Banking Control Law in Saudi Arabia, Lacks and development
Read the following comments on the last revised copy of the attached research and rewrite the points in advanced concentration and follow up the comments (most of them received as a feedback from my supervisor):
1- I am still troubled by the lack of critical analysis relating to the choice of the Bank of England as the institution that underpins your analysis. On page 32 you refer to the Bank of England as the “model in (sic) which major Central banks have been based. It can therefore be taken as a model for other central banks including SAMA.” No authority or sources are cited in relation to this statement .You also refer to the Bank of England as a benchmark for efficiency (on page 33) without any deep analysis or criticism of its past operations. A similar concern relates to the discounting of the US Federal Reserve as an example (on page 43) when you state: “Since SAMA is largely based on the American concepts of banking a comparative study with the Bank of England would be vital.”
2- Chapter 3: This is an area where there have been very significant developments in the UK, with the FCA now having a significant competition law remit. Since April of this year, it is a concurrent regulator, which means that it has the capacity to apply competition law fully as part of its regulatory role. This is an aspect that you might mention as part of your comparative analysis. Competition law is a friend of new entrants (as you mention on pages 131 and 132) and can be used to breakdown oligopolies. It is especially unwelcome to existing powerful state-owned enterprises. We can discuss the structure-conduct-performance paradigm in section 188.8.131.52 and contestability aspects mentioned in the subsequent sections when we next meet. Certainly in the UK there is a determination to break down concentration levels in retail banking. This suggests that you need to expand on your treatment of the FCA in you earlier chapters and on your comments relating to UK concentration levels, which are rather general and not wholly accurate in terms of substantive law (e.g. on page 144 “To a very large extent, banks Aare (sic) not allowed to hold a market share (sic) that exceeds certain threshold (sic).”). Also, as regards the reluctance to lend, this in turn is not a uniquely KSA phenomenon and could be linked back to the capital and reserve requirements you mentioned earlier.
3- Please try to answer these questions:
a) Why the US Federal Reserve is not an adequate comparator
b) Why the Bank of England is held out as a paragon when there are many critics of its handling of the 2008 crisis (on page 56 you lay the blame at the door of the FSA, but this needs elaboration),
c) The global nature of that crisis
d) The light-touch regulation pursued in the UK and US that led to it (Gordon Brown: “an end to boom and bust”)
e) Why the crisis affected those countries which were in the Eurozone, but which had not suffered from lending bubbles
f) Why the Canadian banking sector weathered the storm so well
4- The research still suggests a relatively uncritical admiration of the Bank of England. On page 70 you state: “Deregulation of the Bank of England caused London to emerge as the financial hub of Europe”. Is this true? What about Frankfurt? Did the Financial Services Act 1986 not play a role in deregulating UK commercial banks? On page 73, you indicate: “The deregulation of the Bank of England is believed to have had a hand in the creation and spread of the 2007-2012 Global Financial Crisis.” You later refer to the FSA as being responsible, but not in any depth.