Hands Across the Sea

Friday, January 1st, 1988 at 12:00 am by Jonathan Charkham
Jonathan Charkham, Hands Across the Sea, 1988 Colum. Bus. L. Rev. 765

The recent creation of the Securities and Investment Board of the United Kingdom (the “SIB”) serves as a reminder that although the systems for securities regulation in the U.K. and the United States are similar in many fundamental respects, there are still significant differences. Thus, while the discussion that follows will concentrate on the British experience, many of these lessons are equally applicable to the U.S. corporate system, making due allowance for the differences. Most significantly, both economies rely upon capital markets to finance economic expansion. The Anglo-American example, therefore, contrasts sharply with economies where banks play a much larger role in corporate funding, such as Japan and West Germany. These differences in corporate finance have, predictably, created markedly different economic superstructures.

Author Information

Advisor to the Governors, Bank of England. MA (CANTAB).