IRSG response to HM Government Financial Services Future Regulatory Framework: Proposals for reform
01 April 2022
The IRSG are supportive of the proposals set out in the consultation but believe there may be too large a gap between the high-level legislation that sets the overall objectives of UK policy and the specific rules applying to products or markets..
The IRSG welcomes the opportunity to respond to this final phase of
the consultation on the UK's future regulatory framework. The IRSG has
been focused on the regulatory framework since it published its first
report ‘The Architecture for regulating finance post-Brexit’ in 2016.
The IRSG response to this phase of the consultation builds on points
from that report and a follow-up report produced in 2020.
As well as responding to the specific questions the IRSG response sets out:
- The IRSG are supportive of the proposals set out in the consultation
but believe there may be too large a gap between the high-level
legislation that sets the overall objectives of UK policy and the
specific rules applying to products or markets..
- The proposals will generate significant additional tasks for the UK
parliament, government, and regulators. To operationalise the changes,
the new model will require significant extra expertise and resources.
- The process of transferring onshored legislation to regulators
rulebooks needs to observe the same objectives of ensuring continuity
and certainty unless there is an intention to change policy.
- There is a significant gap the in framework for democratic
oversight. The IRSG encourages Parliament to take the opportunity to
consider additional mechanisms to build that oversight.
- The overall goal of the proposals should be to drive an appropriate
regulatory culture for this new era. Effective policy making and
oversight needs to be supported by effective day to day engagement with
market participants and other stakeholders.
IRSG
© IRSG - International Regulatory Strategy Group
