Thursday, November 21, 2019
Swanson's Theory of Caring Essay Example | Topics and Well Written Essays - 1500 words
Swanson's Theory of Caring - Essay Example Clinical observations include temperature, blood pressure and pulses are normal. The model used in this context involves evaluating the caregiver’s attitude. They include being competent, meeting individual needs of the women and respecting their dignity. If proper care is given after a woman miscarries then she has the power to improve on her own. The scenario involves women who had early miscarries and those who had a late miscarriage. Nurses and midwives who care for these women are also considered in this situation. Swanson’s caring categories apply in this scenario that includes â€Å"Maintaining belief†, â€Å"knowing†, â€Å"being with†, â€Å"doing for†and â€Å"enabling†(Brier, 2008). The middle range caring theory The theory is built on the basic Swanson’s fundamental principles. These elements are the usual five that the doctor developed in her theory. The first developed by the doctor in 1991 element is referred to as â€Å"knowing†(Jansson & Adolfsson, 2011). It strives to understand an event in the way it has a meaning in another person’s life. It does not assume that one can know what the other feels or they way he or she is affected by the situation. Instead, it tries to understand and endeavor to take care of the person. The lives of the patients are important and the nurse is obliged to fully understand it. When a nurse embraces ‘knowing’, he or she develops empathy that is important for the care receiver. It encompasses observations, systematic research and prolonged clinical experience. The second process is ‘being with’ and it implies being available or with the woman. It implies stepping into her shoes, providing psychological, emotional and physical support (Krippendorff, 2004). It also involves effective communication and good listening skills. The midwife must display assertiveness, advocacy and competence to protect her interests. ‘ Doing for’ process requires maintenance of both knowledge and skills (Adolfsson et al., 2004). It entails doing what the other person would do to themselves and is a practical side and art of the midwife profession. It can be described as comforting, being protective, anticipatory. Nurses should practice it with competency and use all the available skills. The other process is ‘enabling’. This model describes it as facilitation of an individual’s passage through transitions from unfamiliar events (Jansson & Adolfsson, 2011). It is also referred to as empowerment. To empower the women, nurses must give them choices and be fully informed of them. This enables them to control their decisions regarding pregnancy resulting to equal partnership when giving care. For the midwives to give informed choices, they must be aware of all evidence-based guidelines that are relevant to them (Brier, 2008). Finally yet importantly, ‘maintaining belief’ is the f ifth process and entails fulfilling expectations using realities. However, it is only achieved if the expectations are real. Maintaining belief enables midwives â€Å"to know, be with and do for†(Kvale & Brinkmann, 2009). This final process brings all other processes together thereby forming one whole process. Brier (2008) describes it as holding individuals in esteem; believing in the person’s ability to realize set goals. The goal is to have a normal birth that includes a healthy infant and a well-being mother. In the real world, great emotions are always achieved with the importance of birth. The
Tuesday, November 19, 2019
Contemporary auditing and risk management Essay
Contemporary auditing and risk management - Essay Example In the event that our application is not complied with, we ought to cease to act as auditor to your company or to support the company in any revenue or tax matter. We must convey a copy of our resignation to an applicable office of the Revenue Commissioners within 14 days. We ought to report material pertinent offences to the administrator of the company in writing, in a period 6 months. Our costs or fees are calculated on the basis of the period spent on your matters by our staff and partners, and on the levels of expertize and obligation involved and expenses incurred and VAT. We shall not reveal, to potential competitors or third party, confidential information attained in during our professional duty without your permission unless a legal right to disclose. Under the law of our institution, we obliged to avail all documents available for scrutiny in the course of a general practice review. Where the engagement is dismissed the constitutional provisions governing dismissal or term ination of auditors in accordance to the Companies Act, shall apply. When we as auditors cease to continue in office, we have an obligation to notify UK Auditing and Accounting Supervisory Consultant within one month after the date of cessation. Once this letter has been approved, it will remain operative, from one audit employment to another, till it is replaced. We shall be thankful if you could sanction in writing your pact to the terms of our engagement letter, by appending your signature and returning copy of this letter, or inform us if they are not in accordance with your comprehension of our terms of appointment. Yours faithfully, _______________________ Loughran and Shrives Chartered Accountants We approve to the terms of this letter. ______________________________________ Signed for and on behalf of Land Securities Group Plc. Ethical Issues for New Clients Leaflet Study Title: Ethical Issues for New Clients Leaflet Firm: Loughran and Shrives Chartered Accountants Client: L and Securities Group Plc Ethical auditing is a procedure which examines the internal and external reliability of a company's values base. The key ideas are that it must be value-linked, and that it integrates a stakeholder method. Its purposes are two-fold: It is envisioned for transparency and accountability towards stakeholders and it is anticipated for internal regulation, to meet the moral objectives of the company. The importance of the moral audit is that it empowers the company to evaluate itself through a diversity of lenses: it incarcerations the company's ethical profile. Compliance with moral requirements involves: independence of a company with ethical standards supporting all stakeholders. Integrity of all the undertakings; where confidentiality, transparency, and accountability upheld. Objectivity and Professional Competence are added values. Our firm has been tested for the above ethical issues and proven fit of all. If you need any additional information now or at an y moment in the future, please contact: Name: Address: Phone No: Internal Control and Risk Management Letter The findings of the Cadbury Board provided an outline for corporate control which has become the foundation for the
Sunday, November 17, 2019
Identifying Quantifiable goals for the monitor, control and effectiveness of the marketing plan Essay Example for Free
