위기 이후 금융개혁: 영국·독일ㆍ호주의 경험과 시사점

The policy debate on reforming the financial supervisory system that began in June 2012, was unintendedly caught from the outset in ‘the trap of choosing a right model of financial supervision’, which led to the blurring of the entire focus of the debate that evolved for about a year since. There, the twin-peak model came into the limelight, being supported by many critics of the existing integrated model as one that would certainly help enhance financial consumer protection. Later in Spring 2013, the Park Administration (Financial Services Commission) that took the lead in the debate by setting up and operating the Task Force for Reforming the Financial Supervisory System, used the top-down approach to the issue and drew up its own proposal for reform, with little or no conscientious efforts made to consult publicly with stakeholders. This paper first examines the recent domestic financial reform experiences of the United Kingdom and of Germany, demonstrating that consumer protection does not directly depend on choosing a particular type of model of financial supervision. Note that the United Kingdom has newly adopted post-crisis a twin-peak model, with the extant integrated model abolished, and that the Germany’s current integrated model has survived post-crisis domestic financial reforms. Based on the recent experiences of the United Kingdom and of Germany, the paper has arrived at several findings as follows. First, recent financial supervisory reforms in the UK and in Germany focused not on which specific financial supervisory model to choose but on how to reallocate powers of financial supervision among the agencies concerned. That is, the United Kingdom’s discontinuance and Germany’s continuance with the use of the integrated model, have been the mere outcomes that accompanied respective countries’ decisions regarding reallocating financial supervisory powers among the agencies concerned. Second, the institutional structure of a financial consumer protection regime entrenched seems to have little to do with a specific type of financial supervisory model in use. This is the case with both the UK and Germany. Third, financial consumer protection has been enhanced again in both countries, not by the choice of a specific type of financial supervisory model but by the improvement in policy substance. The paper next looks at what the Murray Inquiry appointed by the Australian government has recently done during the 11-month period of its activities to make its own recommendations for financial reforms, arriving at the finding that the Inquiry’s activities themselves have represented its genuine efforts to consult with stakeholders and the public in an open, transparent, and independent manner, to resolve differences in views, and possibly to come, as closer as possible, to social consensus. Such “a consultative approach” to financial reforms which the Murray Inquiry, being an ad-hoc expert committee equipped with good governance, took from the beginning in the design phase of financial reforms, may well have raised greatly the chances of success in the implementation phase to come. It is particularly worthy to note that the Murray Inquiry was supposed to work in ways that bear the closest resemblance to the world-renowned Wallis Inquiry of the mid-1990s. The Wallis Inquiry operated for a prescribed period of eleven months, producing the interim report and the final one, right in the middle and at the end of the period, respectively. Further, the Wallis Inquiry made most use of two rounds of submissions from stakeholders and the public for information purposes, opening the first round soon after the beginning of its operation and the second round right after the delivery of the interim report. These submissions, together with numerous meetings the Inquiry members had with a variety of stakeholders, domestic or abroad, were in effect the primary source of information that was used to shape up the Inquiry’s interim and final reports. Exactly these and other features of the Wallis Inquiry have been purposely built into the Murray Inquiry from the beginning by the Treasurer of the Australian Government. Needless to add, the Murray Inquiry has been equipped with such good governance as the Wallis Inquiry was able to enjoy. The paper has probed into the post-crisis financial reform experiences in the United Kingdom, Germany, and Australia, revealing that the most recent policy debate on reforming the financial supervisory system in Korea has left a couple of things to be desired, as stated at the outset. This finding has straightforward implications to full-fledged financial reforms that still remain long overdue in Korea.