4
a
a
Part XVII of the Bill becoming effective. Not only could career bankers from the commercial sector help the supervisory authority in the assessment of risks and of their weighting, but could also provide a practical input to the application of many of the other technical provisions of the Bill. In turn these bankers could
obtain
better understanding of the work of a Government regulatory unit which may be useful experience on return to their
In fact, normal
of managerial responsibilities.
programme continuous interchange of personnel between the two sides, while possibly radical in concept, would make good practical sense; and This in Hong Kong actually already have
precedents.
the steam out of the proposal, if implemented, would also take argument that the Banking Bill has in parts submerged commonsense by theory, and could help in the effort of preventing those who always readily
we
some
see
loopholes,
from too
and are
to keen
exploit any
their easily achieving poachers do make more effective gamekeepers.
legislative
aims. Sometimes
The
to
to
as an
Other public criticisms of the Banking Bill relate its possible effects on the smaller banks and DTC's. Among the latter are especially those whose asset portfolios include large held offshore loans, loans to parent institutions, or securities as trading assets, and which as a result have argued for the creation of a new category of "limited service banks" subject
liberal rules.
to disadvantages
Hong Kong
international financial centre resulting from the possible scaling down or disappearance of the operations of these DTC's, if such a differentiation was not ultimately accepted, must be
the weighed against
likely to
made greater
of several different institutions. The whole tenor of the present Bill
more
effective
financial
supervision
demands
be
categories
on
of
is
of course towards unification and not diversity; the reasons advanced for separate treatment are also not fully convincing.