Perhaps the most fundamental confusion in the evolution of financial services regulation is the equation of financial stability with the survival of established institutions. If I had £1m for every time I have heard a possible reform opposed because “it wouldn’t have prevented Northern Rock or Lehman Brothers going bust”, I might now have enough money to bail out a bank.
或许,在金融服务监管的演化中,最根本的混淆是把金融稳定与现有机构的生存混为一谈。一项可能的改革因“不能防止北岩银行(Northern Rock)或雷曼兄弟(Lehman Brothers)破产”而遭到反对,如果每次我听到这样的事情就赚100万英镑,那现在我可能就有足够的钱来救助一家银行了。
The objective of reform is not to prevent Northern Rock or Lehman going bust. It is highly desirable that organisations such as Northern Rock or Lehman should go bust.
改革的目标不是防止北岩银行或者雷曼兄弟破产。北岩银行或雷曼兄弟这样的机构倒闭才是大快人心。
Northern Rock had overambitious expansion plans and a business strategy that proved flawed (although many people thought at the time, with reason, that reliance on wholesale funding was a strength rather than a weakness).
北岩银行的扩张计划野心过大,商业战略被证明存在缺陷(虽然很多人当时以他们的理由认为,依赖批发融资是优势,而非弱点)。
Lehman was run – badly – for the benefit of its senior employees rather than customers or shareholders. In a market economy, such organisations fail while rivals with better business models and management structures gain at their expense. That process of selection is the reason market economies have an impressive record of promoting efficiency and innovation. The problem revealed chking this is the appropriate wordby the 2007-08 crisis was not that some financial services companieswere on the brink of collapse? were on the point of collapse, but that there was no means of handling their failure without endangering the entire global financial system.
雷曼兄弟是为其高级员工的利益而经营的,而非为了客户或股东的利益,这很糟糕。在市场经济中,这样的机构会失败,被有着更好商业模式和管理结构的竞争对手吞噬。正是由于这一选择过程,市场经济才在促进效率、推动创新方面创造了极佳的历史。2007-08金融危机暴露出来的问题并非某些金融服务公司倒闭了,而是没有办法在不危及整个全球金融体系的情况下处理这些公司倒闭带来的冲击。
Still, would it not be better if proper supervision ensured that no financial institution could ever get into a mess like Northern Rock or Lehman – or Royal Bank of Scotland or Citigroup or AIG? No, it would not. Just replace “financial institution” with “fast-food outlet” or “supermarket” or “carmaker” in that sentence to see how peculiar is the suggestion.
那么,如果有恰当的监管来保证,不会有任何金融机构陷入北岩银行或雷曼兄弟——或苏格兰皇家银行(RBS)、花旗集团(Citigroup)或美国国际集团(AIG)的糟糕境地,情况不是会更好吗?不,不会的。只需把这句话里的“金融机构”替换成“快餐店”或“超市”或“汽车制造商”,就能看出来这条建议有多怪异。
Begin with practicality. It is hard enough to find people capable of running financial conglomerates – the fading reputation of Jamie Dimon, JPMorgan Chase chief executive, confirms my suspicion that managing these businesses is beyond the capacity of anyone. The search for a cadre of people employed on public-sector salaries to second guess executive decisions is a dream that could not survive even the briefest acquaintance with those who perform supervisory tasks in regulatory agencies. They tick boxes because that is what they can do, and thus we should aim to design regulatory structures that boxtickers are capable of implementing.
先从现实说起。找到有能力管理金融企业集团的人已经很困难了,摩根大通(JPMorgan Chase)首席执行官杰米·戴蒙(Jamie Dimon)日益蒙尘的声誉证实了我的猜测:管理这样的企业远超出任何人的能力。而寻找一批领着公共部门工资、有能力推测高管决策的人,实在是白日做梦,哪怕仅仅是与在监管机构里执行监管任务的人只有一面之缘,这样的梦想也可以破碎了。他们的工作就是在调查表上打对勾,因为这就是他们能做的事,因此我们的目标应该是设计出打对勾者能够执行的监管架构。
We have experience of structures in which management or regulatory committees in Moscow or Washington take the place of the market in determining the criteria by which a well-run organisation should be judged, and that experience is not encouraging. The truth is that in a constantly changing environment nobody really knows how organisations should best be run, and it is through trial and error that we find out.
我们经历过一种监管架构,在这种架构中,俄罗斯和美国的监管委员会替代了市场,决定评判一家组织运营良好的标准,但这样的经历并不让人欢欣鼓舞。真相是,在一个不断变化的环境中,谁也不知道怎么才能最好地经营各种机构,只有通过试错才能知道。
Financial stability is best promoted by designing a system that is robust and resilient in the face of failure, which is why effective and implementable mechanisms of resolution are the key to meaningful financial reform. Some progress has been made, but overall very little; living wills too complex to implement at all, far less within hours, are no solution to the problem of too complex to fail. The bungled Cyprus bailout showed how far the EU is from the goal of an established resolution programme. The Cypriot parliament understood, even if supposedly more sophisticated policy makers did not, that deposit protection is the primary purpose of banking supervision. What people in the streets, correctly, understand by financial stability is confidence that their savings are safe.
只有设计一套面对失败时强舰适应性强的体系,才能最好地推动金融稳定,因此有效、可执行的清盘机制是有意义的金融改革的关键。我们做出了一点进步,但总体上来说进步很校如果“生前预嘱”过于复杂,完全无法执行(遑论在数小时以内了),就不是应对“复杂到不能倒”问题的解决方案。拙劣的塞浦路斯纾困表明,欧盟(EU)远未达到拥有一套成熟清盘方案的目标。塞浦路斯议会明白(即便那些照理说更有经验的政策制定者不明白),储蓄保护是银行监管的首要目的。普通人对金融稳定的理解是能够让他们对存款安全有信心,而这一理解是正确的。
Now we have an equally dotty, and essentially similar, proposal to fund the bailout of failed derivatives exchanges using customers’ collateral. The explicit rationale is that it is more important to keep the institution intact than to protect the interests of its customers. But the reverse is the case. The services may go on (or not: the commonest reason commercial organisations fail is that people do not want their product). But the failed organisation that provided such services need, and should, not. This applies to fast-food outlets and supermarkets and car plants – and also to utilities such as electricity, water, and the payment system. Financial services differ only because the lobbying power of incumbent companies is so great.
如今,我们面临一个同样荒唐而且基本类似的提议,要拿顾客的抵押品来为失败的衍生品交易所的纾困融资。该提议所表现出来的逻辑是,保持交易所完整无损比保护顾客利益更重要。但实际上正相反。这种服务或许会继续存在下去(或许不会:商业机构失败的最常见原因是人们不需要它们的产品)。但提供此类服务的失败机构没有必要、也不应该继续存在下去。同理可用于快餐店、超市和汽车工厂,也适用于电力、水务和支付系统等公用事业部门。金融服务与众不同仅仅是因为现有企业的游说力量太强大了。 |
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