Identifying Quantifiable goals for the monitor, control and effectiveness of the marketing plan Essay In order to evaluate, monitor, and control the effectiveness of the marketing plan, identifying quantifiable elements are detrimental to V-Techs financial gains and holdings. Marketing campaigns are the most costly measurement to the company and the launch of V-Techs Virta Window new product line in its marketing practices needs to show financial accountability. The focus of controlling and effectiveness to quantifiable elements reside in the metrics analysis of: 1. Revenue 2. Sales 3. Lead generation 4. Sales feed back 5. Return on investment 6. Customer retention Once the elements of V-Tech’s marketing campaign is identified, quantifiable goals can be set to counter financial loss and actionable measures can be taken to offset the losses for exchange of returnable gain. To begin identifying the elements of concern, V-Tech accounting management will look at: A. Product B. Place C. Price D. Promotion The product is an innovative technological breakthrough, meant to create real time life and learning experiences for its target audience. The product has little competition but may be hard to catch on in the marketplace and cause resistance within consumers. Quantifiable marketing goals that would need to be set: Be flexible to understanding that new products may need a longer campaign run. Placement metrics track the impact of consumer awareness and the impact of individual campaigns ability to reach marketing goals. Calculating metrics for analysis will determine if the whole of the marketing plan is bringing in more profit than it cost to run. Placement of the products marketing geographical and economic stature is an important quantifiable element. A metric analysis of location placement will measure the buying power and behavior of the consumer by geographic location. If the product is not selling well in placement, location factors may be that the target areas do not have the right selling class. Geographical metrics indicate a target audience income, medium house hold income, pay scale and if the economics of the area are depressed or thriving for businesses and product buying. The goal would then be to move the marketing campaign into better location areas where purchasing is a stronger asset for the product. Measuring the metrics of geographic locations can also help the company keep a competitive advantage as more technology companies advance to offering consumers a similar product. By being better able to understand consumer behavior by geographic V-Tech will have a higher ROI(return on investment) strengthen their marketing campaigns that keep customer retention, loyalty and target a larger audience base. Pricing by far may be the most important aspect in finding quantifiable controlling elements. A new product of technology changes the whole atmosphere of the market place from how it is developed to the price of manufacturing and distribution. The marketing of V-Techs new product is to reach a broad base of a consumer audience over affordability. This may cause a huge financial loss for the company. The campaign of the marketing needs increasing without the extra-added expenditures to cover the cost of loss and turn a profit. The reasoning behind quantifiable control is marketing the product to show value, and to measure financial gains where the product and marketing campaign will exceed profit and generate profit growth. The goals would then be to do a review of past sales to compare to sales of the new product and build on the strengths that previous campaigns have generated. A metrics analysis can be done in order to find out how many people clicked on an ad from online, what the numbers of new sales are and the percentage of new leads generated. From measuring sale metri cs, the company will be able to tweak the marketing campaign, generate a new marketing design, or repeat the campaign until the marketing goals meets its value. The company will also be able to determine the effectiveness of its Public relations effort in relation to its marketing efforts. A cost saving measurement to the company and the marketing campaign would be to get out in front of the face of the audience. Increase web activity, broaden the scope of social media awareness and depth in which marketing the product can help exceeded sales goals. The promotion of V-Techs product quantifiable control elements are to measure consumer awareness and set goals if the product is failing in brand awareness, website traffic, and not generating the sales lead expectations. Taking advantage of sending out Brand Ambassadors to area store locations and increasing trade market showings will promote and target the customer audiences awareness of the new product, how it is designed and will demonstrate why the consumer has a need to purchase the product. Social media marketing is limitless for brand awareness, in where a campaign can go to reach a borde r target buying audience. The quantifiable elemental goals are to take advantage of the use of the internet’s effectiveness of marketing to cost with web videos, direct coupons to the consumer, customer loyalty incentives, package discounts on education and parental sites. Identifying the quantifiable elements that help to control a marketing plan is an invaluable asset to V-Tech technologies and its new product launch. The analyzed metric data sets timely goals to which the company can redefine its control of marketing execution to increase sales and profits. The wealth of information extracted from the identification process takes on a new format that will find strengths and weakness of the consumer target audience, and will help to keep a competitive advantage as new companies move in the territorial locations of the innovative technology that V-Tech Windows will bring to a new market place.
Thursday, November 14, 2019
The Pandas Thumb -- Stephen Jay Gould Essay -- essays research papers
The Panda’s Thumb: More Reflections in Natural History With a touch of humor, geology, evolutionary theory, biology, cartoon characters and even some references to baseball, The Panda’s Thumb definitely makes excellent reading for people with all types of interests. The old clichà ©, â€Å"Don’t judge a book by its cover,†or in this case, title, holds true for The Panda’s Thumb. Theories concerning adaptations of the panda are only a fraction of the many exciting facts held within the pages of this publication. Gould is able to put what he writes about in words that are easy to understand without compromising the quality of the information. Many questions are raised in this book. Some questions that science just can’t answer at the moment. Time is a major theme in some of the essays in The Panda’s Thumb. I found these essays of utmost interest. Stephen Jay Gould writes as if you were sitting in a chair across from him having an insightful conversation. His essays are written in ways that are down-to-earth, entertaining, and easy to understand. Bits of humor are scattered throughout the book. One passage read, â€Å"The history of any one part of the earth, like the life of a soldier, consists of long periods of boredom and short periods of terror.†These little scraps of humor are placed in the just the right locations. After reading one of his essays concerning bipedalism (walking on two feet) I chuckled at the following statement, â€Å"It is now two in the morning and I’m finished...
