parliamentary scrutiny of what Treasury and the regulators intend to do”.94 The City of London Corporation also recommended such a committee, which “would look in detail at specific pieces of financial services regulation”.95
63.The Financial Services Bill currently before Parliament pre-empts the Government’s proposals for the future regulatory landscape and will come into law before these plans are published. This is a missed opportunity. The return of greater powers to UK regulators allows for more flexible and innovative regulation but will require changes to the way Parliament scrutinises the regulations and holds the regulators to account.
64.The Government and regulators now hold significant power in setting financial services regulation. We welcome the House’s recent decision to establish a Select Committee on Industry and Regulators, which is an important step towards bringing greater parliamentary oversight to these decisions. However, this new Committee’s remit is broad and its resources are likely to be too limited to undertake dedicated scrutiny of the financial services sector. We recommend that the Liaison Committee considers further the merits of a committee dedicated to scrutiny of the financial services sector.
UK influence in setting standards
65.The UK’s strength in financial regulation means that, in the words of Miles Celic, it “could well be the swing voter” in future debates on global regulatory standards. He added that it would be “hugely in the national interest” for the Government to use the UK’s “regulatory diplomacy” to “make the case for open markets and free trade” in international forums, and the “louder and more persuasive and authoritative a voice the UK can have in those international forums, the better”.96
66.Andrew Bailey stressed in his Mansion House speech on 10 February that “the public goods of open economies, an open financial system and the stability of that system are global, not regional, in nature” and that it is “reasonable to think that a common framework of global standards combined with the common basis of the rules—since the UK transposed EU rules from the outset—would be enough to base equivalence on global standards.”97
67.The Government should use the UK’s innovative leadership to maintain high standards in financial services regulation on the global stage.
23 TheCityUK, Key facts about the UK as an international financial centre 2020, December 2020: https://www.thecityuk.com/assets/2020/Reports/8716847a2f/Key-facts-about-the-UK-as-an-international-financial-centre-2020.pdf [accessed 1 March 2021]
24 City of London Corporation, The total tax contribution of UK financial services in 2020, February 2021: https://www.cityoflondon.gov.uk/assets/Business/total-tax-contribution-2020.pdf [accessed 4 March 2021]
25 Trade and Cooperation Agreement between the European Union and the European Atomic Energy Community, of the one part, and the United Kingdom of Great Britain and Northern Ireland, of the other part (24 December 2020): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/948119/EU-UK_Trade_and_Cooperation_Agreement_24.12.2020.pdf [accessed 23 February 2021]
31 Ibid.
32 Ibid.
34 European Union Committee, Brexit: financial services (9th Report, Session 2016–17, HL Paper 81), para 55
36 Written evidence from Professor Sarah Hall and Martin Heneghan, University of Nottingham (FTS0029)
40 Ibid.
43 Bovill, ‘London to remain financial services centre of Europe’, 22 February 2021: https://www.bovill.com/london-remains-financial-service-centre-of-europe-final-numbers-show/ [accessed 4 March 2021]
46 BBC News, ‘Barclays urges UK to focus on US and Asia post Brexit’, 5 February 2021: https://www.bbc.co.uk/news/business-55939857 [accessed 4 March 2021]
47 European Commission, ‘Draft EU-UK declarations’, 26 December 2020: https://ec.europa.eu/info/sites/info/files/draft_eu-uk_declarations.pdf [accessed 23 February 2021]
49 Letter from Baroness Donaghy, Chair, EU Services Sub-Committee, to Rt Hon. Rishi Sunak MP, Chancellor of the Exchequer, 27 March 2020: https://committees.parliament.uk/publications/476/documents/1873/default/
57 European Commission, ‘Questions & Answers: EU-UK Trade and Cooperation Agreement’, 24 December 2020: https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_2532 [accessed 24 December 2020]
58 European Commission, Draft EU-UK declarations, 26 December 2020: https://ec.europa.eu/info/sites/info/files/draft_eu-uk_declarations.pdf [accessed 23 February 2021]
59 European Commission, Equivalence taken by the European Commission as of 10/02/2021: https://ec.europa.eu/info/sites/info/files/business_economy_euro/banking_and_finance/documents/overview-table-equivalence-decisions_en.pdf [accessed 23 February 2021]
60 Communication from the Commission to the European Parliament, the Council, the European Central Bank, the European Economic and Social Committee and the Committee of the Regions, COM(2021) 32, 19 January 2021
64 Ibid.
67 BBC News, ‘Brexit: London loses out as Europe’s top share trading hub’, 11 February 2021: https://www.bbc.co.uk/news/business-56017419 [accessed 4 March 2021]
74 Written evidence from Professor Sarah Hall and Martin Heneghan, University of Nottingham (FTS0029)
76 Ibid.
78 Oral evidence taken before the House of Commons Treasury Committee on 6 January 2021 (Session 2019–21), Q 7 (Andrew Bailey)
81 The G20 has promoted deference since 2013, when its leaders agreed that “jurisdictions and regulators should be able to defer to each other when it is justified by the quality of their respective regulatory and enforcement regimes, based on similar outcomes, in a non-discriminatory way, paying due respect to home country regulation regimes.”
85 Oral evidence taken before the EU Services Sub-Committee on 2 July 2020 (Session 2019–21), Q 2 (John Glen MP)
86 BBC News, ‘Barclays urges UK to focus on US and Asia post Brexit’, 5 February 2021: https://www.bbc.co.uk/news/business-55939857 [accessed 23 February 2021]
88 Ibid.
94 Ibid.
97 Andrew Bailey, Speech on the case for an open financial system, 10 February 2021: https://www.bankofengland.co.uk/speech/2021/february/andrew-bailey-mansion-house [accessed 23 February 2021]