ࡱ> kmj EFbjbj 4Tcc=33@@@@@@@@@8%A9A@VUAUA:AAA~BVCd8D4VVVVVVVY[LV@lD~B~BlDpDVxE@@AAVxExExEtD@A@AVxElDVxExET@@-VL@Ep-U]V<V0VAU[xE[(-VxE-V@AVlDlDlD3 ?:   Session 6: How do the General Agreement on Trade in Services (GATS) rules relate to countries post-crisis financial regulatory policies? Sub theme III: Coherence between the ϲʹ and other areas of global governance Moderator Mr Wamkele Mene, Economic Counsellor, Permanent Mission of South Africa to the ϲʹ Speakers Dr Pedro Paez, President of the Technical Commission on New Regional Financial Architecture; member of the UN Commission of Experts on Reforms of the International Monetary and Financial System Mr Abdel-Hamid Mamdouh, Director of Trade in Services, ϲʹ Ms Ellen Gould, Research Associate, Canadian Centre for Policy Alternatives Ms Lori Wallach, Director, Public Citizen's Global Trade Watch Organized by Our World Is Not For Sale (OWINFS) Report written by Sarah Edelman, Public Citizens Global Trade Watch division Wednesday, 15 September 2010 16.15-18.15 Abstract This session explored questions emerging among governments, non-governmental organizations (NGOs) and trade and finance experts about the interaction between financial regulation and ϲʹ financial services rules. 1. Panel introduction Wamkele Mene, Economic Counsellor, Permanent Mission of South Africa to the ϲʹ This was the weeks most interesting topic: it will occupy our attention for some time to come because of its significance in economic history and the governance of global finance. It is a multidimensional topic, covering globalization of finance via liberalization of capital accounts, the relationship between GATS and other bodies dealing with financial regulation, and how the ϲʹ can respond within its mandate to trade in financial services and the crisis that emerged therein. There have been two significant responses at the ϲʹ: Argentina, Ecuador and India co-sponsored a paper in the General Council seeking analysis of the trade impact of stimulus packages; and Ecuador, India, Argentina and South Africa proposed a paper in the Committee on Trade in Financial Services (CTFS) to examine the same, as well as the interaction between GATS provisions that may be pertinent to regulatory questions. The relevant GATS provisions and prudential carve-out were also noted: the latter is attracting debate amongst trade lawyers about whether it provides countries the ability to protect financial markets when they foresee dangers. 2. Presentations by the panellists (a) Abdel-Hamid Mamdouh, Director of Trade in Services Division, ϲʹ The GATS is the first multilateral agreement to establish rules for the progressive liberalization of services trade. It is the international community's response to the transformation of the service sector in modern economies. In the past, various services were mainly government functions performed by public utilities. In modern economies, services became commercial products exchanged in competitive markets. Under the GATS, liberalization does not mean deregulation. On the contrary, the liberalization process requires a more rigorous approach towards strong regulation. Liberalization has a very specific and precise meaning under the GATS: granting market access and national treatment to foreign services and service suppliers. A full market-access commitment requires a member to refrain from using the six types of limitations specified in ArticleXVI. A full national-treatment commitment under ArticleXVII requires a member to treat foreign and national services and service suppliers equally. Members need not take full commitments on either. They specify in their schedule limitations which they wish to maintain. Members also have obligations to allow international payments and transfers for services. However, on capital transfers, the scope of such obligations is very limited, confined only to two situations. The first, in the case of mode1 (cross-border supply) commitments on the supply of a financial service of which the capital transfer is an essential part, both incoming and outgoing transfers should be allowed. For the second, with respect to commitments on mode3 (commercial presence), only incoming capital transfers should be allowed. These obligations are waived in situations of balance of payments problems or an International Monetary Fund (IMF)-requested restriction. The GATS Annex on Financial Services also contains an important exception provision to accommodate prudential regulations. A member may deviate from its commitments under the GATS and impose measures of any type, as long as this is for prudential reasons (protecting depositors, investors, policy-holders or the stability and integrity of the financial system). This considerable regulatory freedom is qualified only by the requirement that such measures not be used as a means to avoid obligations and commitments under the GATS. This provision has never been invoked in a dispute and therefore no jurisprudence exists. However, it can be argued that it is less stringent than the "necessity test" found in ArticleXIV (General Exceptions). The Secretariat background note on financial services (S/C/W/212) discusses the root causes of the financial crisis, which include many