Tuesday, November 12, 2019
Discovering Themes In Poetry
IntroductionPoetry at its deepest level, communicates unspeakable aspects of human experience. It is man’s greatest invention a channel wherein he gains the power to manipulate words to better express his thoughts and feelings. It has the unique ability to delve deeply in all topics imaginable, with which language becomes the media for translation and portrayal, offering an image of a world perceived and delivered through curt and descriptive words.Poets may venture a variety of themes, with all probability that each one may create literary pieces having the same theme. Edna St. Vincent Millay’s â€Å"What Lips My Lips Have Kissed†written on 1923 and Dorothy Parker’s â€Å"Review of the Sex Situation†both touched the theme on love. What made each of their works unique and set apart from one another is the poets’ outlook towards the subject.Similarity of the Poems AnalyzedMillay and Parker’s poems both divulge a sad conclusion on love brought about by a series of unsuccessful attempts on relationships. Contrary to what is implicated in Millay’s â€Å"What Lips My Lips Have Kissed†, the poem does not implicate romance and heart-warming recollections of past relationships. It talks about a woman constantly falling in and out of love and had come to realize that love is an elusive thing:                                   â€Å"I cannot say what loves have come and gone,                                   I only know that summer sang in me                                   A little while, that in me sings no more.†The last line implies resignation, a phrase which seems to have accepte d that â€Å"there is nothing more for me in this thing called love†. Summer passed her by, indicating her chances of finding her heart’s desire had come to pass as well. Further on, the last three lines implies either that she has aged and finding a man who will want her has become beyond probable or her heart has grown tired from flinging from one man to another and finding them â€Å"vanished one by one†. Parker on the other hand, seemed to be wary whether love will still bring good to her when she said:                                              â€Å"With this gist and sum of it,                                              What earthly good can come out of it?†Knowing that l ove is an unsteady and fleeting feeling, the possibility of loving someone only brings about sadness and pain. Love does not serve its purpose when it only breeds grief and unwarranted loyalty. What other purpose does love serve then given the situation? Love, according to the two poets, just seems to come and go and holding on to it and instilling in the consciousness that â€Å"Love is woman’s moon and sun†(Parker) will only be futile and will only cause more sad recollections and loneliness when â€Å"in the winter stands the lonely tree†(Millay).Parker and Millay’s sad conclusion on love was anchored on man’s fleeting emotions. Love, as Parker said, â€Å"is woman’s moon and sun†yet, â€Å"man delights in novelty†and when woman views man as her lord, â€Å"count to ten, and man is bored†. Despite showing the man how much the woman loves him, he seems to be discontented and will grow weary of the relationship. He g oes from one relationship to another, unconsciously leaving each woman behind, sad and broken hearted. Parker portrayed man as a soul discontented and never easily satisfied having one woman beside him. This then lead her to questioning whether love can still be good when man, as a partaker of love, is hardly satisfied with one. Millay seemed to have suffered from man’s uncanny ability to change heart in a short time, as a matter of fact, she had experienced quite a few of them when she opened her poem thus:                                   â€Å"What lips my lips have kissed, and where, and                                    when and why,                                    I have forgotten, and what arms have lain                                   under my head till morning; but in the rain                                   Is full of ghosts tonight, that tap and sigh†¦Ã‚                                   And in my heart there stirs a quiet pain                                   For unremembered lads that not again                                   Will turn to me at midnight with a cry.†The reader may convey a different image from what Millay narrated about her experiences. But the stirring in her heart proved it otherwise. The woman is clearly longing and looking for a true love, yet from all the men she had encountered, she appeared to have been used. It is an understatement that she easily responds to men who turn to her at midnight and cry hoping that in each man, there might be one who truly loves her and will stay. Millay’s experience is a confirmation of what Parker is saying when she concluded men to be easily bored and delighted in novelty.Point of Difference Found in the PoemsWhile both poets shared the same sad realization on love, the tone of the poem marked the difference with which each poet conveyed their message to their reader. Millay tells of a woman who constantly fall in and out of love and had come in full realization that not one of them really stayed long for her to remember:â€Å"I have forgotten, what arms have lain un der my head in the morning. In the end, the poem speaks of loneliness and longing, even regret for something that will never be fulfilled: â€Å"loves has come and gone†¦summer that sang in me†¦sings no more.†She likened each of her encounters to seasons and days, signifying her sadness and brief happiness as well as the gnawing loneliness as she discovered that summer ceased to sing to her. She uses strong and descriptive words that truly showed her feelings. The word vanished implied lost forever and with this she felt lonely. Each element of nature that Millay used – rain, ghosts in the night, midnight with a cry, winter and summer – amplified the strength of her longings and regrets.Parker on the one hand, is a woman who had a full grasp of the reality concerning man-woman relationship and the irony that exists between them. Her poem’s tone is that of sardonic and sarcastic, though, as a woman she still felt wary of what that realization on men implicated. Still, this made her poem less emotional than that of Millay despite the gravity of the message of her poem. Her curt portrayal of man and woman’s difference is to a point laughable yet contemplative; it makes one think for a while and comes to examine the validity of the poet’s claim. Even her concluding statement became less melodramatic:                                              â€Å"With this gist and sum of it,                                              What earthly good can come of it?†While Millay’s concluding statement:                                    â€Å"I cannot say what loves have come and gone,                                    I only know that summer sang in me                                   A little while, that in me sings no more,†divulged resignation and loneliness, Parker’s seemed to challenge her women readers to ponder on the truth of her claim. Though the impact of the question is sad in that it shows love as incompetent and unreliable, it does not invoke a feeling of pity or grief. Her poem’s tone is light and humorous yet very reflective.ConclusionThe theme love is indeed a very broad topic. It covers vast array of situations conceivable in man’s day to day experiences – from sad to hatred born from deceitful love; forbidden love when one or two people di sagrees with the relationship; unrequited love, when only one person experiences the feeling; loneliness when one does not find the right one; and mockery when one seems to have lost faith in love. It can also be love of parents to child, friend to another and human to animals. Discovering varied themes in poetry is indeed very trying for though it constitutes one value, it is further broken down to specific categories whichever it is that the poet find fanciful and relevant.
Sunday, November 10, 2019
Prayer, Humility, and Fate
Victoria Smith (H) English 3 Mrs. Parsons September 24, 2012 Prayer, Humility, and Fate In the story, Sir Gawain and the Green Knight, Gawain is developed as a Christian hero through his reliance on prayer and his humility which illuminates the theme that God controls fate. Gawain is developed as a Christian knight through his reliance on prayer. This trait is shown when Gawain is lost in a storm and does not know which way to turn. Gawain prays â€Å"Lord I beseech you†¦for some house where I may hear Mass devoutly†(Sir Gawain and the Green Knight 157, 159).Gawain demonstrates his dependence on prayer through this quote because it shows him praying to God for shelter in the storm and continually saying â€Å"Cross of Christ, bless me! †(Sir Gawain and the Green Knight 761). Gawain is established as a Christian hero through this quote because he relies on prayer in order to complete his task because he realizes that he cannot do it on his own. Immediately after G awain prays, God reveals to him a castle just ahead. Gawain’s establishment as a Christian hero illuminates the theme that God controls fate because it shows God granting his request and granting him victory.This is essential to the development of the theme because it clearly shows God altering Gawain’s fate which sets the course for the rest of the story. Gawain’s humility throughout the story also establishes him as a Christian hero. In contrast to Beowulf, a pagan hero, who often bragged about his strength and superior ability; Gawain, a Christian hero, is humble, often to the point of putting himself down. After Bertilak’s wife finishes telling Gawain how great he is, Gawain responds â€Å"I am all unworthy†¦to presume to the honor you ascribe me†(Sir Gawain and the Green Knight 1243, 1244).Gawain reveals his humility to Bertilak’s wife by not talking himself up, but humbling himself and claiming himself unworthy of such high prais e. Another example of Gawain’s humility can be found when he speaks to Arthur following the Green Knight’s challenge saying â€Å"I am the weakest†¦ and the least wise†and in response to Gawain’s humility, King Arthur gives Gawain God’s blessing and allows him to take the challenge in his place (Sir Gawain and the Green Knight 354).Gawain’s humility is essential in his development as a Christian hero because the Bible commands Christians to humble numerous times including the verse found in 1 Peter 5:6 which says, â€Å"Humble yourselves, therefore, under God’s mighty hand, that he may lift you up in due time. †As Christians, it is believed that God will exalt those who are humble. This belief is clearly shown through Gawain’s humility and success as a hero further proving the theme that God controls fate. Because of Gawain’s humility, and his reliance on prayer, God grants him success in the end and Gawain is exalted.
