Jacob Rees Mogg Is Wrong To Say That Loss of Passporting Will Not Be A Problem For The City

I consider the question as to whether The City will suffer a severe impact from the loss of passporting and conclude that it will

Jacob Rees Mogg made the claim below this morning on the Today programme:

“Passporting is mainly retail and UK financial services mainly wholesale.”

This was aimed at supporting the further claim that loss of passporting will not be much of a problem.  Passporting is the regulatory feature whereby financial institutions located in any EU member state can offer financial services in any EU member state.

The first thing we need is clarity on the distinction between retail and wholesale banking.  This maps approximately on to what we might call “high street banking” and “investment banking.”

The former are retail banks such as for example RBS or HSBC.  Their primary lines of business involve dealing with retail customers — i.e. individuals — and their financial needs.  They will offer deposit acceptance, interest bearing accounts (often in pre-crisis times with non-zero amounts of interest!) and mortgages.

Investment banks such as Goldman Sachs or will mostly deal with HNWIs and corporate clients.  HNWIs are merely very rich individuals, who require additional services such as estate planning and access to hedge funds.  Corporate clients will want funding usually.  This is provided by investment banks often by issuing bonds for them on the global financial markets.  (There are also some banks like Citi who are both retail and investment banks.)

So now we see that the Rees Mogg position is approximately that the passport enables banking across the EU to individuals whereas the City specialises in corporate clients.  Rees Mogg is definitely correct that the passport enables retail banking.  Basically, the passport means that a banking licence in any EU member state is a banking licence in all EU member states.  With that in hand, one can be regulated by the ECB, open a branch anywhere in the EU and start accepting deposits and making loans.

So the key contestable element of the claim becomes the one that one does not need to be an EU bank to conduct business with corporate clients in the EU.  One point to bear in mind is that many if not all investment banks which operate in The City will also be banks in Frankfurt.  So they will be fine; but of course London could easily lose a lot of high paying jobs and tax revenue.

But to look in more detail, I turn to a report entitled “THE IMPACT OF THE UK’S EXIT FROM THE EU ON THE UK-BASED FINANCIAL SERVICES SECTOR” from Oliver Wyman, commissioned by lobby group TheCityUK.  This report considers four aspects of the wholesale financial ecosystem:

  • Sales and Trading
    • Sales means buying financial assets such as stocks in bulk for major investors; trading is attempting to make a profit by e.g. predicting future directions of market assets
    • Wyman suggest that economies of scale mean that:

“banks could move other activities that are not directly restricted into the EU and away from the UK”

  • Market Infrastructure
    • This means “clearing.” When there are large volumes of trading — and there is well over £2tn (yes, trillion) of daily foreign exchange trading done in London — there are lots of trades that must be cleared.  This means basically moving cash from the bank that bought something to the  bank that sold it and changing the documentation accordingly.  (Incidentally, this sort of thing is why the blockchain is so interesting.  That however, is not a reason to buy Bitcoin: https://timlshort.com/2017/09/16/bad-arguments-for-the-permanence-of-bitcoin/)
    • Wyman suggest that fragmentation of clearing across jurisdictions will increase costs, and

Due to these inefficiencies, some firms could move their clearing out of the UK

  • Asset Management
    • This is managing large investment portfolios for corporate and financial clients such as large EU insurance companies
    • Wyman note that inefficiencies will arise if sales/trading desks migrate to  Frankfurt etc, and so benefits of managing portfolios from the UK could be eroded thus:

leading some companies to manage a greater portion of their assets from within the EU

  • Corporate and Specialty Insurance
    • This is the Lloyds market, specialising in writing large bespoke insurance contracts for major corporate clients
    • Here Wyman suggest:

A loss of depth in the marketplace due to the loss of EU-related activity might lead some insurance firms to relocate outside of the UK

Taking all of this into account, Wyman conclude that no passporting means:

up to 50% of EU-related activity (£20BN in revenue) and an estimated 35,000 jobs could be at risk, along with £5BN of tax revenues per annum

I therefore conclude that some elements of the Rees Mogg claim are true.  It is indeed the case that passporting is on the face of it more of a retail matter than a corporate one.  But corporate clients are still EU clients in a number of important lines of business.  And losing access to those clients from London desks will cause significant impairment to the UK economy.

Wyman confirm this when they estimate the effects of retaining passporting (or some equivalent regulatory arrangement).  They say that in this scenario:

revenues are predicted to decline by up to £2BN (2% of total wholesale and international business), 4,000 jobs would be at risk, and tax revenues would fall by less than £0.5BN per annum

This is still bad — there are no positives to Brexit — but less severe.  Nevertheless, our overall conclusion must be that loss of passporting is very bad news.






#Brexit Is A Disaster, But @DavidDavisMP Is Right About The 57 Documents

Attacking SecState DEXEU by using an easily foiled challenge does not aid the cause of those seeking soft or no Brexit. I will outline why the HMG position on the 57 documents is coherent and plausible, contrary to widespread opinion

Everyone seems to be struggling with the government’s stated position on these documents, claiming that there have been obvious inconsistencies.  I will argue that on this sole point, there have been no inconsistencies and in fact, the position of HMG is economically correct.

By “everyone,” I mean the Financial Times and noted QCs as well as the entire Twitter commentariat.  So that really is everyone.

The general position seems to be something approximating to the following. “Davis said HMG had done a lot of work (“57 documents”) on the economic impact of Brexit but then when he was asked to provide it, changed his position to the diametrically opposed one of “there are no documents.” ”  If he had said that, he would clearly be inconsistent and incompetent.  But, he did not say that.

The key to this is understanding the formal definition of an Impact Assessment.  According to Davis (and which I accept):

An Impact Assessment must include a “quantitative forecast of economic outcome”

This means that for an Impact Assessment to have been produced, a team of economists and sector experts has produced a complicated spreadsheet modelling cashflows.  Efforts have been made to see what the effect of tariffs on a particular sector would be.  Finally, and critically, assumptions have been made as to exactly what percentage of trade will be lost, to what extent this will be offset by other factors, and what the levels of various key parameters will be, such as GDP growth in the UK and the EU, CPI in various locations, and the level of employment and the flexibility of workers.  If a document does not have such a “quantitative forecast of economic outcome,” it is not an Impact Assessment.

Davis admits that no Impact Assessments have been made.  There has been, though, a great deal of assessment of the economic impact of Brexit.  These are the 57 documents.  Note also that these documents can have detailed numerical underpinning but still not meet the formal definition of being an Impact Assessment.  Just because something considers the impact of Brexit economically does not make it an Impact Assessment.  We see this when Davis says that the fact that a document contains the word impact is not sufficient to make it an Impact Assessment.

Should HMG do Impact Assessments?  No.  They are, again as Davis says, of limited value.  This is because we have little idea of what CPI or GDP are next year, and we have absolutely no idea over the 30 year horizon of relevance here.   I discuss such difficulties of forecasting in a precise way in my new book (see for example pp. 79-80):


So, it is now clear that there is no inconsistency in the position taken by SecState DEXEU and it is in fact economically appropriate.