factors, such as macroeconomic, monetary, financial and risk management factors, weaknesses in underwriting standards, as well as regulatory and supervision shortcomings. The analyses in the paper, as well as studies by other organizations, clearly conclude that GATS commitments on financial services are not among these causes. (b) Lori Wallach, Director, Public Citizens Global Trade Watch division Financial experts and government officials have begun asking whether ϲʹ rules lock in pre-crisis policies and deregulation philosophies, and/or limit policy space needed for reregulation. For instance, the United Nations (UN) Stiglitz Commission concluded that trade pacts can restrict a countrys ability to revise its financial regulatory regime in not only domestic prudential but crucially capital accounts regulation. Obviously they have to be altered in light of what weve learned in the crisis. In particular, theres concern that existing agreements under the ϲʹ financial services agreement might, were they fully enforced, impede countries from revising their regulatory structures in ways that promote growth stability and equity. GATS rules conflate liberalization and deregulation. GATS market access rules absolutely ban countries use of categories of non-discriminatory regulatory tools with respect to committed sectors. This includes policies related to legal form, firms size, and firewalls. SecretaryGeithner wrote a 1990 memo as a junior Treasury staffer describing these threats. The United States scheduled a commitment to reform Glass-Steagall to meet GATS rules. GATS market access rules also forbid bans of risky financial services in committed sectors. The Antigua gambling case explicitly deemed regulatory bans to be GATS-forbidden zero quota quantitative restrictions. GATS ArticlesXI, XII andXVI (footnote8) forbid capital management techniques used by many nations to safeguard against bubbles and surges. Requiring free capital movement may make sense in some sectors, but application to the financial sector can result in countries loss of control over current and capital accounts. The limited short-term exceptions relate only to balance of payments crises. GATS ArticleVI poses additional limits on licensing, technical standards and qualifications standards. Until now, there have been no GATS challenges, because the trend was toward deregulation. Now, a recent European Commission (EC) staff report identified the financial transaction tax as a possible violation of European Union (EU) GATS commitments; think-tank analyses claim Germanys ban on speculative short-selling violates GATS; Panama has issued GATS threats to anti-tax-haven measures; and more. The prudential exception does not safeguard countries regulation from GATS constraints. The second sentence cancels out its usefulness, with expansive limiting language not found in any other ϲʹ exception provisions anti-abuse clauses, which all contain the same boilerplate. Many other versions of prudential language were proposed during GATS talks that offered better safeguards, and numerous law review articles note the problem and suggest clarification. MsWallach concluded by referring participants to six Public Citizen papers on these issues. She also argued that, post-crisis, the Doha Round should do no further harm. As a political or policy matter, it is unimaginable that new limitations on domestic regulation would be included in the Doha Round (i.e. those being negotiated in the Working Party on Domestic Regulation (WPDR) or the accountancy regulation disciplines). A review of existing GATS language is needed to identify what must be fixed (or at least clarified) to provide countries with the policy space needed to reregulate. (c) Pedro Pez, Chair of the Ecuadoran Presidential Technical Commission on New Regional Financial Architecture Unlike the post-war decades, financial crises are now normal: over the past 35 years, the IMF has identified 267 financial crises. Most relate to neoliberal policies, capital account liberalization, financial deregulation and openness of trade accounts. This type of globalization is based on the transnationalization of finance and financialization of transnational firms. It has no historical precedent: one can find this level of openness and planetary integration, but never at todays intensity. Globalized financial markets largely determine trade and global market prices, which determine conditions of life and production even for people who produce primarily for the local markets, but are directly impacted by intermediation, arbitrage and substitution effects. It is critical to focus on the crisis real-life effects in terms of employment, poverty and the extreme vulnerability for segments of the population and for entire countries. There are various UN interventions that state current ϲʹ rules could be obstacles to financial re-regulation, including policies related to capital transfers and prudential measures. Explicit action should be taken at the ϲʹ to preempt future interpretations of key articles in the GATS text (e.g.ArticlesXVI(2) and XI) that go against the need for economic stability. As any governmental official could say, when a country is facing a financial crisis, every second