Thursday, November 7, 2019
2008 enhanced national, regional and international efforts to improve systemic stability in banking The WritePass Journal
How the global financial crisis of 2007/2008 enhanced national, regional and international efforts to improve systemic stability in banking Introduction: How the global financial crisis of 2007/2008 enhanced national, regional and international efforts to improve systemic stability in banking Introduction:Basel IPillar one Pillar two:Pillar three: II. Why regulate banks:III. The Financial Crisis: what happened?IV. An evaluation of Basel II as a uniform system of International banking regulation:1. Shortcomings of Basel I1.1. Procyclicality: 1.2. Unfair competition:1.2.1. Compliance Cost1.2.1.1.  Lack of supervisory uniformityV. Conclusion:ReferenceRelated Introduction: The global financial crisis of 2007/2008 has enhanced national, regional and international efforts, to improve the monitoring of systemic stability in banking. It exposed the weaknesses of the current regime the Basel I; thus leading to increase pressure for a tougher uniform regulation in the banking system. This paper briefly discusses the importance of banks and why they should be regulated; and the causes of the financial crisis. It then goes on further to discuss and evaluate in detail Basel II and the weaknesses of such a uniform system of International banking regulation. Basel I Following criticisms of Basel I and the increasing complex and global nature of bank operations; the Basel Committee on Banking Supervision hereon ‘the Committee’, published Basel II in 2004. Basel II is an international regulatory framework on capital adequacy of internationally active banks. It is an international standard for national regulators to follow when setting standards for minimum capital. For some, Basel II is one of the most successful uniform regulations, at least in the commercial field[1]. It has been signed by 12 countries and the wake of the financial crisis has led emerging markets and countries such as those in the Asian Pacific region to adopt some of its provisions. Despite its popularity amongst some, many banks still preferred to adopt Basel I because of the complex nature and cost of compliance associated with Basel II; which is feared will be transferred to borrowers through higher capital charges.[2] Though a soft law, it can be argued that Basel II is being adopted by banks not only to encourage international reciprocity, but also because of the benefits it has to offer. It offers an opportunity for banks to improve their sustainability and competitive advantage because it aims at securing financial stability through aligning capital closely with risks. Unlike Basel I, Basel II achieves this through securing sophisticated approaches to calculating credit and market risks and now operational risks. Others[3] have questioned the practicality of the minimum regulatory capital under Basel II. This is because banks tend to hold more capital due to market forces and national regulation may demand higher capital than Basel II. Whilst the above statement is true, one argues that an international standard of this nature is a necessity justified by the need to prevent systemic risk and to control banks from engaging in excessive risks. Thereby creating market discipline and inherently safeguarding the safety and soundness of the international banking system. Basel II operates on a three pillar approach: Pillar one addresses capital requirements and risks management. Pillar two addresses the supervisory review process. Pillar three addresses market discipline.   Pillar one It proposes three compliance methods for minimum capital based on the complexity of the bank. These include the standard approach and the Internal Ratings Based (IRB) approaches. Smaller banks are encouraged to adopt the standard approach and the larger banks the IRB approaches. Under the standard approach, assignment of risk weights are handled by external credit rating agencies, a commendable move as each bank’s risks will be defined more accurately. Nonetheless, this approach raises concern as it does not eradicate the risk of capital arbitrage nor complacency since it is not subjected to supervision unlike the IRB approach[4]. Moreover, the IRB approaches even though banks worry about compliance cost, is more likely than the standard approach to increase banks safety and soundness; simply because it empowers banks to understand and estimate their potential risks. Yet, how reliable is this approach? It is too complex and provides a bank with a lot of discretion which may be abused through creating risk models for regulatory purposes (regulatory arbitrage).[5] Nonetheless, this risk appears to have been reduced by pillar two which authorises supervisors to monitor and approve these models. However, it is believed that the IRB approaches could led to inconsistent regulatory application and treatment of risks by banks. A standardised approach on the other hand, eradicates such inconsistencies though it reduces the willingness to enhance risk controls[6]. Despite its weaknesses, pillar one seeks to promote stronger risk management practices amongst the banks, and therefore its main attraction. Although its name depicts it as a mere improvement of Basel I, Basel II does not incorporate a ‘one size fits all’ approach to risk management as that would hardly reflect the true nature of the borrower’s risk[7].  Pillar two: This pillar provides supervisors the power to review bank risk models and provide constructive feedback. It maintains control over bank practices and harmonises supervision. The discretion it offers is critical given the international scope of Basel II in order to fit into national regulations, differing bank practices and unforeseen innovations. Notwithstanding, there is no provision within the pillar for the extent of these supervisory powers or enforcement actions towards poorly managed institutions,[8] making the discretion too wide. Therefore, not only could such a wide discretion strain the relationship between the banks and supervisors; it could distort consistent regulatory application as supervisors can in effect enforce these standards however they see fit.