Creating an enabling environment for growth
Simplification, ease of use and innovation are threads that have run through the Commission’s recent policy development work and we plan to continue to focus upon them. As the Director General, William Mason, has noted previously, this is part of our commitment to ensuring the Bailiwick of Guernsey is appropriately positioned internationally as an attractive hub for business, with sensible and usable regulations that meet international standards.
Getting this balance right, and creating an enabling environment for growth, is not something the Commission can do in isolation, and we value the input, challenge and discussion with our finance industry.
This includes regular, formal and informal meetings and discussions with key industry associations, including GIBA (Guernsey International Business Association), GIFA (Guernsey Investment & Funds Association), GAT (Guernsey Association of Trustees), CBA (Commercial Bar Association), GAPP (Guernsey Association of Pension Providers), GIIA (Guernsey International Insurance Association), AGB (the Association of Guernsey Banks), and the GSCCA (Guernsey Society of Chartered and Certified Accountants).
Recently, we have held some roundtable discussions as part of our policy development engagement process. We have found these to be of real value, providing an opportunity to discuss challenges, barriers to entry and ideas from a wide range of industry perspectives. We would like to say thank you to those, including industry association representatives, who have participated in these, and look forward to organising more in the future.
Informal bilateral engagement, often over coffee, with firms and individuals also provides an effective channel to discuss specific areas of concern, ideas and opportunities.
We find this local input, which we combine with our understanding of international expectations developed through our work as members of various international standard setting bodies [1], helpful as we seek to formulate the optimal regulatory policies for the Bailiwick.
As a regulator we also devote time to supporting, participating and learning from international standard setting bodies. Understanding how global standards are evolving on a real time basis, enables us to understand policy objectives and then carefully consider how to implement measures in a proportionate way for the Bailiwick.
In terms of recent policy developments that are aimed at helping to create an enabling environment for growth, we have:
- Simplified our Private Investment Fund (PIF) regime, introducing added flexibility, with no compulsory audit requirement and no upper limit on the number of qualifying private investors, whilst retaining the speed to market and strong focus on corporate governance
- Updated the prospectus rules to provide enhanced clarity and to standardise some requirements to ensure that the Bailiwick’s investment and funds proposition is as accessible and as simple to use as possible
- Published an article outlining our approach to crypto currencies which reinforces Guernsey’s position as an international financial hub that is open to embracing digital assets.
This week, we have published a feedback paper on the future of sustainability reporting in the Bailiwick in response to the discussion paper we issued last year. Ahead of publishing this, we carefully considered the feedback received, along with recent international developments and worldwide political shifts, and considered how we may sensibly and pragmatically take action to support biodiversity, and mitigate against greenwashing, without imposing unnecessary regulatory burdens. The
feedback paper includes our approach to the Bailiwick’s adoption of sustainability reporting, including the voluntary adoption of the International Sustainability Standards Board (ISSB) reporting standards.
We like to think of ourselves as being an approachable and pragmatic regulator and welcome feedback and ideas from industry on how we can enhance and simplify our rules and regulations, whilst continuing to fulfil our statutory objectives appropriately. Whilst we cannot promise to implement all ideas, we will give them due consideration. Please do get in touch with one of us if you would like to discuss an innovative or simplification idea.
Gillian Browning
[1] These are IOSCO for the Investment Sector, GIFCS for the Fiduciary Sector, IOPS for the Pensions Sector, IAIS for the Insurance Sector, The Basel Committee for the Banking Sector, FATF for Combatting Financial Crime.