counts. This happened in Ecuador, Argentina, Greece, etc. Governments face real limitations in their responses to crises due to ϲʹ, bilateral investment treaties (BIT) and free trade agreement (FTA) commitments. GATS ArticlesXI andXII preclude limits on capital flows and refer the final word to the IMF. And, under those circumstances, a government cannot openly ask for this type of permission, because it would worsen speculative attacks. Other dangers include Northern-headquartered banks operating in the South, which can create deeper exposure to the risky creative accounting practices that fostered and still foster the global financial crisis. Additional ϲʹ disciplines on accountancy regulation could make it even more difficult to detect such opaqueness. Instead of contributing to the widening of asymmetric conditions, the ϲʹ and other multilateral institutions should provide new rules for a safer economic environment, like universal bans of short-selling and credit default swaps related to the food and energy markets in order to avoid harm for the worlds most vulnerable people. (d) Ellen Gould, Research Associate, Canadian Centre for Policy Alternatives The GATS financial services negotiations in general and the domestic regulation negotiations in particular threaten to increase the likelihood of another, more global, financial crisis. Canada is pointed to as a country that escaped the financial crisis largely unscathed with all of its banks intact, yet this was because Canada kept key policy tools ones that it had to make limitations for in its GATS commitments. Canada did not fully liberalize its banking sector, and a 2009 IMF study pointed to the lack of external competition as a key reason why Canadian banks survived the crisis intact. Canada took a significant limitation for banking under GATS in order to protect the non-discriminatory Canadian policy that does not allow foreign or domestic institutions to own more than 10per cent of a Canadian bank. This policy was critical in safeguarding the Canadian banking sector from the financial crisis. Had Canada not listed this policy as a limitation in its GATS schedule, it would have needed to eliminate it. So the GATS does require deregulation where countries make commitments. On the other hand, in the sectors where Canada did fully liberalize mortgage insurance and asset-backed commercial paper Canada saw extreme problems. In 2006, Canada allowed AIG (American International Group, Inc.) and other US firms into the Canadian insurance market to introduce more competition. This liberalization conformed with Canadas GATS commitments. The result was almost instantaneous looser lending standards. Within a year, more than half of Canadians taking out mortgages leapt into high-risk mortgages. This sudden spike in risky lending prompted expressions of concern from the Bank of Canada. The Canadian government responded to the problem by increasing lending standards. Had the draft disciplines in the WPDR been adopted, Canada would have been in trouble. Under the pre-established provision, one interpretation is that one is not allowed to introduce any new regulation on firms that are already licensed. Another provision relevance also might have come into play, since avoiding a housing bubble is not relevant to consumers of mortgage-lending services. MsGould closed by reflecting back on the larger picture of one of the biggest financial crises in history, and the wake-up call it has provided. Part of the cause of the financial crisis was people not giving enough consideration to the worst-case scenarios. She urged the Secretariat and the chair of WPDR to look at the worst-case scenarios the potential challenges that could arise, financial crisis and to ask themselves, do we want to limit the ability to regulate any more? 3. Questions and comments by the audience Ivano Casello, EU mission to the ϲʹ The EC paper that MsWallach cited does not show that there is a split between the EC and member countries on the financial transaction tax (FTT) being a possible GATS violation, and the French and German advocacy for such a policy. Ahmad Mukhtar, Pakistan Mission and Chair of the WPDR MrMukhtar advocated for the need for strong WPDR disciplines, noting that service providers seeking access to a market need some regulatory certainty. He disputed whether the current WDPR text could cause the regulatory limitations referenced. Myriam Vander Stichele, Center for Research on Multinational Corporations: Would the prudential exception also cover financial measures outside of the definition of prudential (provided in the Annex2 text) that are important to overall social stability, such as banning food commodity derivatives that have led to price spikes and hunger? Sanya Reid Smith, Third World Network: The Secretariat raises important questions about the prudential exceptions reach in its paper S/C/W/72, which casts doubt on whether the United States Glass-Steagall firewall would have been protected under the prudential exception. The same issues raised about GATS are at play under the FTAs and economic partnership agreements (EPAs) under negotiation with over a hundred developing countries.      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