Journal article

A jurisdictional comparison of the twin peaks model of financial regulation

Andrew Godwin, Timothy Howse, Ian Ramsay

JOURNAL OF BANKING REGULATION | PALGRAVE MACMILLAN LTD | Published : 2017

Abstract

The last two decades have seen an increasing number of jurisdictions adopting the 'twin peaks' model of financial regulation. Since it was pioneered in Australia, the model has been adopted by the Netherlands, Belgium, New Zealand and the United Kingdom. South Africa is currently in the process of changing its model, and it has also been considered by the US. This paper evaluates the twin peaks model as it has been adopted in these jurisdictions and investigates the extent to which there is uniformity in its design and implementation from a regulatory perspective. The comparative analysis indicates that there are many variations in the design of a twin peaks model and that there is no archet..

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Funding Acknowledgements

This article is part of a research project funded by the Melbourne Law School and the Centre for International Finance and Regulation entitled 'Financial System Regulation - is Australia's "Twin Peaks'' Approach a Model for China?' (see http://www.cifr.edu.au). The authors would like to thank Steve Kourabas and the anonymous reviewers for their helpful and insightful comments on this paper.