[9] Consequently, this creates an unbalanced levelled playing field at an international level. Moreover, the Committee appears to have failed to give much thought to effectively linking pillar 1 and 2. Whilst banks ar e encouraged under pillar one to adopt banking strategies, pillar 2 significantly curtails this freedom. It is for these reasons that it is believed to be the weakest pillar of all and unlikely to promote soundness and stability[10]. Pillar three: Pillar three compliments the first two pillars and pays particular focus on enhancing transparency and prudential banking. Banks are required to publicly disclose information such as capital structure and capital adequacy. As a result, greater bank discipline will be achieved and consequently, economic efficiency. However, it fails to demand the disclosure of essential information in areas relating to credit risks and internal and external ratings by major banks. Additionally, banks may not be willing to disclose information where capital ratios are falling;[11] consequently, this pillar is only a ‘first step towards providing a foundation for market discipline’[12]  II. Why regulate banks: Basel II cannot be discussed in isolation without reference to banks and the role they play, because banks are the sole reason for the existence of Basel II. Banks are central to the economic activities of every society, what Cohen refers to as the ‘oil that lubricates the wheel of commerce’[13]. Moreover, they are vital source of sustenance of every economy because they provide finances for various commercial purposes as well as access to payment. Their activities have a huge impact on society and failure could result in dire consequences. In 2007, setbacks brought about by failure of Northern Rock resulted in systemic bank failures and eventually a recession in the United Kingdom (UK) economy. Society has had to bear the burden of sustaining the economy through spending cuts, redundancies, unemployment and increase in prices of goods and services. Additionally, banks are more reluctant to give out loans and people are less willing to spend and leading to a decl ine in economic growth. This partly explains why there are numerous on going debates on banking regulation. Banks have been described differently by different people. For some a bank is inherently a dangerous institution that will generate crises from time to time.[14] Banks are fragile and one bank failure could spread systemically with devastating results on society[15] and the international banking system as discussed in the previous chapter. Cranston[16] argues that a failure could cause customers in other banks to rush in to withdraw their savings; causing a liquidity crisis. Whilst there may be a real risk of this happening, it is argued that it is not always the case. Customers of other UK banks, for example, did not rush to withdraw money from their banks because of the failure of Northern Rock. Rather its collapse seemed to have raised public concern and awareness on the fragility and susceptibility of banks to collapsing. This confirms the perspective that bank failure and fragility does not mean that the financial system is failing but rather that it should be handle d carefully[17]. Additionally, consumer protection is necessary to prevent abuse of power by unscrupulous bankers who may encourage consumers to enter into financial transactions that may be unbeneficial to them. What is more is that, regulations should not only protect customers but also ensure that public confidence in the stability of the financial system is enhanced and protected.[18]These explain why banks need to be regulated so that their activities do no increase systemic risk, spread to other jurisdictions and plunge the economies into financial crisis like the case of 2007/2008. All in all, the underlying reason for regulating banks is to ensure bank soundness and stability both nationally and internationally, and to prevent systemic risks. III. The Financial Crisis: what happened? Similarly, Basel II cannot be discussed without a mention of the financial crisis, because, due to the crisis, the debate on Basel II and its role in the financial crisis has been intense. The recent financial crisis, â€Å"arguably the greatest crisis in the history of financial capitalism†[19] has raised a lot of political and academic debate on its causes including the following: Inadequate regulatory framework and supervision[20] Macro-economic imbalances and housing policies in the United States (US)[21] Poor risk management[22] The financial crisis has undoubtedly revealed inadequacies with current banking regulations. The international framework at the time, Basel II[23], was not adequately designed to prevent or deal with the global financial meltdown. However, should not be completely responsible for the collapse of the banking system. Many of the factors that led to the crisis were in place long before the establishment of Basel II[24]. Nevertheless, one would have expected Basel II to be designed to curb these known practices, inherently preventing or mitigating the crisis. It was inadequate and focused a lot on capital requirements with no guidance for liquidity management, an issue that is now to be addressed by Basel III[25]. For example, the Northern Rock crisis was not as a result of inadequate capital but a lack of a strong asset base[26]. Furthermore, at a domestic level, the UK’s banking regulation operated on a less invasive, less strict basis for fear of forcing out lucrative International banks to other countries.[27]This system may have worked for years, but it failed when it was most needed. The Financial Services Authority (FSA) failed to ensure adequate supervision of banking system, inherently failing to prevent the crisis or mitigate its effects[28]. This is evident in the fact that it: ‘focused excessively on risks at the level of the individual firm, rather than the aggregate picture, as well as placing an over-emphasis on conduct-of-business regulation rather than its prudential responsibilities’.[29] The FSA failed to take over Northern Rock during early stages; this is partly why the Special Resolution Regime[30] was introduced to give it powers of early intervention. Nonetheless, given the nature of the regulations in place and the global nature of the financial crisis it is doubtful that the FSA could have prevented systemic risks. In addition, to the origin of the crisis from the sub-prime markets in the US, the US economy was consuming more than it was producing as reflected in its large deficit.[31] Besides, there has been plenty of talk in the media about bankers being the cause of the crisis; with bankers such as Sir Fred Godwin at the forefront of the firing squad.[32] These bankers were recklessly engaged in affordable credit facilities and excessive remuneration. Financial innovation led to the creation of complex products and excessive risk taking by the banks that lacked adequate capital to safeguard against failures. However, the pitfalls in the banking system should not rest solely with bankers and the regulators but also with the consumers.