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Hong Kong's International Financial Centre: Retrospect and Prospect

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such a context, the range of financial market issues amenable to discussion <strong>and</strong> debate is defined,<br />

often too narrowly.<br />

Let me end by drawing out several plausible policy implications from the assessment set<br />

out above. Not all of them can or should be entirely separated from the broader economic<br />

context, but all of them flow naturally out of my analytical narrative. Food for thought offered<br />

humbly by an outsider <strong>and</strong> not a fully digested meal, they nevertheless seem to me ripe for open<br />

deliberation <strong>and</strong> debate.<br />

To strengthen today’s IFC in <strong>Hong</strong> Kong, a single entity ‘above the fray’ needs to be in a<br />

position to think strategically. FSTB is a logical place to lodge it. The best of its high-quality<br />

staff members need to be deployed for longer than usual terms of civil service postings. In a<br />

sense, they need to act as a permanent secretariat <strong>and</strong> strategic think-tank for the Council of<br />

<strong>Financial</strong> Regulators. Their main task would be to help the Council balance <strong>and</strong> rebalance the<br />

stability <strong>and</strong> competitiveness imperatives pushing <strong>and</strong> pulling <strong>Hong</strong> Kong’s IFC in new<br />

directions. Since the agenda necessarily crosses many policy arenas, with fiscal policy at the<br />

core, the alternative idea of shifting even more power <strong>and</strong> responsibility to the monetary<br />

authority should be resisted.<br />

Closer to the markets, a version of the UK’s Prudential Regulatory Authority, as a distinct<br />

<strong>and</strong> distinctly m<strong>and</strong>ated subsidiary of the monetary authority, should be considered. Such an<br />

agency might provide a useful buffer for both the HKMA <strong>and</strong> the government in an era of global<br />

finance that looks to remain crisis-prone. Under its stability m<strong>and</strong>ate, the HKMA should remain<br />

in a position continually to re-assess <strong>and</strong> guide macro-prudential policies, especially as they<br />

apply to systemically significant banks, cross-border banks, <strong>and</strong> large bank-equivalents at or near<br />

the core of the payments system. In this regard, it needs to maintain its excellent research<br />

capabilities <strong>and</strong> its relationships with important central banks around the world. It should also<br />

continue to be responsible for ensuring that the technology of settlement <strong>and</strong> clearing in <strong>Hong</strong><br />

Kong’s IFC meets world st<strong>and</strong>ards. It does not, however, need directly to h<strong>and</strong>le responsibilities<br />

for day-to-day financial supervision. Like most of its counterparts abroad, it should st<strong>and</strong> one<br />

step removed from future problems akin to the Lehman mini-bond problem. <strong>International</strong><br />

comparators should also inform related reconsideration of the relationship between the SFC <strong>and</strong><br />

the HKEx <strong>and</strong> the continuing debate on establishing a separate, cross-sectoral agency for<br />

consumer protection. The ad hoc response to the Lehman crisis provided a vivid example of<br />

what needs to be avoided in the future.<br />

There is no reason to tamper with the HKMA’s primary responsibility for managing the<br />

Exchange Fund. But it is reasonable for the government to insist that reserves not likely to be<br />

needed to maintain the integrity of the linked exchange rate system or the liquidity of the<br />

payments system be invested more aggressively. A sovereign wealth fund does not have to be<br />

explicitly carved out, but the return on a serious portion of existing <strong>and</strong> future reserves could<br />

reasonably be benchmarked, not simply against the guideline set by the <strong>Financial</strong> Secretary, but<br />

also against the performance of SWFs in comparable jurisdictions. The HKMA’s move to<br />

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