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“Banking control law, in Saudi Arabia, lacks and development),
Many thanks for the work on chapters 1 & 2, which reads well. Thank you also for the additional material contained in the highlighted sections, which addresses some of the points that we have discussed. However, the new sections do not address these points in quite the depth I had hoped. In particular, the new sections identify very few new sources and the structure remains a little weak.
You know that I’m focused on the issues within the KSA banking regulatory regime and the dis-empowerment of SAMA and this is obviously a significant issue and one that merits the research focus. However, it requires greater contextualization by reference to a deeper analysis of the wider range of initial issues we have previously discussed.
I set out below some important aspects that you need to consider in the research. I appreciate that the work you have submitted is partial and it may be that you intend to address some of these issues in due course. However, I would like you to move on to these quite quickly. The issues are as follows:
1) The section on the history of Saudi banking reads well. However, you seem quite reliant on a limited number of secondary sources, e.g. Robertson and Wilson. There are no references to any sources produced or available in the KSA, for instance.
2) Would it not be appropriate to elaborate more fully on Sharia law in the historical section? It seems relevant to both the early development of banking and the later evolution of the banking regulatory framework in the KSA. Is Shariah law influenced by differing religious schools of thought and if so, are these schools also relevant? If they are, then they need to be referred to, otherwise references to Shariah might appear to be too simplistic. For instance, in the last sentence of your final paragraph in section 1.4.4, you refer to “strict adherence to the Shariah law” as being “the greatest impediment to the updating of the Saudi banking laws.” However, it is not at all clear why this is considered to be so.
3) With reference to the US Federal Reserve, I am not clear why you say on page 42 that “If the US Federal Reserve[’s] were selected for the study, the probability of the identified gaps remaining unaddressed would be high. This is the reason to select the Bank of England.” What would the gaps have been? Can you say that the Bank of England is the superior bank for comparison purposes without a far greater explanation for your conclusions here? You cannot really make this statement without a far deeper analysis and explanation of the differences. You also indicate that the KSA favoured the influence of the US (rather than that of the UK) in the evolution of banking in the KSA. Does this mean that the system of banking regulation inherited US flaws and that that is why you have selected the Bank of England? On page 42 refer to the US Federal Reserve as having been the model for setting up SAMA – why does this rule out the Federal Reserve as a comparator for the purposes of analyzing SAMA’s current difficulties? Is the US Federal Reserve insufficiently independent? If so, this needs to be explained and stated.
4) You still need to justify why the Bank of England is your principal focus in greater depth. In section 1.5, you indicate that the Bank of England “represents an outstanding model of a central bank.” Why is this so? On page 42, you state that: “the Bank of England has proved its effectiveness as a supervisory body.” My recollection is that the Bank of England was criticized for its role in the recent financial crash.
5) We have also discussed the issue of who the relevant watchdog/supervisor should be and as to what tasks it should perform, e.g. the division of responsibility between the Bank of England and the Financial Conduct Authority in the UK. This requires a clearer analysis of what the SMA’s role is and how it compares to these alternative institutions in the UK. You refer to the Prudential Regulatory Authority and FCA on page 42, but do not give details of their functions. Would the Bank of England have done better if it had kept all of its oversight (as former Governor, Mervyn King argued)? Is SAMA in a better position to provide integrated banking oversight than the Bank of England?
6) Are all central banks alike? In section 1.2.1 you refer to a key central bank function as being that of regulating the conduct of individual banks. Which institution regulates this in the UK? Central banks perform quite a wide range of functions and we are interested in those that SAMA performs and the issue how its lack of independence impacts on specific aspects of its remit.This will help the reader to understand why the precise functions of SAMA are important and why it should have regulatory independence. For instance, in the second paragraph of section 1.4.4 you note that the IMF criticized the fact that SAMA is not an independent body – why did it? Was it to do with a lack of independent monetary policy or problems with the licensing/regulation of commercial banks? You refer to the role of a central bank in a number of places by reference to different policy issues (e.g. growth, financial stability etc.) but you need a tighter analytical framework that addresses each specific goal and the independence issue in respect of each of these.
7) You also need to discuss KSA existing banking regulation in greater detail. Paragraphs 1.4.5 and 1.4.6 are quite ‘broad brush’, with references to economic growth allied to existing laws being adequate to “serve their purpose” and a reference to SAMA being left free “to work on the issues that really matter.”
8) Are banking regulation problems global or local? Can any national regulator hope to address problems in the banking sector on its own. There is a wealth of literature that was a result of the recent banking crisis, but you do not explore this in any depth. So, you might want to consider the reports of the Financial Stability Board and authors such as Howard Davies, David Green, Barry Eichengreen, John Eatwell, Lance Taylor and Adair Turner. Was the crisis due to light touch regulation, poor capital adequacy levels, political failure and/or excessive debt/leverage? What specific aspects of this are relevant to banking regulation in the KSA? Are the real problems macro or micro?
9) IMF: You need to explain more fully the nature of the IMF and why any government should take its advice.
So, quite a bit to work remaining, as you need to avoid too much assertion and base your conclusions on greater depth of research and more concrete analysis.
10) Revised all chapters introductions and conclusions for all chapters to be connected together as a full research.
Please find the chapter 1,2,3 draft attached.
11) Please highlighted the new word you will add, to be clear for the reader.
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