Consolidated Financial Regulation: Six National Case Studies and the Experience of the European Union

Abstract

This paper provides an overview of how six, developed nations (Australia, Canada, France, Germany, Japan, and the United Kingdom) created consolidated regulatory structures for financial services (e.g., banking, securities, insurance). It also provides a summary of how the European Union has consolidated some forms of financial services regulation at the European Union level. It is not intended to be an exhaustive study of these regulatory structures. Instead, it highlights to what extent these experiences may provide useful lessons for the United States as it considers consolidating its financial services regulators.

Note: This paper was prepared for the Volcker Alliance as background for its project on structural reform of the federal financial regulatory system. The views expressed in this paper are those of the author and do not necessarily reflect the position of the Volcker Alliance. Any errors or omissions are the responsibility of the author.

Keywords: Financial Services Regulation, Banking Law, Securities Law, Insurance Law, Comparative Law

JEL Classification: K2, K23, N2