Woods defines 'clinical' banking supervision
Sam Woods, Deputy Governor for Prudential Regulation, reflected on the unique nature and evolution of banking supervision in a speech at Bayes Business School. He argued that supervision is a 'clinical' and unusually intrusive activity within a capitalist economy.
Supervision: An unusual capitalist activity
Sam Woods, Deputy Governor for Prudential Regulation, defined banking supervision as a distinctly interventionist and continuous monitoring activity, setting it apart from mere regulation.
He noted that while regulation involves setting rules, supervision entails a more intrusive oversight, which is unusual in a capitalist economy.
This 'clinical' approach is now even being exported to other sectors like energy and water.
Woods explained that the fundamental rationale for such deep engagement stems from the immense economic costs of financial crises, estimated at 43 percent of GDP, which are largely borne by the wider economy.
Banks also provide critical public infrastructure by creating money in the form of deposits, making their safety and soundness paramount for economic functioning.
This unique role necessitates the state's close monitoring of private actors licensed to create money and credit.
Two centuries of evolving oversight
Woods traced the evolution of banking supervision through two case studies: the US and the UK.
In the US, oversight began in the early 19th century in response to private note-issuing banks, with New York State introducing periodic checks by 1829. The Office of the Comptroller of the Currency (OCC) established a systematic, nationwide supervisory approach in the 1860s.
In contrast, UK bank supervision remained largely informal until the 1970s.
The Bank of England's Discount Office conducted market surveillance, but formal powers were limited.
The secondary banking crisis of the 1970s exposed the limits of this informal approach, leading Parliament to grant the Bank a formal supervisory role in 1979, though a flexible, judgement-based philosophy persisted.
The price of public trust
Woods' speech effectively frames banking supervision as a unique and necessary intrusion, directly linked to banks' critical role in providing public money and the immense societal cost of financial crises.
The argument for broad supervisory powers, including 'meta-regulation' and judgment-based approaches, is compelling given the inherent risks.
This perspective underscores that the extensive oversight is not merely regulatory burden, but a fundamental safeguard for economic stability.
Source: Sam Woods: Clinical supervision
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