[33] Consumers’ insatiable desire for high living standards and the economic growth of previous years also contributed to the recklessness and complacency of bankers. Whilst consumerism has been great for social growth, its negative impact on the econo my cannot be underestimated and should be partly blamed for the financial crisis[34]. IV. An evaluation of Basel II as a uniform system of International banking regulation: With an understanding of the origin and the aim of Basel II, this section will now closely examine and asses Basel II as a uniform system on international banking. Basel II meets the requirements of a uniform regulation through providing rigorous and detailed guidance on capital requirements applicable to all banks. It takes into consideration differences in bank sizes and operations. Moreover, its three compliance methods for capital requirements respectively apply uniformly to all banks depending on their size. Therefore, this reassures member countries and non-member countries that banks within their country and other countries are sufficiently safe and sound financially; and unlikely to create systemic risk or worsen an international financial crisis[35]. Hence, such reassurance helps to prevent banks from being perceived by the international community as dangerous, unattractive or left isolated in the international financial sphere. Moreover, its menu of approaches to capital requirements such as the standard approach is suitable for both developed and developing countries as well as small and large banks. Basel II reduces regulatory burden by ensuring that banks operating in more than one country comply with only one and similar financial regulation. If for example, a bank like HSBC with global operations has to comply with different banking and financial regulations in different countries, it might experience confusion due to the regulatory differences, which might lead to waste of valuable time and increase compliance cost which could be reinvested into other profitable areas. The result may be that, banks may refrain from international operations because the costs may outweigh the benefits. If this occurs, it could have dire consequences for some economies. Additionally, Basel II creates a level playing field where single set of rules and a standard level of supervision are uniformly applicable to all banks. For example, its capital requirements ensure that all banks hold a minimum regulatory capital and as such domestic banks cannot have lower capital rates in comparison to foreign banks. Implying that, domestic banks cannot hold less capital whilst investing the other into profitable ventures which may in turn increase their market share, thereby enhancing their competitiveness at the expense of foreign banks. Consequently, Basel II eliminates legal barriers and barriers to fair competition and by so doing, promoting efficiency, uniformity and prudential international banking[36]. Whilst Basel II has the ability to act as an instrument of fairness and uniformity in International banking, nevertheless, it has a number of shortcomings including procyclicality and unfair competition which will be discussed further below. 1. Shortcomings of Basel I 1.1. Procyclicality: As a uniform system of International banking, Basel II can create pro-cyclicality and disproportionate capital requirements which can lead to huge consequences on macroeconomics. It does not promote consistency throughout an economic cycle, an important component of banking stability. Under Basel II during a boom, banks will appear better capitalised, more likely to lend and make risky investment. However, when the value of assets starts dropping; these banks will appear to be below the minimum capital requirements. For example, the IRB approach is too sensitive to macroeconomic variations and will enhance pro-cyclicality unlike the standard approach which is designed with focus on the credit worthiness of the borrower throughout the economic cycle[37]. Ratings are updated annually under IRB approaches, therefore, during a recession a high risk borrower will reflect a higher probability of default, leading to higher capital charges. This over reliance on risk sensitivity distorts reg ulatory capital when banks are in need of it. The larger risk weights and strict regulatory capital requirements could lead to banks refusing to lend money during a recession and excessive lending during a boom. This could also have a significant impact on developing countries who may suffer a reduction in international lending or a significant increase in their borrowing cost; as they will be reflected as high risk borrowers with a high probability of default. Nevertheless, some argue that this will not be the case since banks price using economic not regulatory capital[38]. Supporters of Basel II argue that allowing banks to have their own risk model reduces the effect on pro-cyclicality.[39] Additionally, it is not entirely clear that Basel II will aggravate procyclicality because pillar one requires banks to stress-test their credit portfolios and rate borrowers according to their ability to pay back with a recession in mind. Additionally, pillar two requires supervisors to take into account procyclicality during the review process where the bank fails to do so.[40] Therefore, the procyclical effects of Basel II cannot be fully justified given the mechanisms in place under pillar one and two. Moreover, a certain degree of procyclicality is inevitable and appropriate if a bank’s capital is to be closely aligned to its risks for prudential purposes[41].Albeit this, Basel II is bad economics in its attempt to use market prices to predict market failures. It is procyclical, something a uniform regulation should avoid and that may explain why the Ba sel III aims to reduce procyclicality by demanding that banks hold a countercyclical capital buffer of 0% 2.5% by January 2019[42]. 1.2. Unfair competition: Enhancing uniformity and competitive equality is one of the main aims of Basel II. However, it is often difficult to draft rules that will take into account institutional and legal differences and yet apply similarly to all. However, Basel II in its attempt to move away from the ‘one size fits all’ approach may create a breeding ground for unfair competition because there are winners and losers. As it stands, larger banks are favoured because as a result of the nature and complexity of their operations they are more likely to qualify for the IRB model. Hence, they will enjoy a 2% 3% reduction in capital which may be invested in other profitable ventures. For example, in the EU, Basel II is applicable to all banks irrespective of their size or geographical location. This might give larger banks an unfair competitive advantage as the anticipation of lower regulatory requirements can cause them to manipulate risk portfolios and take on excessive risks. This may occur at th e expense of financial stability and smaller banks; that through the standard approach may have the quality of their portfolio worsen[43], causing them to lose market shares. Additionally, because of the wide supervisory powers under pillar two, supervision amongst countries may not be uniform and this may place other countries in a better competitive position than others. For example, countries that are stringent in the application of Basel II rules may be at a competitive disadvantage than countries that do not[44] because their banks may have more capital to invest in other areas. Moreover, Basel II does not apply to non-deposit taking lenders but who nonetheless compete in the financial market. Accordingly, they are placed in a better position, since they comply with lower capital rates than banks that have to comply with Basel II. 1.2.1. Compliance Cost The cost of introducing such a uniform system of regulation such as Basel II may be very high, placing an unnecessary burden on some. For example, the lack in uniformity of capital requirements may have a significant impact on emerging economies and markets as the risk management systems will be costly to introduce. Therefore, the balance of the cost and benefits for introducing and implementing it may be disproportionate.