Mise à jour : 10 septembre 2012 (Rédaction initiale : 5 septembre 2012 )
Sur le vif
The Dog and the Frisbee, severe metaphor thrust forward on August 31, 2012 by the Bank of England, about stacking new rules in banking Regulation.
http://www.thejournalofregulation.com/spip.php?article1600
It quarrels on the best model of banking regulation, but the key is to determine the criteria against which we fight. However, two representatives of the Bank of England, during the global meeting of central bankers in Jackson Hole in the US, have appointed what they believe to be the relevant criterion: simplicity. In a short intervention, they stressed that the North American banking regulation would make about 30,000 pages and 60,000 pages for the European Union. Entitling their speech "Dog and Frisbee", they said that it is equivalent to require that a dog learns Newton's laws before catching the Frisbee. Under these conditions, many would would like to return to Glass-Steagall Act, the mere fact that this law was simple.
© thejournalofregulation
Each year, the central bankers meet in Jackson Hole, United States, in Wyoning. The highlight of this year seems to have been the supported absence of the President of the European Central Bank.
But the most instructive was the intervention prepared for the Bank of England by its economist Vasileios Madouras and its Executive Director Andrew G. Hasldane. It is remarkable that he is in charge of financial stability.
However, the speech is a very powerful burning down the evolution of banking Regulation on the single criterion: simplicity.
Taking the image of the dog and Frisbee, they point out that legislation that makes 30,000 pages (Dodd-Frank) or 60,000 pages (Basel III) require operators to an impossible learning before the application. As if the dog were forced to study Newton before catching the Frisbee ...
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Warning, images are always "effects of speech" and for that reason, we must be careful. Operators are not dogs and why these huge beasts those are banks could not swallow these regulations?
Similarly, when the speech refers to the Basel III rules as constituting a new "Tower of Babel", it is a "play on words", another form of rhetoric that we must beware.
Indeed, there is no relationship between the Tower of Babel, in which all spoke the same language (and a key element of simplicity) and the standards much more or less easy to understand (that is to say, the plurality of languages, so the curse that followed the construction of the Tower of Babel).
Regardless, the speech also intended to strike the imagination with images. Returning to the subject of the statement, is simplicity the first criterion of Regulation quality ?
If so, then all the new banking regulations that are put in place, whatever their purpose are properly catastrophic.
We must return to the classical art of writing rules. Brevity is a pillar. Forgiveness, "pillar" is another image...
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