[45] On the other hand, more advanced and developed markets and economies are placed at an advantage. Largely because, aside from the benefit enjoyed by larger banks, the more developed economies and countries are more likely to be equipped and well-resourced to effectively supervise their banks.[46] Consequently, they are in a better position to enjoy the benefits of Basel II than the emerging economies or developing countries. Additionally, where these emerging economies and developing countries fail to implement Basel II they could become unattractive. Nonetheles s, these countries can start by introducing the less complex standard approach and then progress as the economies grows. 1.2.1.1.  Lack of supervisory uniformity As a uniform system the effective implementation Basel II is dependent on voluntary cooperation, yet the discretion and independence of supervisory powers and abilities under pillar 2 are too wide. This could create conflict where the home and host countries follow different schemes of regulations, for example a host country may impose in the place of the IRB approaches the standardised approach for a bank that follows the IRB in its home country in order to avoid lower capital requirements and competitive advantage over domestic banks. Additionally, Basel II formalises the role of external credit rating agencies in assessing bank risks. Whilst they play an important role, their record especially in the recent Asian crisis, raises concern because they are not regulated like the IRB models. The absence of a standard of ratings could lead to capital arbitrage caused by banks shopping for favourable ratings. Hence, encouraging unfair competition amongst agencies as well as intensifying procyclicality of bank lending[47]. This lack of uniformity in the regulation of rating standards and supervision could raise serious concerns in achieving its aim of soundness and stability. An organisation responsible for regulating these rating agencies should be created to ensure that they adhere to the same level of supervision as the IRB models.[48] This issue is now being tackled by Basel III by requiring the registration and supervision of credit agencies[49]. V. Conclusion: It is without a doubt that Basel II has contributed to prudential banking both at an international and national level; through its three pillars on better risk management, greater transparency and greater supervision. Through its pillars, Basel II offers many great opportunities for banks such as the ability to improve sustainability and competitiveness through closely aligning their risks with capital. It also reduces regulatory burden and to some extent creates a level playing field as it seeks to ensure that the same rules are applicable to all banks. A uniform international banking regulation is greatly desirable and needed as a result of the increasing global operations of banks and constant development in the financial sector. Regardless, Basel II does not fulfill the requirements of a uniform system. Its three pillars although developed with a great vision in mind, fail to make it a desirable piece of uniform regulation. Basel II as a uniform system of banking regulation focuses a lot on capital requirements, ignoring other important areas of banking such as liquidity management. As a result, it failed to prevent or mitigate the financial crisis and its effects. A harmonising international standard that seeks to achieve consistency yet is highly flexible such as Basel II is more than likely to fail. Basel II is over detailed, complex and vague as such relies a great deal on domestic supervisors for effective implementation, which will in effect fail to achieve consistency and uniformity, hence its main weakness. Whilst an international banking regulation is needed, Basel I is highly flawed, hence the reason for the new Basel II Accord. Reference [1] R Bollen, ‘The International financial system and future global regulation’ JIBLR (2008) 23(9), 462 quoting from Felson and Bilali, ‘The role of the bank’ (2004) http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744c0970000012fd01158ecc34d593cdocguid=I53D96EE057A211DDA3BBFE4B3DB72F6Bhitguid=I53D96EE057A211DDA3BBFE4B3DB72F6Bspos=8epos=8td=15crumb-action=appendcontext=37resolvein=true accessed 21st April 2011 [2] FJ Carden de Carvalho, Basel II: A critical assessment (March 2005) 1-4 ie.ufrj.br/eventos/seminarios/pesquisa/basel_ii_a_critical_assessment.pdf accessed 26th April 2011 [3] DK Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008) 141-143 [4] D Coskun, ‘Credit-rating agencies in the Basel II framework: Why the standardised approach is inadequate for regulatory capital purposes’ (2010 )JIBLR 157-169, 164 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744d05f0000012fd08ca524199ce1a6docguid=IB858F4F230AC11DF9C83BB18AACF6BDBhitguid=IB858F4F230AC11DF9C83BB18AACF6BDBspos=1epos=1td=1crumb-action=appendcontext=6resolvein=true accessed 21st April 2011 [5]D K Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008) 170 [6] A A Jobst, ‘Regulation of Operational risks under the new Basel Capital Accord critical Issues’, (2007) JIBLR 22(5) 264 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744d05f0000012fd0b2f898199ce260docguid=I25B9EA20E3D211DBB19ABA1496637E01hitguid=I25B9EA20E3D211DBB19ABA1496637E01spos=10epos=10td=24crumb-action=appendcontext=36resolvein=true accessed 21st April 2011 [7] G LIND, ‘Basel II – the new framework for bank capital’ Economic Review 2, 2005, 23 riksbank.com/upload/Dokument_riksbank/Kat_publicerat/Artiklar_PV/Lind.pdf accessed 16th April 2011 [8] D Vanhoose, ‘Market Discipline and Supervisory Discretion in Banking: Reinforcing or Conflicting Pillars Banking’ (Networks Financial Institute, Indiana State University) 2007 WP 06,26 networksfinancialinstitute.org/Lists/Publication%20Library/Attachments/56/2007-WP-06_VanHoose.pdf accessed 15th April 2011 [9] F J Cardim de Carvalho ‘Basel II: A critical assessment’,(March 2005) 19 [10] D Vanhoose, ‘Market Discipline and Supervisory Discretion in Banking: Reinforcing or Conflicting Pillars Banking’ (Networks Financial Institute, Indiana State University) 2007 WP 06, 25 networksfinancialinstitute.org/Lists/Publication%20Library/Attachments/56/2007-WP-06_VanHoose.pdf accessed 26th April 2011 [11] D K Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008) 178 [12] D Vanhoose, ‘Market Discipline and Supervisory Discretion in Banking: Reinforcing or Conflicting Pillars Banking’ (Networks Financial Institute, Indiana State University) 2007 WP 06, 24-25 [13] BJ Cohen, ‘In Whose Interest? International Banking and American Foreign Policy’ (New Haven, CN: Yale University Press 1986) cited in O JACOBSOHN, ‘Impact of Basel II on the South African banking system’ (2004) Magister Commercii in Business Management Rand Afrikaans University, 72 http://ujdigispace.uj.ac.za:8080/dspace/bitstream/10210/273/1/Dissertation7.pdf accessed 1st May 2011 [14]House of Commons Treasury Committee, ‘Banking Crisis: regulation and supervision’, 2008-09 available at parliament.the-stationery-office.co.uk/pa/cm200809/cmselect/cmtreasy/767/767.pdf accessed 15th April 2011 [15] This is commonly referred to as systemic risk. [16] R Cranston, Principles of Banking Law (2nd edn OUP 2002) 66-67 [17]MJB Hall and GG Kaufman, ‘International Banking Regulation’ (2002), 8 www.luc.edu/faculty//InternationalBankingRegulation7-12-02.doc accessed 15th May [18] This is also objective 2 of regulators laid down in s.4 of the Banking Act 2009 [19] A Peel, ‘The Turner Review’ (2009) 33 CSR 9, 70,1 lexisnexis.com/uk/legal/results/docview/docview.do?docLinkInd=truerisb=21_T11911683585format=GNBFULLsort=PUBLISHED-DATE,D,H,$PSEUDOLOSK,A,HstartDocNo=1resultsUrlKey=29_T11911683589cisb=22_T11911683588treeMax=truetreeWidth=0csi=280148docNo=1 accessed 15th April 2011 [20] C Chambers, ‘The Reforms: A Political Safe Haven or Political Suicide – is the Labour bubble bursting?’ (2011) JFRC 19(1), 2 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744c0970000012fcff20386f488fee9docguid=I6213C8F246DF11E0A6ECC01597E875E2hitguid=I6213C8F246DF11E0A6ECC01597E875E2spos=2epos=2td=15crumb-action=appendcontext=17resolvein=true accessed 15th April 2011; Deputy K Ekholm, ‘Some lessons from the financial crisis for monetary policy’ (4th December 2009) bis.org/review/r091214c.pdf accessed 15th April 2011 [21] F J Cardim de Carvalho ‘Basel II: A critical assessment’,(March 2005) 19 ie.ufrj.br/eventos/seminarios/pesquisa/basel_ii_a_critical_assessment.pdf accessed 26th April 2011 [22] IH-Y Chiu, ‘Legislation, regulatory and governance reforms in financial regulation: reflections on the global financial crisis’ Editorial, Comp Law,(2010) 31(6), 165 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744cc630000012fcfffcb546e891311docguid=IECBD4B406ACE11DFB49F99FD3B90BEF9hitguid=IECBD4B406ACE11DFB49F99FD3B90BEF9spos=15epos=15td=262crumb-action=appendcontext=30resolvein=true accessed 17th April 2011 [23] Basel II: The International Convergence of Capital Measurement and Capital Standards A Revised Framework, 2004 [24] E Fournier, ‘How Basel Should Change’ 28 IFLR 16 (2008-2010), 20 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744c09a0000012ffaeb98dabae8321bdocguid=I57126030E6A411DDB056C665510274F9hitguid=I57126030E6A411DDB056C665510274F9spos=1epos=1td=1crumb-action=appendcontext=7resolvein=true accessed 21st April 2011 [25] International Regulatory Framework for Banks, 2010 [26] R Bollen, ‘The International financial system and future global regulation’ JIBLR (2008) 23(9), 470 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744c0970000012fd01158ecc34d593cdocguid=I53D96EE057A211DDA3BBFE4B3DB72F6Bhitguid=I53D96EE057A211DDA3BBFE4B3DB72F6Bspos=8epos=8td=15crumb-action=appendcontext=37resolvein=true accessed 21st April 2011 [27] Economics online ‘Banking regulation’ economicsonline.co.uk/Business_economics/Banking+regulation.html accessed 15th April 2011 [28] ‘Bank regulation failed – Lords Committee’ (moneyfacts 2nd June 2009) http://moneyfacts.co.uk/news/economy/bank-regulation-failed-lords-committee/ accessed 16th April 2011 [29] DK Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008) 141-143 [30] Introduced the Banking Act 2009 [31] F J Cardim de Carvalho ‘Basel II: A critical assessment’,(March 2005) 19 ie.ufrj.br/eventos/seminarios/pesquisa/basel_ii_a_critical_assessment.pdf accessed 26th April 2011 [32] The Times Online, ‘Bankers to blame for the economic â€Å"mess†‘ (The Sunday Times 28th February 2008) http://business.timesonline.co.uk/tol/business/industry_sectors/banking_and_finance/article5820951.ece accessed 16th April 2011 [33] ‘Causes and costs of a global financial crisis’ (The Sunday Times 2nd October 2008) timesonline.co.uk/tol/comment/letters/article4862921.ece accessed 16th April 2011 [34] F J Cardim de Carvalho ‘Basel II: A critical assessment’,(March 2005) 19 ie.ufrj.br/eventos/seminarios/pesquisa/basel_ii_a_critical_assessment.pdf accessed 26th April 2011 [35] D K Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008) 178 [36] E Ferran, K Alexander, ‘Can soft law bodies be effective? The special case of the European Systemic Risk Board’ (2010) ELRev 35(6), 761 http://login.westlaw.co.uk/maf/wluk/app/document?src=rlsrguid=ia744d05e0000012fd0dd7691146455a0docguid=I1E797CE008C611E0A451F66F817AC0EEhitguid=I1E797CE008C611E0A451F66F817AC0EEspos=1epos=1td=4crumb-action=appendcontext=9resolvein=true accessed 26th April 2011 [37] D K Tarullo, ‘Banking on Basel: The future of International Financial Regulation (1st edn, The Peterson Institute For International Economics, 2008),178 [38] O JACOBSOHN, ‘Impact of Basel II on the South African banking system’ (2004) Magister Commercii in Business Management Rand Afrikaans University, 72 http://ujdigispace.uj.ac.za:8080/dspace/bitstream/10210/273/1/Dissertation7.pdf accessed 1st May 2011 [39] J Vinals ‘Procyclicality of the Financial System and Regulation’ Speech at the conference on Managing Procyclicality of the Financial System, Hong Kong, (22nd November 2004) bankofspain.org/webbde/es/secciones/prensa/intervenpub/archivo/vinals/relaci221104.pdf accessed 20th April 2011 [40] International Monetary Fund, ‘Will Basel II help prevent crisis or worsen them?’ Finance Development (June 2008), 30 imf.org/external/pubs/ft/fandd/2008/06/pdf/saurina.pdf accessed 1st May 2011 [41] International Monetary Fund, ‘Will Basel II help prevent crisis or worsen them?’ Finance Development (June 2008) 31 imf.org/external/pubs/ft/fandd/2008/06/pdf/saurina.pdf [42] The Basel III Accord basel-iii-accord.com/ accessed 6th May 2011 [43] E Feess and U Hege, ‘The Basel II Accord: Internal Ratings Approach and Bank Differentiation’, CFS Working Paper no 2004/25, 27 ifk-cfs.de/fileadmin/downloads/publications/wp/04_25.pdf accessed 5th May 2011 [44] F Roger Jnr, ‘Basel II: discussion of complex issues’. BIS Review 08/2003 bis.org/review/r030623a.pdf accessed 5th May 2011 [45] O JACOBSOHN, ‘Impact of Basel II on the South African banking system’ (2004) Magister Commercii in Business Management Rand Afrikaans University, 73 http://ujdigispace.uj.ac.za:8080/dspace/bitstream/10210/273/1/Dissertation7.pdf accessed 30th April 2011 [46] R Lall, ‘Why Basel II failed and why Basel III is doomed’, (October 2009),GEG Working Paper 2009/52, 10 globaleconomicgovernance.org/wp-content/uploads/GEG-Working-paper-Ranjit-Lall.pdf accessed 21st 2011 [47] D Coskun, ‘Credit-rating agencies in the Basel II framework: Why the standardised approach is inadequate for regulatory capital purposes’ (2010 )JIBLR 157-169 [48]E Fournier, ‘How Basel Should Change’, 28 IFLR 16 2009-2010, 17 [49] J Kollewe and G Wearden ‘Basel III: the main points’ (guardian.co.uk 13th September 2010) guardian.co.uk/business/2010/sep/13/basel-iii-the-main-points accessed 21st 2011
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